OSHA Inspection: STANLEY WORKS, HARDWARE DIVISION

Issued

Jun 25, 1990

Abate by

Mar 28, 1992

Penalty

Initial $1,000 · Current $550 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
of serious physical harm to employees in that employees were exposed to
cumulative trauma disorders:
EMPLOYEES, ESPECIALLY FOR THE OPERATIONS IN THE FOLLOWING DEPARTMENTS,
WERE REQUIRED TO PERFORM DUTIES WHICH REQUIRE REPETITIVE HAND,WRIST,
ARM, NECK AND/OR SHOULDER MOTIONS RESULTING IN STRESSES LIKELY TO
CAUSE UPPER EXTREMITY CUMULATIVE TRAUMA DISORDERS.
A) DEPARTMENT 116
1) THE ASSEMBLERS OF BENCH WORKER D AT THE KICKPRESS STATION WERE
EXPOSED TO UNDUE REPETITIVE MOTIONS OF FINGERS, HANDS AND FOOT/LEG
RESULTING IN STRESSES TO FLEXOR TENDON OF THE WRISTS, HANDS AND LEGS
FROM FLIPPING HINGES UPSIDE DOWN WITH LEFT HAND/FINGERS, TAPPING THE
HEADS OF THE PINS ON THE TABLE TO INSERT PINS IN ABD FROM KICKING
THE FOOT PEDAL OF THE PRESS TO INSERT END BEARINGS IN.
SINCE THE ULTIMATE RESPONSIBILITY FOR HAZARD CORRECTION REST ON THE
EMPLOYER, FEASIBLE AND USEFUL METHODS TO ADDRESS THE PROBLEM OR REDUCE
THE HAZARD INCLUDE, BUT ARE NOT LIMITED TO:
a) USE OF MECHANICAL OR POWER FIXTURE TO INSERT END BEARINGS.
b) USE OF ALTERNATE METHOD(S) TO FLIP HINGES UPSIDE DOWN.
c) USE OF FIXTURE OR EQUIVALENT TO INSERT HINGE PINS IN.
d) USE OF ERGONOMICALLY DESIGNED, SWIVEL AND ADJUSTABLE CHAIR.
2) THE ASSEMBLERS OF BENCH WORKER D, ADJACENT TO THE KICK PRESS STATION,
WERE EXPOSED TO UNDUE REPETITIVE MOTIONS OF LEFT HANDS, FINGERS,
RIGHT ELBOWS AND NECK/BACKS FROM GRABBING AND HOLDING HINGES WITH
LEFT HANDS, TWISTING UPPER BODY TO RIGHT TO PLACE FINISHED HINGES
INTO TRAYS AND OBSERVING WORK WHILE SITTING ON A CHAIR WITH NECK
BENT DOWN.
SINCE THE ULTIMATE RESPONSIBILITY FOR HAZARD CORRECTION RESTS ON THE
EMPLOYER, FEASIBLE AND USEFUL METHODS TO ADDRESS THE PROBLEM OR REDUCE
THE HAZARD INCLUDE, BUT ARE NOT LIMITED TO:
a) USE OF ADJUSTABLE AND TILTABLE FIXTURE TO HOLD A STACK OF HINGES OR
EQUIVALENT TO ELIMINATE THE USE OF HAND AS A FIXTURE.
b) USE OF ERGONOMICALLY DESIGNED ADJUSTABLE AND SWIVEL CHAIR TO AVOID
TWISTING UPPER BODY AND STRESS TO THE BACK.
c) USE OF ERGONOMICALLY DESIGNED ADJUSTABLE HEIGHT WORK SURFACE TO AVOID
NECK BENDING DOWN.
d) USE OF TILT BOX OR EQUIVALENT TO HOLD PINS SO THAT EMPLOYEES CAN
REACH IN DIRECTLY RATHER THAN REACHING OVER THE EDGE OF THE PIN BOX.
B) DEPARTMENT 127
1) THE STRINGERS/RACKERS WERE EXPOSED TO UNDUE REPETITIVE MOTIONS OF
WRISTS, SHOULDERS AND BACKS RESULTING IN STRESSES TO FLEXOR TENDON
OF WRISTS (CARPAL TUNNEL SYNDROME), SHOULDER EXTENSION AND LOWER BACK
PAIN FROM STRINGING/UNSTRINGING HINGES ONTO HOOKS OF THE UMBRELLA
RACKS, REACHING OUT FOR HOOKS/RACKS AND FROM STANDING CONTINUOUSLY
ALL DAY WHILE WORKING AT STATION.
SINCE THE ULTIMATE RESPONSIBILTY FOR HAZARD CORRECTIONS RESTS ON THE
EMPLOYER, FEASIBLE AND USEFUL METHODS TO ADDRESS THE PROBLEM OR REDUCE
THE HAZARD INCLUDE, BUT ARE NOT LIMITED TO:
