OSHA Inspection: EMBACEE, INC.

Issued

Oct 18, 1989

Abate by

Mar 5, 1990

Penalty

Initial $560 · Current $560

Hazardous substances 8302

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 in that employees were exposed to
an increased risk of developing cumulative trauma disorder(s) from tasks
that they were performing:  engineering and administrative controls were
not implemented:
a) Lamp Assembly, 60's and 40's line, fifteen (15) employees who
repeatedly perform assembly line tasks which require various arm and
wrist postures (wrist flexion, extension and rotation, pinching and
thumb abduction) were exposed to ergonomic stresses, resulting in
cumulative trauma disorders. The illness and injury records for 1987
and 1988 documented two diagnosed cases of Carpal Tunnel Syndrome;
observed September 8, 1989.
AMONG OTHER METHODS, ONE FEASIBLE AND ACCEPTABLE ABATEMENT METHOD TO
CORRECT THIS HAZARD IS THE IMPLEMENTATION OF A COMPREHENSIVE REPETITIVE
STRAIN ILLNESS PREVENTION PROGRAM. THIS PROGRAM SHOULD INCLUDE AT A
MINIMUM, THE FOLLOWING ELEMENTS:
1) Indentification of all current employees who experience systoms
generally associated with repetitive motion disorders.
2) Perform an assessment using an ergonomic consultant of each operation
to identify mechanical stressors which may be produced by the
environment, tools or work methods.
3) Implementation of control measures for reducing job repetitiveness.
The following specific methods should be considered.
a) Install static are rests to decrease fatigue from reaching
postures. Minimize lower arm contact with sharp edges.
b) Investigate alternative means of holding the assembly while it is
being wired in order to eliminate harmful flexed wrist postures.
4) Provide training sessions to familiarize workers with the types of
movements and postures which precipitate cumulative trauma disorders.
5) Implementation of a workplace education and awareness program aimed
at the maintenance of muscloskeletal health and prevention of
injuries. Specific efforts should be expended in identifying and
reducing obstacles that prevent or deter a worker with symptoms from
reporting them.
6) Implementation of a medical surveillance and treatment program for
employees exposed to repetitive motion hazards. This program should
contain the following elements and be readily accessible to all
employees working at high risk jobs:
a) Medical examinations and counseling of employees as soon as
symptoms generally associated with repetitive trauma disorders
are reported.  Detailed examinations of each employees' specific
work history should be performed, and medical treatment, including
ice therapy, anti-inflammatory medications and exercise therapy,
should be considered where appropriate.  Employees should be
alerted to the minimal effectiveness of surgical interventions,
especially when returning to a job with high risk factors.
b) Employees should be prohibited from returning to their former jobs
following surgery until the work environment has been modified to
the extent that the risk of recurrent injury has been minimized.
c) Follow-up mild cases of impairment to ensure that medical
treatment and job changes have been effective.
d) Pre-employment examinations with special attention to medial nerve
distribution, muscular aberrations and wrist flexibility;
including both strength and stamina testing along with a review of
employee work histories relative to repetitive trauma disorders.
Step 1- Effective administrative protection, such as employee training,
physical assessment, job rotation, etc. shall be provided as an
interim protective measure until feasible engineering or
permanent administrative controls can be implemented which will
reduce employee exposure to nominal risks.
Step 2- Submit to the Area director a written detailed plan of abatement
outlining a schedule for the implement which will be reduce
employee exposure to nominal risk.
Step 2- Submit to the Area Director a written detailed plan of abatement
aoutlining a schedule for teh implementation of engineering or
administrative measures to control employee injury due to
repetitive motion tasks. Engineering controls to reduce
musculoskeletal stresses include, but are not limited to, job
redesign. This plan shall include, at a minimum, target dates
for the following actions which shoulde be consistent with the
dates required by this citation:
1) Evaluation of the conditions, locations and reptitive motion
activities that the employees are performing at the onset of
injuries.
2) Evaluation of aplicable control measure(s).
3) Procurement, installation and operation of selected control
measure(s).
All proposed control measures shall be approved for each
particular use by a person trained in the evaluation of
workplace conditions which cause repetitive motion disorders.
Thirty (30) day progress reports are required the abatement
period.
Step 3- Abatement shall have been completed by the implementation of
feasible engineering and/or administrative controls, upon
verification of their effectiveness in reducing the occurrence
of repetitive motion injuries.

Issued

Oct 18, 1989

Abate by

Mar 16, 1990

Penalty

Initial $560 · Current $560

Hazardous substances 8110

Issued

Oct 18, 1989

Abate by

Nov 17, 1989

Penalty

Initial $400 · Current $400

Hazardous substances 81108111

Issued

Oct 18, 1989

Abate by

Nov 17, 1989

Penalty

Initial $400 · Current $400

Issued

Oct 18, 1989

Abate by

Nov 2, 1989

Penalty

Initial $400 · Current $400

Issued

Oct 18, 1989

Abate by

Nov 17, 1989

Penalty

Initial $480 · Current $480

Issued

Oct 18, 1989

Abate by

Nov 2, 1989

Issued

Oct 18, 1989

Abate by

Nov 17, 1989

Issued

Oct 18, 1989

Abate by

Nov 2, 1989

Issued

Oct 18, 1989

Abate by

Nov 2, 1989

Hazardous substances 2580