OSHA Inspection: C A REED INC

Issued

Jan 10, 1990

Abate by

Aug 1, 1991

Penalty

Initial $1,000 · Current $675 Reduced

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
increased risk of cumulative trauma disorder(s) from the tasks that they
were performing and administrative or engineering controls were not
provided:
a) Distribution Center - employees selecting boxed paper party items
(distribution selectors); the evaluation of this repetitive motion
task indicates that employees are exposed to an increased risk of
repetitive motion injuries based upon studies of populations exposed
to similar lifting conditions. The injury and illness records for
1988 and 1989 documents a pattern of repetitive motion injuries,
October 27, 1989.
b) Crepe Department - feeder - packagers; the evaluation of this
repetitive motion task indicates that employees are exposed to an
increased risk of repetitive motion injuries based upon studies of
populations exposed to similar lifting conditions. The injury and
illness records for 1988 and 1989 documented a pattern of repetitive
motion injuries, October 27, 1989.
c) Napkin Department - feeder - packagers; the evaluation of this
repetitive motion task indicates that employees are exposed to an
increased risk of repetitive motion injuries based upon studies of
populations exposed to similar lifting conditions. The injury and
illness records for 1988 and 1989 documented a pattern of repetitive
motion injuries, October 27, 1989.
d) Napkin Department - master packer; the evaluation of this repetitive
motion task indicates that employees are exposed to an increased risk
of repetitive motion injuries based upon studies of populations
exposed to similar lifting conditions. The injury and illness records
for 1988 and 1989 documented a pattern of repetitive motion injuries.
October 27, 1989.
e) Plate Department - feeder - packagers; the evaluation of this
repetitive motion task indicates that employees are exposed to an
increased risk of repetitive motion injuries based upon studies of
populations exposed to similar lifting conditions. The injury and
illness records for 1988 and 1989 documented a pattern of repetitive
motion injuires, Octobe 27, 1989.
f) Tablecover Department - feeder packagers; the evaluation of this
repetitive motion task indicates that employees are exposed to an
increased risk of repetitive motion injuries based upon studies of
populations exposed to similar lifting conditions. The injury and
illness records for 1988 and 1989 documented a pattern of repetitive
motion injuries, October 27, 1989.
AMONG OTHER METHODS, ONE FEASIBLE AND ACCEPTABLE ABATEMENT METHOD TO
CORRECT THIS HAZARD IS THE IMPLEMENATION OF A COMPREHENSIVE REPETITIVE
STRAIN ILLNESS PREVENTION PROGRAM. THIS PROGRAM SHOULD INCLUDE AT A
MINIMUM, THE FOLLOWING ELEMENTS:
1) Identification of all current employees who experience symptoms
generally associated with repetitive motion disorders.
2) Perform an ergonomic assessment 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) Re-evaluate existing work allowances and production standards with
consideration of the economics of potential compensation costs for
repetitive strain injuries at these high risk operations.
b) Investigate the need for increased job rotation in work positions.
4) Implementation of control measures for reducing biomechanical forces:
a) Maintain machinery in optimal condition (particularly cutters and
shears) to reduce the force required for separation of products.
5) Provide training sessions to familiarize workers with an appreciation
of the types of movements and postures which precipitate cumulative
trauma disorders:
a) Investigate the movements and postures used in work positions that
may contribute to repetitive motion disorders and train workers in
alternate methods, if feasible.
6) Implementation of a workplace education and awareness program aimed
at the maintenance of musculoskeletal 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.
7) 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) 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.
b) Medical examinations and counseling of employees as soon as symptoms
generally associated with repetitive trauma disorders are reported.
Detailed examinations of each employee's specific work history should
be performed, and medical treatment, including ice therapy, anti-
inflammatory medications and exercise therapy, should be considered
when appropriate. Employees should be alerted to the minimal
effectiveness of surgical interventions, especially when returning
to a job with high risk factors.
c) 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.
d) Follow-up of mild cases of impairment to ensure that medical
treatment and job changes have been effective.
Abatement Schedule
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 implements which will reduce employee
exposure to nominal risk.
Step 2-
Submit to the Area Director a written detailed plan of abatement
outlining a schedule for the implementation of engineering or
administrative measures to control employee injury due to repetitive
motion tasks. Engineering controls to reduce musculoskeletal stress
include, but are not limited to, job design. This plan shall include,
at a minimum, target dates for the following actions which should be
consistent with dates required by this citation:
1) Evaluation of the conditions, locations and repetitive motion
activities that the employees are performing at the onset of
injuries.
2) Evaluation of applicable 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 during 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

Jan 10, 1990

Abate by

Jan 15, 1990

Penalty

Initial $700 · Current $375 Reduced

Issued

Jan 10, 1990

Abate by

Feb 9, 1990

Penalty

Initial $900 · Current $325 Reduced

Issued

Jan 10, 1990

Abate by

Feb 9, 1990

Issued

Jan 10, 1990

Abate by

Jan 20, 1990

Penalty

Initial $500 · Current $275 Reduced

Issued

Jan 10, 1990

Abate by

Jan 15, 1990

Issued

Jan 10, 1990

Abate by

Jan 20, 1990

Penalty

Initial $500 · Current $275 Reduced

Issued

Jan 10, 1990

Abate by

Jan 20, 1990

Penalty

Initial $600 · Current $325 Reduced

Issued

Jan 10, 1990

Abate by

Jan 15, 1990

Penalty

Initial $600 · Current $100 Reduced

Issued

Jan 10, 1990

Abate by

Feb 9, 1990

Issued

Jan 10, 1990

Abate by

Feb 9, 1990

Issued

Jan 10, 1990

Abate by

Jan 15, 1990