a) USE OF ERGONOMICALLY DESIGNED RACKS OR EQUIVALENT SO THAT EMPLOYEES
DO NOT HAVE TO REACH AROUND HOOKS AND BEND WRISTS TO STRING/UNSTRING
HINGES; E.G., TRIANGLE TYPE UMBRELLA RACKS RATHER THAN SQUARE TYPE.
b) REDESIGN OF THE CONVEYOR SYSTEM OR EQUIVALENT SO THAT EMPLOYEES
DO NOT HAVE TO REACH OUT FOR HOOKS OR RACKS.
c) USE OF ERGONOMICALLY DESIGNED ADJUSTABLE AND SWIVEL CHAIRS, SIT/STAND
STATIONS OR EQUIVALENT TO AVOID LONG STANDING FATIGUES.
2) BENCH AND MOD
a) THE 908 STRAP HINGE ASSEMBLERS WERE EXPOSED TO UNDUE REPETITIVE
MOTIONS OF FINGERS AND WRISTS RESULTING IN STRESSES TO FLEXOR TENDON
OF WRISTS AND FINGERS FROM PUSHING PALM BUTTON WITH MAINLYTHREE (3)
FINGERS.
b) THE 908 STRAP HINGE STAKERS WERE EXPOSED TO UNDUE REPETITIVE MOTIONS
OF WRISTS AND FINGERS RESULTING IN STRESSES TO FLEXOR TENDON OF
WRISTS/FINGERS FROM CLOSING HINGES MANUALLY AND THROWING FINISHED
HINGES TO LEFT.
SINCE THE ULTIMATE RESPONSIBILITY FOR HAZARD CORRECTION RESTS ON THE
EMPLOYER, FEASIBLE AND USEFUL METHODS TO ADDRESS THE PROBLEM OR REDUCE
THE HAZARD INCLUDE, BUT ARE NOT LIMITED TO:
a) REDESIGN OR REPLACE THE PALM BUTTON OR EQUIVALENT SO THAT THE
EMPLOYEES DO NOT USE FINGERS RATHER THAN PALMS TO ACTIVATE THE
PRESSES.
b) REDESIGN PIN INSERTING OR HINGE ASSEMBLING MECHANISM TO ELIMINATE
MANUAL CLOSING OF HINGES WHILE STAKING.
c) REDESIGN OF WORK STATION OR EQUIVALENT TO AVOID MANUAL THROWING OF
FINISHED HINGES.
C) DEPARTMENT 125
1) THE PACKERS OF 908 STRAP HINGES WERE EXPOSED TO UNDUE REPETITIVE
MOTIONS OF RIGHT HAND, SHOULDER AND BACK RESULTING IN STRESSES TO
FLEXOR TENDON OF WRISTS/HAND, EXTENSION OF SHOULDER INTO BOXES AND
FROM STANDING AND TWISTING CONTINUOUSLY ALL DAY TO REACH AND PACK
HINGES.
2) THE PACKERS OF PACKER D WERE EXPOSED TO UNDUE REPETITIVE MOTIONS OF
BOTH WRISTS/FINGERS AND RIGHT SHOULDER RESULTING IN STRESSES TO
FLEXOR TENDON OF WRISTS/HANDS AND EXTENSION OF SHOULDER FROM CATCHING
AND PLACING SCREWS ONTO PREPRINTED SHEETS, STRETCHING OUT BOTH ARMS
TO PLACE SCREWS ON DIFFERENT BLOCKS OF SHEETS AND TWISTING UPPER BODY
TO RIGHT FOR NEW SHEETS.
SINCE THE ULTIMATE RESPONSIBILTY FOR HAZARD CORRECTION RESTS ON THE
EMPLOYER, FEASIBLE AND USEFUL METHODS TO ADDRESS THE PROBLEM OR REDUCE
THE HAZARD INCLUDE, BUT ARE NOT LIMITED TO:
a) USE OF ERGONOMICALLY DESIGNED ADJUSTABLE AND SWIVEL CHAIRS OR STOOLS
AND REPOSITION BINS OF HINGES TO AVOID TWISTING UPPER BODY.
b) REDESIGN OF WORK STATION BY LOWERING BOX, FOLDING FLAPS AND PROVIDING
WIDER SUPPORT BARS ON FRONT OF BOX STANDS SO THAT EMPLOYEES CAN TILT
BOXES AND FEED HINGES DIRECTLY INTO BOXES RATHER THAN RAISING ARMS.
c) REDESIGN OF WORK STATION OR EQUIVALENT TO AVOID STRETCHING OUT ARMS.
d) REDESIGN OF SCREW EJECTING MECHANISM AND SCREW PLACING SYSTEM/PROCESS
OR EQUIVALENT TO AVOID TWISTING BOTH WRIST/HANDS TO CATCH AND PLACE
SCREWS ONTO SHEETS.
D) DEPARTMENT 103
1) THE BENCH AND MOC DOOR ROLLER CATCH ASSEMBLERS WERE EXPOSED TO UNDUE
REPETITIVE MOTIONS OF BOTH WRIST/FINGERS AND SHOULDERS RESULTING IN
