OSHA Inspection: PROLON, INC.

Issued

May 19, 1994

Abate by

Oct 19, 1994

Penalty

Initial $2,750

General-duty citation text

Section 5(a)(1) of the Occupational Safety and Health Act of 1970:  The
employer did not
furnish employment and a place of employment which were free from
recognized hazards that
were causing or likely to cause death or serious physical harm to
employees:
(a)Compression Molding - On or about November 22, 1993 and at times prior
thereto, employees were exposed to the increased risk of cumulative trauma
disorders
because of: repetitive forceful finger exertions with the hands in
deviated wrist postures
to use tools to remove plates form molds; elevated and extended reaches to
load, unload,
and access various work items; and the task requires long periods of
standing.
(b)Injection Molding - On or about November 22, 1993 and at times prior
thereto,
employees were exposed to the increased risk of cumulative trauma
disorders and low
back injury because of repetitive forceful finger exertions to operate
manually powered
snips, side cutters, and pliers; repeated torso flexions and extended
reaches
to access
work materials; and the task requires long periods of standing.
(c)Finishing - On or about November 22, 1993 and at times prior thereto,
employees
were exposed to the increased risk of cumulative trauma disorders and low
back injury
because of use of bulky cloth gloves while performing repetitive finger
exertions to hand
buff cups; repeated torso twisting to access work items; repeated extended
reaches to
access work items; repeated extended reaches to access work items;
repeated torso
flexions to load shipping pallets; and the task requires long periods of
standing.
Among other methods, feasible and acceptable abatement methods to correct
these hazards are:
(1)Redesign the suction cup device and the compressed air wand used for
compression molding product removal such that they can be used with the
hand in an
ergonomically neutral posture.  Bending the handles of both devices should
permit
performance of the task with the wrist in a straight in-line alignment.
(2)Provide a powered snip, side cutter, or pliers, heated cutters or
grinders to
remove excess material from molded products.  Provided tools should reduce
or
eliminate repeated forceful and repeated hand exertions.
(3)Modify workstations to allow employees to perform the majority of tasks
in
ergonomically desirable postures.  These are generally though to
be:Reaches limited
to no more than 16 to 17 inches horizontally and vertically between waist
and shoulder
height; tasks should be able to be performed with the elbows in close to
the torso; work
should be performed within an arc of about 120 degrees in form of the
employee; and
torso flexions  should be limited to no more than 6 to 10 degrees from
vertical.
(4)Provide palletizers or elevate pallets such that employees can load
products
for
shipment while maintaining ergonomically neutral postures.
(5)Provide gloves which are made of a material which increases the
coefficient of
friction such that employees can reduce the finger force required to
perform tasks.
(6)Provide sit/stand stools, anti-fatigue mats and foot rests at all
applicable stations
such that employees working at standing tasks can have periods of rest.
(7)Provide adequate rest for employees by developing work rotations which
will
reduce the amount of stress placed on any single muscle group; and
providing adequate
rest periods during the work day which is generally considered to be a
minimum of at
least 15 minutes every two hours.
(8)Keep dies in good operational condition thereby decreasing the force
necessary
to remove the product from the molding machine and diminishing the flash
remaining on
the pieces.
(9)Jobs should be classified as to the nature and extent of exertion and a
rotation
schedule should be created that allows for as much variation as possible
in the
distribution and frequency of musculoskeletal activity.
(10)Establish a medical management program that facilitates employee
health and
wellness following surgery, treatment, or prescribed rest for cumulative
trauma disorders
by defining and providing light duty jobs and maintaining a conservative
return to work
approach.
NOTE:
Engineering controls implemented shall be evaluated and implemented by a
professional
ergonomist, physical engineer, or any professional who is adequately
trained in
anthropomorphic data, biomechanics and/or physiology.
(11)Develop and implement an Ergonomics program which includes all parties
involved in the work process and addresses these major points in an
ongoing training and
awareness program.
Step 1 -Develop and implement an ergonomic program for worksite analysis,
medical management, training and
education as detailed below in items 1 through 3.
(1)Worksite analysis to recognize and identify existing ergonomic risk
factors in the workplace
should be performed.  The analysis should include the development and use
of an ergonomic checklist and
worker survey/questionnaire.  Periodic surveys of the high risk work areas
shall be conducted at least
annually to evaluate the effectiveness of current work practices and
engineering controls.  Employee
participation in the ergonomic program should be encouraged through a
mechanism such as a
labormanagement
safety committee.  Worksite analyses performed should be
documented and can be used to
assist in the assignment of "light duty" jobs through the identification
and verification of low-risk factors.
(2)Medical management which include the maintenance of accurate
recordkeeping for cumulative
trauma disorders sustained by employees should be performed.  The program
should address early
recognition, evaluation and referral of cumulative trauma disorder cases,
and should include conservativetreatment and conservative approach for
employees to return to work.  Systematic worksite review by the
medical team should also be included in the program.
(3)Training and education program for exposed employees, including the
methods to evaluate the
effectiveness of the training shall be developed and implemented.
Periodic evaluation of the effectiveness
of the training shall be performed.  Training should address the hazards
associated with the job, operations
changes, the risks of developing cumulative trauma disorders, symptoms of
exposure and how to prevent
or reduce the occurrence of cumulative trauma disorders. On-the-job
training can be used for new and
reassigned employees to emphasize the development and use of safe and
efficient
techniques when
assigned to perform high-risk tasks.  A supervisor/management training
program should also be
implemented to allow recognition of the signs of cumulative trauma
disorders and to reinforce the
employer's ergonomics program.  Appropriate/sufficient training should be
provided for the personnel
responsible for the administration of the program.
(4)Hazard prevention and control which includes engineering, work
practices, administrative
controls and personal protective equipment shall be identified and
implemented.
(a)Administrative controls which are implemented shall be used to reduce
the duration,
frequency and severity of worker exposure to ergonomic stress.  These
controls may include job
rotation, reduction of repetitions and the preventive maintenance of
related equipment and
tooling.  The use of personal protective equipment shall be evaluated to
determine its
effectiveness and contribution to the ergonomic stress of the operation.
Step 2 -Submit to the Area Director a written detailed plan of abatement
outlining a schedule for the
implementation of the administrative, work practice and engineering
controls as detailed above in items
1-11.
All proposed control measures shall be approved for each particular use by
a person trained in
the evaluation of workplace conditions which cause cumulative trauma
disorders.
Step 3 - Implementation of administrative work practice and engineering
controls as descried in items 1-11.