OSHA Inspection: CLUETT PEABODY & CO. INC. DIV OF BIDERMANN IND USA

Issued

Sep 28, 1990

Abate by

Mar 28, 1991

Penalty

Initial $9,000 · Current $4,500 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 the following employees
were exposed to cumulative trauma stressors of the hands, fists, arms,
neck and back:
a) Sewing machine operators and automated stitch operators regularly
performing small parts and mid-assembly operations; i.e., runon
sleeves, yokes bottom hems, folder fell, cuffs and collars.
b) Heat set operators, pressers, buttoner, folders, and packers
performing repetitive motion functions with less than thirty (30)
seconds cycle.
c) Utility people and instructors performing the same operations on
an irregular basis.
Feasible methods of abatement for these instances include, but are not
limited to, the following:
Establish a comprehensive ergonomic control program, including
engineering and administrative control, and close medical
surveillance, as described at the end of the citation.
Replace current top switch collar machines with automated stitcher.
Install automatic counting device on sewing machines to eliminate
operator use of manual counters.
Provide specialized training to sewing machine operators, automated
stitch operators, instructors, utility workers, folders, buttoners,
pressors, heatset provide necessary time for work harden and warm-up
exercises for job activities involving significant cumulative trauma
stressors.
Investigate sit/stand options.
Relocate/reposition the sewing machines so that the worker can sit
erect and perform his/her tasks. If the sewing machine is canted to
the right or left, the machine operator could center his/her
shoulders, neck, and to be able to observe the active sewing area.
As an alternative, if mirrors were placed on supports at the sides of
the machine, the operator could observe the active sewing area by
looking into the mirror.
Change the angle of incline of the sewing machine by moving the
neck-end backwards and angling the active sewing area upward, so that
each worker can operate the machine while sitting with an erect
position.
Pad the edges of all sewing work stations subject to machine
operators resting or supporting forearms.
Change foot controls connected to mechanical rod to an electric
switch which can be moved to fit variable employee positions, leg
lengths, or used as knee control. This will allow additional use as
knee control. This will allow additional use of swivel chairs.
Elements of a Comprehensive Ergonomics control program
In addition to specific abatement methods described in the instance
descriptions, general methods of abatement for item 1-5 are necessary
componets of a comprehensive health program for CTS. These feasible
methods of abatement include, but are not limited to, the following:
1) Conduct an ergonmic assessment, including worker provided information
of each operation, to determine the stressors that are present.
Identification of all current employees with symptoms generally
associated with repetitive motion disorders. By using questionnaires
and supporting examinations done by the plant nurses and/or doctors,
determine the current health conditions of the plant workers.
Rate operations according to CTS potential to support effective use
of job rotation and light duty transfers. Redesign supervisor
evaluations in accident reports of CTS to standardized and specify
stressors involved.
2) Implement administrative control measures aimed at reducing the
degree of repetitiveness of jobs. Specific recommendations include:
Rotate employees between jobs requiring different types of motions.
Require employee break periods at a frequency greater than two (2)
ten (10) minute breaks per day for operations identified as high risk
for repetitive strain injuries.
Potentially restrict job transfers to high stressor jobs by employees
suffering pain and impairment from CTS.
Reevaluate existing work allowances and production standards with
consideration of the economics of potential compensation costs for
repetitive strain injuries at these high risk operations. Time study
evaluations must be based on work activities emphasizing neutral
postures and motions.
Enrich job tasks performed so that completion time equals or exceeds
45 seconds. Vary job activities.
3) Implement control measures to increase adjustablity of position for
the job and reduce awkward postures. The following specific methods
should be considered at all the cited operations:
Utilize spring loaded trimming scissors with plastic handles
ergonomically designed to spread forces over the entire surface of
the scissors grip throughout the plant. Provide ergonomically correct
chairs.
These chairs should be equpped with five legs and wheels, seat
rotation, and seat and back adjustments that can be operated by
levers or controls especially made for this purpose. The chairs
shall be padded and the chair back should include a shaped support
for the lumbar region of the back.
Install thread saver attachments to reduce the amount of thread
trimming necessary machine operators.
Change foot controls connected to mechanical rod to an electric
switch which can be moved to fit variable employee positions, leg
lengths, or used as knee control. This will allow additional use of
swivel chairs.
Assure that the allowed lifting weights found in the National
Instittue of Occupational Safety and Health (NIOSH) "Work Practices
Guide for Manual LIfting," March 1981, are followed.
4) Implement a workplace education and awareness program aimed at the
maintenance of musculoskeletal health and prevention of injuries.
Specific efforts should be expended identifying and reducing
obstacles that prevent or deter a worker with symptoms from reporting
them.
Conduct training for workers, union representatives, maintenance,
engineering and management, to make people aware of the following:
a) Motions and postures that precipate back, shoulder, and neck strain.
b) Motions and postures that lead to repetitive motion disorders of the
shoulders, arm, elbows, wrists, hands, and fingers.
Use video tapes to correct unsafe practices of employees involved in
sewing.
5) 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:
Program supervision and evalution by a single physician to promote
consistent and correct treatments and to act as case manager.
Pre-employment examinations.
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, i.e., work harding
should be used and surgery delayed until after conservative treatment
has been tried.
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.
Follow-up of mild cases of impairment to ensure that medical
treatment and job changes have been affective.
Contract doctor should make frequent visits to the worksite; twice a
year and whenever major process changes are made. If light duty jobs
are assigned to injured employees, doctors should recommend such jobs
in concert with employees and management.

Issued

Sep 28, 1990

Abate by

Oct 20, 1990

Penalty

Initial $300 · Current $300