STRESSES TO FLEXOR TENDON OF FINGERS AND SHOULDERS FROM PRESSING DOWN
PALM BUTTONS WITH BACK OF FINGERS, MAINLY FOUR(4) FINGERS - EXCEPT
THUMBS -BETWEEN FIRST AND SECOND KNUCKLES, WHILEBOTH SHOULDERS ARE
ELEVATED.
SINCE THE ULTIMATE RESPONSIBILITY FOR HAZARD CORRECTION RESTS ON THE
EMPLOYER, FEASIBLE AND USEFUL METHODS TO ADDRESS THE PROBLEM OR REDUCE
THE HAZARD INCLUDE, BUT ARE NOT LIMITED TO:
a) USE OF ERGONOMICALLY DESIGNED ADJUSTABLE CHAIRS OR EQUIVALENT TO
AVOID EMPLOYEES' SHOULDERS BEING RAISED.
b) REDESIGN, REPLACE THE PALM BUTTONS OR EQUIVALENT SO THAT EMPLOYEES
DO NOT USE BACK OF FINGERS TO PRESS PALM BUTTONS.
2) THE 1205 BASE STAMPING PRESS OPERATORS WERE EXPOSED TO UNDUE
REPETITIVE MOTIONS OF WRISTS/FINGERS, ELBOWS/ARMS AND RIGHT SHOULDERS
RESULTING IN STRESSES TO FLEXOR TENDON OF FINGERS, ELBOWS AND
SHOULDERS FROM HOLDING/PINCH GRIPPING PARTS WITH LEFT HAND WEARING
RESTRAIN DEVICE, LOADING PARTS WITH RIGHT HAND WEARING PULLBACK
DEVICE AND FROM MOVING RIGHT SHOULDER TO "BACK AND UP" DURING PRESS
DOWN CYCLES.
SINCE THE ULTIMATE RESPONSIBILITY FOR HAZARD CORRECTION RESTS ON THE
EMPLOYER, FEASIBLE AND USEFUL METHODS TO ADDRESS THE PROBLEM OR REDUCE
THE HAZARD INCLUDE, BUT ARE NOT LIMITED TO:
a) REDESIGN OF WORK STATION OR EQUIVALENT SO THAT EMPLOYEES DO NOT NEED
TO HOLD PARTS WITH LEFT HAND/FINGERS.
b) REDESIGN OF WORK STATION, USE OF ERGONOMICALLY DESIGNED ADJUSTABLE
CHAIRS AND/OR EQUIVALENT SO EMPLOYEES' ARMS, ELBOWS AND SHOULDERS CAN
BE AT REST POSITION RATHER THAN RAISED.
c) REPLACE, REDESIGN OF THE PULLBACK DEVICE OR EQUIVALENT TO ELIMINATE
OR REDUCE THE SWINGING RADIUS OF THE PULLBACK ARMS.
E) DEPARTMENT 105
1) THE BENCH AND MOC ASSEMBLERS WERE EXPOSED TO UNDUE REPETITIVE MOTIONS
OF ELBOWS, SHOULDERS, FINGERS AND ARMS RESULTING IN STRESSES TO
FLEXOR TENDON OF WRISTS/FINGERS, ABDUCTION OF ARMS/ELBOWS AND
EXTENSION OF SHOULDERS FORM FORCEFUL HAND GRIPPING AND PULLING WHILE
REACHNG BACK AND RAKING HINGES INTO SHOOT, PINCH GRIPPING AND OUTWARD
ROTATIONS OF RIGHT ARM WHIL PLACING HINGES INTO FEEDER AND FROM
CONTACT STRESS ON UPPER LEFT ARM AND FOREARM WITH THE EDGE OF HINGE
BIN.
SINCE THE ULTIMATE RESPONSIBILITY FOR HAZARD CORRECTION RESTS ON THE
EMPLOYER, FEASIBLE AND USEFUL METHODS TO ADDRESS THE PROBLEM OR REDUCE
THE HAZARD INCLUDE, BUT ARE NOT LIMITED TO:
a) REDESIGN OF WORK STATION OR EQUIVALENT TO ELIMINATE MANUAL RAKINGOF
HINGES.
b) PAD EDGE OF BIN WITH SOFT OR FOAM MATERIAL TO ELIMINATE CONTACT
STRESS.
c) USE OF ERGONOMICALLY DESIGNED ADJUSTABLE AND SWIVEL CHAIR OR REDESIGN
OF WORK STATION BY ROTATING THE FEEDER TO ELIMINATE RAISING HAND(S)
WHILE FEEDING HINGES.
2) THE BENCH AND MOD ASSEMBLERS WERE EXPOSED TO UNDUE REPETITIVE MOTIONS
OF HANDS/FINGERS, ARMS AND SHOULDERS RESULTING IN STRESSES TO FLEXOR
TENDON OF HANDS/WRISTS, ABDUCTION OF ELBOWS, EXTENSION OF SHOULDER
AND FATIGUE IN LOWER BACK AND NECK FROM STANDING CONTINUOUSLY ALL DAY
LOOKING AT THE WORK WITH NECK BENT DOWN WHILE WORKING AT STATION,
