OSHA Inspection: CLINTON'S DITCH COOP CO., INC.

Issued

Nov 3, 1994

Abate by

Aug 3, 1995

Penalty

Initial $5,000 · Current $2,500 Reduced

General-duty citation text

Section 5(a)(1) of the Occupational Safety and Health Act of 1970:  The
employer did not
furnish employmnent 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 the hazards of repetitive motion and awkward postures
resulting in
musculoskeletal injuries of the back, hands, wrists, shoulders, arms,
knees, ankles and legs:
a) On or about May 10, 1994, employees involved in tasks including (but not
limited to) tank wash, tank fill, moving pallets on roller conveyors,
bottle
palletizer, pallet repair and packer/operator.
Feasible and useful abatement methods include, but are not limited to, the
following:
1)  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.
2)  Decrease elevated and extended reaches; reduce distance employees must
reach:
a)  Tank Wash:  Use of a ball-roller platform or rotatable turntable at
the wash
station such that employees can rotate the pallet and gain greater access
to
materials to be worked to reduce the distance employees must reach to
access
canisters.
b)  Tank Fill:  Elevate employees with relation to the tank tops to provide
positioning of arms in an ergonomically neutral posture.  Reposition
actuation
mechanisms.
c)  Bottle Palletizer:  Use of an adjustable height palletizer which will
elevate the
stack of cardboard as weight is removed will maintain the supply at a
desirable
height.
3)Decrease static loading on back and leg muscles created by extended
periods of
standing.
a)  Tank Wash, Pallet Repair, Tank Fill:  Provide anti-fatigue mats and/or
shoes
with well cushioned insteps and insoles for employees who have extended
periods
of standing.
b)  Tank Wash, Tank Fill, Pallet Repair:  Work-rest schedule should be
developed and enforced.  Generally, a minimum of a 15 minute rest break at
least
every two hours is required.
4)  Forceful exertions:
a)  Tank Fill:  Improve or replace powered conveyor with a system which
delivers the pallet all the way onto the transport trolley cart to
eliminate
manual
handling of the pallets.   Modify the conveyor line to reduce push pull
forces (if
the pallet must be manually moved) and limit push pull forces to less than
20 to
25 pounds).
b)  Tank Fill:  Install a handle or pull rope such that all pushing and
pulling tasks
can be accomplished at recommended heights (36 to 45 inches or at about
waist
height).
c)  Pallet Repair:  Redesign the pry bar to mechanically pull the board
out such
that the employee does not need to manually exert force or redesign the
pry bar
by using a lighter material and reduce the gap between the "u" shaped head
of the
pry bar to reduce the travel distance of the handle.
d)  Packer:  Discontinue the practice of stacking boxes on the elevated
conveyor.
Lower the conveyor to the point where employees can load boxes to it
without
elevating the arms above ergonomically desirable heights.  Use of a spring
loaded
palletizer will automatically raise the load as weight is removed from the
pallet
and eliminate the need to obtain boxes of materials from pallets placed on
the
floor.
Among other methods, one feasible and acceptable method to reduce these
hazards is to establish
and implement an Ergonomics Management Program which includes at a minimum
the following
elements:
A)  Engineering and Administrative Controls
1)  Proper engineering design of the job, work station, and equipment so
that the
work can be performed independent of specific worker characteristics and
techniques, evaluating and modifying as necessary.  This requires the job
be
made
to fit the worker and not make the worker fit the job.  Jobs should be
classified
as to the nature and extent of exertion.
2)  Instituting administrative controls, including the following:
a)Training new employees in safe work techniques;
b)Working with minimum strain on the body and minimizing the
application of forces with the fingers;
c)Job rotation and job enhancement, allowing for as much variation
as possible in the distribution and frequency of musculoskeletal
activity;
d)Adequate mandatory rest breaks;e)Implementation of an exercise program.
B.  Consultant Assistance
Hiring of a properly trained ergonomic consultant to assist in an analysis
of all
jobs, training employees and implementing the recommendations made.  A
qualified ergonomic consultant should conduct the job evaluations, seeking
input
from the employees actually performing the work.
C.Medical Management Program
Implementing a medical management program to monitor employees and prevent
early symptoms from progressing to injuries.  Preventative measures that
should
be instituted include early physical evaluation of employees with
musculoskeletal
symptoms; allowing adequate time off after a cumulative trauma disorder is
diagnosed; and providing access to trained medical personnel for
development and
implementation of conservative treatment measures upon detection of
cumulative
trauma disorder symptoms.
D.Training
Implementing a training program to alert employees on the hazards of
cumulative
trauma disorders and controls and work practices that can be used to
minimize
the hazards.  This includes designing and implementing a written training
program for managers, supervisors, engineers, union representatives, health
professionals and employees on the nature, range, causes, and means of
prevention of ergonomic related disorders.  The training program for new
and
reassigned workers should allow demonstrations of safe and effective
methods of
performing their job; familiarize employees with applicable safety
procedures and
equipment; allow the new or reassigned employee to work with a skilled
employee and/or provide on the job training for specific jobs; and allow
new or
reassigned employees to condition their muscle-tendon groups prior to
working
at full capacity rate which has been determined to be safe and will not
cause
adverse effects.