PINCH GRIPPING PARTS OF HINGES, TAPPING SIDE OF HINGES ONTO THE EDGE
OF BENCH, TAPPING THE HEADS OF PINS WITH PALM OF RIGHT HAND TO INSERT
PINS IN AND FROM TWISTING TO LEFT TO LOAD FINISHED HINGES INTO BOXES.
SINCE THE ULTIMATE RESPONSIBILITY FOR HAZARD CORRECTION RESTS ON THE
EMPLOYER, FEASIBLE AND USEFUL METHODS TO ADDRESS THE PROBLEM ORREDUCE
THE HAZARD INCLUDE, BUT ARE NOT LIMITED TO:
A) USE OF ERGONOMICALLY DESIGN ADJUSTABLE AND SWIVEL CHAIR OR EQUIVALENT
TO ELIMINATE TWISTING UPPER BODY, BENDING NECK DOWN AND TO HAVE
ELBOWS, ARMS AND SHOULDERS IN NATURAL COMFORTABLE POSITION.
B) USE OF MECHANICAL OR EQUIVALENT DEVICE(S) TO ELIMINATE TAPPING HINGES
ONTO THE EDGE OF MACHINE BENCH WHILE HOLDING WITH HAND.
C) USE OF MECHANICAL OR EQUIVALENT DEVICE TO INSERT HINGE PINS IN RATHER
THAN TAPPING WITH PALM.
F) DEPARTMENT 109
1) THE ELECTRIC HINGE ASSEMBLER(S) WERE EXPOSED TO UNDUE REPETITIVE
MOTIONSOF FINGERS, HAND AND ELBOWS RESULTING IN STRESSES TO FLEXOR
TENDON OF WRISTS, ABDUCTION OF RIGHT ELBOWS AND SHOULDER FROM
CLEANING OUT SMALL HOLES ON HINGES WITH HANDHELD DRILL BITS, PINCH
GRIPPING WIRE ENDS TO PUSH WIRES THROUGH THE HOLES, TAPPING END
FITTING WITH THE HANDLE OF HANDHELD SCREWDRIVER, THREADING HOLES ON
HINGES WITH HANDHELD THREADER, SCREWING END FITTINGS IN WITH HANDHELD
SCREWDRIVER, BRAIDING WIRES TOGETHER WITH FINGERS, STRIPPING WIRE
END WITH A HANDHELD WIRE STRIPPER, TWISTING WIRE ENDS WITH FINGERS
AND MAKING OPEN/CLOSE MOTIONS OF HINGES WITH BOTH HANDS WHILE
TESTING.
SINCE THE ULTIMATE RESPONSIBILITY FOR HAZARD CORRECTION RESTS ON THE
EMPLOYER, FEASIBLE AND USEFUL METHODS TO ADDRESS THE PROBLEM OR REDUCE
THE HAZARD INCLUDE, BUT ARE NOT LIMITED TO:
a) USE OF ERGONOMICALLY DESIGNED HAND TOOLS, POWER TOOLS, POWER FIXTURES
OR EQUIVALENT FOR CLEANING AND THREADING HOLES OF HINGES, HOLDING
HINGES DOWN, TAPPING AND SCREWING END FITTINGS IN.
b) USE OF MECHANICAL WIRE STRIPPER OR EQUIVALENT THAT WOULD ELIMINATE
FORCEFUL HAND GRIPPING AND PULLING.
c) REDESIGN OF TESTING EQUIPMENT AND PROCEDURE TO ELIMINATE MAKING OPEN/
CLOSE MOTIONS WHILE PINCH GRIPPING HINGES WITH BOTH HANDS.
2) THE MISCELLANEOUS MOD ASSEMBLERS WERE EXPOSED TO UNDUE REPETITIVE
MOTIONS OF BOTH HANDS AND ELBOWS/SHOULDER RESULTING IN STRESSES TO
FLEXOR TENDON OF WRISTS, ABDUCTION OF ELBOWS AND/OR EXTENSION OF
SHOULDERS AND FATIGUE IN LOWER BACK FROM STANDING CONTINUOUSLY ALL
DAY AT STATION REACHING OUT FOR PARTS AND LOADING/UNLOADING PARTS
INTO MACHINE.
SINCE THE ULTIMATE RESPONSIBILITY FOR HAZARD CORRECTION RESTS ON THE
EMPLOYER, FEASIBLE AND USEFUL METHODS TO ADDRESS THE PROBLEM OR REDUCE
THE HAZARD INCLUDE, BUT ARE NOT LIMITED TO:
a) USE OF ERGONOMICALLY DESIGNED ADJUSTABLE AND SWIVEL CHAIR OR
EQUIVALENT TO ELIMINATE TWISTING OF UPPER BODY.
b) REDESIGN OF THE WORK STATION OR EQUIVALENT OT ELIMINATE REACHING OUT
FOR PARTS.
c) REDESIGN OF THE WORK STATION, EQUIPMENT OR RAISE THE EMPLOYEES SO
THAT WRISTS WOULD BE IN STRAIGHT POSITION WHILE LOADING/UNLOADING
RATHER THAN BENT DOWN.
G) DEPARTMENT 117
THE PACKERS OF PACKER D WERE EXPOSED TO UNDUE REPETITIVE MOTIONS of
HANDS, FINGERS AND BACK RESULTING IN STRESSES TO FLEXOR TENDON OF
WRISTS, ABDUCTION OF ELBOWS OR EXTENSION OF SHOULDERS AND STRAINS IN
LOWER BACK FROM STANDING CONTINUOUSLY ALL DAY TWISTING AND REACHING
FOR BRACKETS, EXTREMELY HIGH RATE OF HAND AND FINGER MOTIONS WHILE
ALIGNING AND GRASPING BRACKETS FOR PACKING, WIDE GRIPPING FORCE WHILE
LIFTING AND PLACING BRACKETS INTO BOXES WITH ONE HAND AND FROM LONG
REACHING AND FORWARD BENDING TO FREE BRACKETS STUCK UNDER "FINGERS"
OF SHOOT.
SINCE THE ULTIMATE RESPONSIBLITY FOR HAZARD CORRECTION RESTS ON THE
EMPLOYER, FEASIBLE AND USEFUL METHODS TO ADDRESS THE PROBLEM OR REDUCE
THE HAZARD INCLUDE, BUT ARE NOT LIMIED TO:
A) USE OF ERGONOMICALLY DESIGNED ADJUSTABLE AND SWIVEL CHAIRS, SIT/STAND
STOOL OR EQUIVALENT; REDESIGN OF WORK STATION PLACING BOX ON STAND IN
FRONT OF EMPLOYEES AND OTHER MEANS TO ELIMINATE TWISTING AND WORK
WITH BOTH HANDS WHILE FACING THE CONVEYOR.
B) REDESIGN OF THE PRODUCTION STATION OR RELATED SYSTEM OR INSTALL IDLER
ARMS OR EQUIVALENT TO ALIGN BRACKETS IN CORRECT POSITION SO THAT
EMPLOYEES REQUIRE LESS MANIPULATION OF BRACKETS AND HANDS.
C) REDESIGN OR RAISE "FINGERS" TO HAVE BRACKETS SLIDE UNDER FREELY.
D) REDESIGN OF WORK STATION OR KEEP THE BOXES CLOSE TO EMPLOYEES IN
RIGHT POSITION SO THAT EMPLOYEES WOULD REQUIRE LESS WALKING AND
TWISTING/TURNING TO BOXES.
ABATEMENT SCHEDULE
STEP 1-
REDUCE THE PIECE RATE TO DECREASE THE AMOUNT OF REPETITIVE MOTION WORK
PER EMPLOYEE OR ROTATE EMPLOYEES.
STEP 2-
SUBMIT TO THE AREA DIRECTOR A WRITTEN DETAILED PLAN OF ABATEMENT
OUTLINING A SCHEDULE FOR THE IMPLEMENTATION OF ENGINEERING AND/OR
ADMINISTRATIVE MEASURES TO CONTROL EMPLOYEE EXPOSURE TO CUMULATIVE
TRAUMA DISORDERS (CARPAL TUNNEL SYNDROME) REFERENCED IN THIS CITATION.
THE PLAN SHALL INCLUDE, AT A MINIMUM, TARGET DATES FOR THE FOLLOWING
ACTIONS WHICH MUST BE CONSISTEN WITH THE ABATEMENT DATES REQUIRED BY
THIS CITATION.
A. EVALUATION OF THE EXTENT AND LOCATION OF THE HAZARD SOURCE.
B. EVALUATION OF CONTROL MEASURE OPTIONS.
C. SELECTION OF OPTIMUM CONTROL MEASURES.
D) DETERMINATION OF CONTROL MEASURE DESIGN.
E) ORDERING AND DELIVERING OF ANY EQUIPMENT AND MATERIALS.
F) INSTALLATION OF CONTROL MEASURES.
G) TRAINING OF EMPLOYEES:
1) JOBS WHERE THE POTENTIAL FOR REPETITIVE MOTION INJURIES/ILNESSES
EXIST.
2) ERGONOMIC METHODS OF HOLDING AND HANDLING MATERIALS AND PERFORMING
REQUIRED WORK.
3) PROPER OPERATION AND MAINTENANCE OF NEWLY IMPLEMENTED MEASURES.
H) ASSURANCE OF EFFECTIVE PERFORMANCE OF CONTROL MEASURES.
ALL PROPOSED CONTROL MEASURES SHALL BE EVALUATED FOR EACH PARTICULAR
USE BY A TECHNICALLY QUALIFIED PERSON. PROGRESS REPORTS ARE REQUIRED
DURING THE ABATEMENT PERIOD.
STEP 3-
CORRECTION SHALL BE COMPLETED BY THE IMPLEMENTATION OF FEASIBLE
ENGINEERING AND/OR ADMINISTRATIVE CONTROLS AND THEIR EFFECTIVENESS
AT ACHIEVING COMPLIANCE VERIFIED.

Issued

Jun 25, 1990

Abate by

Mar 28, 1992

Penalty

Initial $1,000 · Current $550 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
serious injury from lifting tasks without administrative or engineering
controls. The injuries have occurred throughout the plant but were
especially noted in the following departments:
A) DEPARTMENT 116
1) BENCH WORKERS WERE OBSERVED LIFTING A CARDBOARD BASKET CONTAINING
HINGE PINS FROM A WOODEN PALLET AND DUMPING PINS INTO HOPPER.
2) THE LEAD PERSON OBSERVED LIFTING, PUTTING A BAG OF CARBON POWDER
ON HIS SHOULDER AND CLIMBING UP THE LADDER/STEPS TO DUMP THE
CONTENTS INTO THE TANK.
B) DEPARTMENT 455
WAREHOUSE WORKERS WERE OBSERVED PICKING UP AND PUTTING CARDBOARD
BOXES OF PARTS FROM ROLLER CONVEYOR ONTO WOODEN PALLETS AS HIGH AS
SIX (6) TIERS.
C) DEPARTMENT 125
THE BLACK ADHESIVE COATER AND/OR HELPER WERE OBSERVED RESTACKING
SHEETS AS FOLLOWS: PICKED UP ON AT A TIME AND PUT A HAND FULL OF
SHEETS FROM PALLET(S) ONTO ANOTHER AND STACKED AS HIGH AS SEVEN (7)
FEET HIGH FROM THE FLOOR.
D) DEPARTMENT 103
TWO (2) MATERIAL HANDLERS (T/L OPERATORS) WERE OBSERVED PULLING STEEL
BOXES OF PARTS WITH A LONG STEEL HOOK FROM BENEATH POWER PRESSES TO
MIDDLE OF FLOOR AND THEN LIFTING AND PUTTING BOXES ONTO WOODEN PALLET
FOR FORK TRUCKING PURPOSE.
E) DEPARTMENT 109
1) THE BUFFER OF BUFFER CUTDOWN WAS OBSERVED PICKING UP AND PUTTING
STEEL BOXES OF PARTS, ONE AT A TIME, FROM A CART ONTO ANOTHER FOR
BUFFING OPERATION.
2) THE BUFFER OF BUFFER CUTDOWN WAS OBSERVED PICKING UP AND PUTTING
STEEL BOXES CONTAINING BUFFED PARTS FROM A TABLE ONTO WOODEN PALLETS
AS HIGH AS TWO (2) TIERS.
3) THE ELECTRIC HINGE ASSEMBLER WAS OBSERVED PICKING UP AND PUTTING
STEEL TRAYS OF PARTS FORM A WOODEN PALLET ONTO A CART AS HIGHAS
FOUR (4) TIERS.
F) DEPARTMENT 123
THE PACKER WAS OBSERVED PULLING AND LIFTING ONE END OF A STEEL BOX
CONTAINING SCRAP PARTS WITH A STEEL HOOK TO PUT THE BOX ON A WOODEN
PALLET.
THE EVALUATION OF THESE MANUAL LIFTING TASK INDICATES THAT EMPLOYEES ARE
EXPOSED TO AN INCREASED RISK OF MUSCULOSKELETAL INJURIES.
THE INJURY AND ILLNESS RECORDS FOR 1987, 1988 AND 1989 DOCUMENTED THAT
THERE WAS A PATTERN OF MUSCULOSKELETAL/OVEREXERTION INJURY.
ABATEMENT NOTE: THE REVIEW OF INJURY AND ILLNESS RECORDS FOR 1987, 1988
AND 1989 REVEALED AND DOCUMENTED THAT MUSCULOSKELETAL INJURIES OCCURRED
PLANTWIDE WITH A HIGHER INCIDENCE OF INJURY REPORTED FOR THE OPERATIONS
AND DEPARTMENTS LISTED ABOVE.
THE COMMON FACTOR THROUGHOUT THE PLANT IS THAT THESE MUSCULOSKELETAL
INJURIES RESULTED FROM LIFTING, CARRYING, STACKING AND/OR LOADING
BOXES AND TRAYS. AMONG OTHER METHODS, FEASIBLE AND USEFUL METHODS TO
REDUCE, ELIMINATE OR CORRECT THE HAZARD INCLUDE:
1) TRAINING AND SUPERVISON OF EMPLOYEES IN PROPER LIFTING AND HANDLING
TECHNIQUES AND IN THE RECOGNITION AND AVOIDANCE OF HAZARDS ASSOCIATED
WITH MATERIAL HANDLING.
2) EVALUATION OF THE LIFTING TASKS TO DETERMINE PROPER WEIGHT RANGES
FOR BOXES AND TRAYS.
3) ERGONOMIC REDESIGN OF WORK STATIONS TO PERMIT REPOSITIONING EMPLOYEES
BODIES WHICH WOULD ALLOW EVEN LIFTS, CLOSE TO THE BODY, AND AT A
HEIGHT TO MINIMIZE THE STRESS OF THE LIFTS.
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 ADMINISTRATIVE CONTROLS
CAN BE IMPLEMENTED OR WHENEVER SUCH CONTROLS FAILS TO 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
ADMINSTRATIVE MEASURES TO CONTROL EMPLOYEE INJURY DUE TO MANUAL LIFTING
TASKS. ENGINEERING CONTROL TO REDUCE MUSCULOSKELETAL STRESSES INCLUDE
BUT ARE NOT LIMITED TO, JOB REDESIGN, REDUCTION OF HORIZONTAL AND
VERTIAL LOAD DISTANCE FROM THE BODY, REDUCTION OF THE LIFTING FREQUENCY
OR WEIGHT AND USE OF MECHANICAL LIFTING AIDS. THIS PLAN SHALL INCLUDE,
AT A MINIMUM, TARGET DATES FOR THE FOLLOWING ACTIONS WHICH MUST BE
CONSISTENT WITH THE DATES REQUIRED BY THIS CITATION:
1) EVALUATION OF THE CONDITIONS, LOCATIONS AND MANUAL LIFTING ACTIVITIES
THAT EMPLOYEES ARE PERFORMING AT THE ONSET OF MUSCULOSKELETAL
INJURIES.
2) EVALUATION OF APPLICABLE CONTROL MEASURE(S).
3) PROCUREMENT, INTALLATION AND OPERATION OF SELECTED CONTROL MEASURES.
4) MONITORING TO ASSURE EFFECTIVE UTILIZATION OF THE CONTROL MEASURES.
STEP 3-
ABATEMENT SHALL HAVE BEEN COMPLETED BY IMPLEMENTATION OF FEASIBLE
ENGINEERING OR ADMINISTRATIVE CONTROLS, UPON VERIFICATION OF THEIR
EFFECTIVENESS IN REDUCING THE OCURRENCE OF MUSCULOSKELETAL INJURIES.

Issued

Jun 25, 1990

Abate by

Jul 23, 1990

Penalty

Initial $1,000 · Current $550 Reduced

Issued

Jun 25, 1990

Abate by

Jun 27, 1990

Penalty

Initial $1,000 · Current $550 Reduced

Issued

Jun 25, 1990

Abate by

Jul 23, 1990

Penalty

Initial $1,000 · Current $550 Reduced

Issued

Jun 25, 1990

Abate by

Jun 25, 1991

Penalty

Initial $1,000 · Current $550 Reduced

Issued

Jun 25, 1990

Abate by

Jul 23, 1990

Penalty

Initial $1,000 · Current $550 Reduced

Issued

Jun 25, 1990

Abate by

Jul 9, 1990

Penalty

Initial $1,000 · Current $550 Reduced

Issued

Jun 25, 1990

Abate by

Jun 25, 1991

Penalty

Initial $1,000 · Current $550 Reduced

Issued

Jun 25, 1990

Abate by

Mar 8, 1991

Penalty

Initial $1,000 · Current $550 Reduced

Issued

Jun 25, 1990

Abate by

Jul 23, 1990

Penalty

Initial $1,000 · Current $550 Reduced

Issued

Jun 25, 1990

Abate by

Jun 27, 1990

Penalty

Initial $1,000 · Current $550 Reduced

Issued

Jun 25, 1990

Abate by

Jun 27, 1990

Penalty

Initial $1,000 · Current $550 Reduced

Issued

Jun 25, 1990

Abate by

Jul 23, 1990

Penalty

Initial $1,000 · Current $550 Reduced

Issued

Jun 25, 1990

Abate by

Mar 8, 1991

Penalty

Initial $1,000 · Current $550 Reduced

Issued

Jun 25, 1990

Abate by

Jul 9, 1990

Penalty

Initial $1,000 · Current $550 Reduced

Issued

Jun 25, 1990

Abate by

Jul 9, 1990

Penalty

Initial $1,000 · Current $550 Reduced

Issued

Jun 25, 1990

Abate by

Jul 9, 1990

Penalty

Initial $1,000 · Current $550 Reduced

Issued

Jun 25, 1990

Abate by

Jul 23, 1990

Penalty

Initial $1,000 · Current $550 Reduced

Issued

Jun 25, 1990

Abate by

Mar 8, 1991

Penalty

Initial $1,000 · Current $550 Reduced

Issued

Jun 25, 1990

Abate by

Jul 23, 1990

Penalty

Initial $800 · Current $440 Reduced

Issued

Jun 25, 1990

Abate by

Mar 8, 1991

Penalty

Initial $900 · Current $450 Reduced

Issued

Jun 25, 1990

Abate by

Mar 8, 1991

Penalty

Initial $1,000 · Current $550 Reduced

Issued

Jun 25, 1990

Abate by

Jul 9, 1990

Penalty

Initial $800 · Current $440 Reduced

Issued

Jun 25, 1990

Abate by

Mar 8, 1991

Penalty

Initial $800 · Current $440 Reduced

Issued

Jun 25, 1990

Abate by

Jul 9, 1990

Penalty

Initial $800 · Current $440 Reduced

Issued

Jun 25, 1990

Abate by

Mar 28, 1992

Penalty

Initial $1,000 · Current $560 Reduced

Issued

Jun 25, 1990

Abate by

Mar 28, 1992

Penalty

Initial $1,000 · Current $560 Reduced

Issued

Jun 25, 1990

Abate by

Jul 9, 1990

Penalty

Initial $800 · Current $440 Reduced

Issued

Jun 25, 1990

Abate by

Jul 9, 1990

Penalty

Initial $700 · Current $390 Reduced

Issued

Jun 25, 1990

Abate by

Jul 9, 1990

Penalty

Initial $700 · Current $390 Reduced

Issued

Jun 25, 1990

Abate by

Jul 9, 1990

Penalty

Initial $600 · Current $335 Reduced

Issued

Jun 25, 1990

Abate by

Jul 9, 1990

Penalty

Initial $500 · Current $280 Reduced

Issued

Jun 25, 1990

Abate by

Jul 9, 1990

Penalty

Initial $500 · Current $280 Reduced

Issued

Jun 25, 1990

Abate by

Jul 9, 1990

Penalty

Initial $400 · Current $225 Reduced

Issued

Jun 25, 1990

Abate by

Jul 9, 1990

Penalty

Initial $700 · Current $390 Reduced

Issued

Jun 25, 1990

Abate by

Jul 23, 1990

Penalty

Initial $700 · Current $390 Reduced

Issued

Jun 25, 1990

Abate by

Jul 9, 1990

Penalty

Initial $700 · Current $390 Reduced

Issued

Jun 25, 1990

Abate by

Jul 9, 1990

Penalty

Initial $700 · Current $390 Reduced

Issued

Jun 25, 1990

Abate by

Jul 9, 1990

Penalty

Initial $600 · Current $335 Reduced

Issued

Jun 25, 1990

Abate by

Jul 23, 1990

Penalty

Initial $1,000 · Current $560 Reduced

Issued

Jun 25, 1990

Abate by

Jul 23, 1990

Issued

Jun 25, 1990

Abate by

Jul 23, 1990

Issued

Jun 25, 1990

Abate by

Jul 23, 1990

Penalty

Initial $700 · Current $390 Reduced

Issued

Jun 25, 1990

Abate by

Mar 28, 1992

Penalty

Initial $700 · Current $390 Reduced

Issued

Jun 25, 1990

Abate by

Mar 28, 1992

Penalty

Initial $800 · Current $440 Reduced

Issued

Jun 25, 1990

Abate by

Jul 23, 1990

Penalty

Initial $800 · Current $440 Reduced

Issued

Jun 25, 1990

Abate by

Mar 28, 1992

Penalty

Initial $800 · Current $440 Reduced

Issued

Jun 25, 1990

Abate by

Mar 28, 1992

Penalty

Initial $1,000 · Current $560 Reduced

Issued

Jun 25, 1990

Abate by

Mar 28, 1992

Penalty

Initial $900 · Current $500 Reduced

Issued

Jun 25, 1990

Abate by

Mar 28, 1992

Penalty

Initial $900 · Current $500 Reduced

Issued

Jun 25, 1990

Abate by

Mar 28, 1992

Penalty

Initial $700 · Current $390 Reduced

Issued

Jun 25, 1990

Abate by

Mar 28, 1992

Penalty

Initial $700 · Current $390 Reduced

Issued

Jun 25, 1990

Abate by

Mar 28, 1992

Penalty

Initial $800 · Current $440 Reduced

Issued

Jun 25, 1990

Abate by

Jul 9, 1990

Penalty

Initial $900 · Current $500 Reduced

Issued

Jun 25, 1990

Abate by

Jul 9, 1990

Penalty

Initial $900 · Current $500 Reduced

Issued

Jun 25, 1990

Abate by

Jul 9, 1990

Penalty

Initial $600 · Current $335 Reduced

Issued

Jun 25, 1990

Abate by

Jul 9, 1990

Penalty

Initial $800 · Current $450 Reduced

Issued

Jun 25, 1990

Abate by

Jun 27, 1990

Penalty

Initial $900 · Current $500 Reduced

Issued

Jun 25, 1990

Abate by

Jul 9, 1990

Penalty

Initial $600 · Current $330 Reduced

Issued

Jun 25, 1990

Abate by

Jul 23, 1990

Penalty

Initial $700 · Current $390 Reduced

Issued

Jun 25, 1990

Abate by

Jun 27, 1990

Penalty

Initial $700 · Current $390 Reduced

Issued

Jun 25, 1990

Abate by

Jul 23, 1990

Penalty

Initial $700 · Current $390 Reduced

Issued

Jun 25, 1990

Abate by

Jul 9, 1990

Penalty

Initial $1,600 · Current $900 Reduced

Issued

Jun 25, 1990

Abate by

Jul 9, 1990

Penalty

Initial $2,000 · Current $1,100 Reduced

Issued

Jun 25, 1990

Abate by

Jul 9, 1990

Penalty

Initial $2,000 · Current $1,100 Reduced

Issued

Jun 25, 1990

Abate by

Jul 23, 1990

Penalty

Initial $1,000 · Current $560 Reduced

Issued

Jun 25, 1990

Abate by

Jul 23, 1990

Issued

Jun 25, 1990

Abate by

Jun 27, 1990

Issued

Jun 25, 1990

Abate by

Jul 23, 1990

Issued

Jun 25, 1990

Abate by

Jul 23, 1990

Issued

Jun 25, 1990

Abate by

Jul 23, 1990

Issued

Jun 25, 1990

Abate by

Jul 23, 1990

Issued

Jun 25, 1990

Abate by

Jun 27, 1990

Issued

Jun 25, 1990

Abate by

Jun 28, 1990

Issued

Jun 25, 1990

Abate by

Jun 28, 1990

Issued

Jun 25, 1990

Abate by

Jun 28, 1990

Issued

Jun 25, 1990

Abate by

Jul 10, 1990

Issued

Jun 25, 1990

Abate by

Jun 28, 1990

Issued

Jun 25, 1990

Abate by

Jun 28, 1990

Issued

Jun 25, 1990

Abate by

Jun 28, 1990

Issued

Jun 25, 1990

Abate by

Jun 28, 1990

Issued

Jun 25, 1990

Abate by

Jul 10, 1990

Issued

Jun 25, 1990

Abate by

Jun 28, 1990

Issued

Jun 25, 1990

Abate by

Jun 28, 1990

Issued

Jun 25, 1990

Abate by

Jul 23, 1990

Issued

Jun 25, 1990

Abate by

Jul 23, 1990

Issued

Jun 25, 1990

Abate by

Jul 23, 1990

Issued

Jun 25, 1990

Abate by

Jun 28, 1990

Issued

Jun 25, 1990

Abate by

Jul 9, 1990

Issued

Jun 25, 1990

Abate by

Jun 28, 1990

Issued

Jun 25, 1990

Abate by

Jun 28, 1990

Issued

Jun 25, 1990

Abate by

Jul 9, 1990

Issued

Jun 25, 1990

Abate by

Jun 28, 1990

Issued

Jun 25, 1990

Abate by

Jun 28, 1990

Issued

Jun 25, 1990

Abate by

Jul 9, 1990

Issued

Jun 25, 1990

Abate by

Jul 9, 1990