OSHA Inspection: CLOVERDALE FOODS COMPANY

Issued

Dec 7, 1999

Abate by

Jun 11, 2002

Penalty

Initial $2,500 · Current $2,500

General-duty citation text

to connective metal on either side of the hand.  The connective metal then
runs up
and around the hand and attaches to the hook.  With this type of design,
there is no
metal which runs between the fingers and the chance of contact trauma to
the sides of
the fingers is greatly reduced.
(vii) Develop a conveyor system to transport materials around the plant
rather than
Section 5(a)(1) of the Occupational Safety and Health Act of 1970:  The
filling and emptying transport tubs.  Utilizing a dumping device at a
centralized
station  would allow for emptying of large tubs and boxes without
repeatedly bending
and reaching to access product.  This central station could then be linked
with the
other work stations via conveyor.  Transport conveyors could deliver
product to
employees at ergonomically desirable heights and distances.
Engineering Controls for Hanging Bacon/Brine Injector
employer did not
(i)   Provide a Lifter/Tilter which will lift and tilt the supply box such
that bacon
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 required to perform tasks involving hazards resulting in
stressors that had
caused, were causing, or were likely to cause musculoskeletal disorders
(MSDs).  These
slabs will tumble to the employee.   Such a device is available from
commercial
vendors and will lift the tub while tipping it toward the worker.  This
motion raises
the elevation of materials within the tub and allows the materials to
slide or tumble
down toward the employee eliminating or greatly reducing the need to bend
forward
at the waist or to reach.  Utilization of such a device will allow
observed hazards are summarized below:
employees to
maintain ergonomically neutral postures during the entire work shift.
Additionally,
since the slabs will be closer to the employee, the need for forceful
exertions with the
hook should be greatly reduced.  Some lifts and transfers of slabs with
this type of
workstation may not require the use of hooks at all.
(ii) Develop a slab hanging station that utilizes a mechanical lifting
device to move
slabs from a loading area to the racks.  Slabs would be placed on bars at
an
ergonomically designed station where torso flexions, twisting, and
elevated
and
extended reaches could be limited.  With this type of station, employees
could hang
the slabs while keeping their elbow in close to the torso.  After a  bar
has been filled,
it then could be lifted using a mechanical device.  This type of device
could be in the
form of a pivot mounted strong arm or could be supported overhead by  I
beams.
Mechanical power would be used to lift the bar containing the slabs into
position.
Employees would simply position the bar onto the rack with all lifting and
lowering
being performed by the mechanical device.
(iii) Discontinue use of the top levels of the loading racks.  This
position requires
extended reaches above head height which greatly increase the hazard of
the task.
The middle three levels of the rack can be used while maintaining the
elbow in close
to the torso.
(iv) Develop a new work station which incorporates a scissors lift to
lower the rack so
employees can load it while maintaining their bodies in an ergonomically
neutral
posture.  The overall station would need to be elevated or the scissors
lift would need
to be placed in a cutout in the floor so when the lift was fully lowered,
the top level
of the rack is at about the employees' waist height.  Then as the rack is
filled, it
could be elevated so the lower levels of the rack could be loaded.
(v) Provide a stirrup design of hook as an alternative for employees who
may be
experiencing contact trauma to the insides of their fingers from the T
handle design.
This type of hook has a bar which runs across the palm of the handle and
is attachedto connective metal on either side of the hand.  The connective
metal then runs up
and around the hand and attaches to the hook.  With this type of design,
there is no
metal which runs between the fingers and the chance of contact trauma to
the sides of
the fingers is greatly reduced.
(vi)  Develop a conveyor system to transport materials around the plant
rather than
filling and emptying transport tubs.  Utilizing a dumping device at a
centralized
station would allow for emptying of large tubs and boxes without
repeatedly bending
and reaching to access product.  This central station could then be linked
with the
other work stations via conveyor.  Transport conveyors could deliver
product to
employees at ergonomically desirable heights and distances.
Engineering Controls for Boning Line
(i)   Remove or significantly reduce the size of the stop bar on the
boning table feed
conveyor.  Employees should not need to pull hams up and over the stop bar
when
moving them into position for processing.  Removal of the stop bar should
allow the
ham to come directly to the employee without the need for forceful
shoulder
and
finger exertion to pull the hams into position.
(ii) Provide a stirrup design of hook as an alternative for employees who
may be
experiencing contact trauma to the insides of their fingers from the T
handle design.
This type of hook has a bar which runs across the palm of the handle and
is attached
to connective metal on either side of the hand.  The connective metal then
runs up
and around the hand and attaches to the hook.  With this type of design,
there is no
metal which runs between the fingers and the chance of contact trauma to
the sides of
the fingers is greatly reduced.
(iii) Elevate the current platform to reduce extended reaches while making
cuts.
Provide appropriate height stands for all employees that are working on
the boning
line.
Engineering Controls for Boxers
(i)   Provide a palletizer or scissors lift at all pallet loading areas
such that all lifts can
be performed with the torso in an upright posture. A palletizer or
scissors lift will
allow the height of the load to be continually adjusted so all lifts can
be performed at
approximately waist height.
(ii)  Addition of a turntable on the palletizer or scissors lift will
allow employees to
rotate the pallet during the loading process so the loading area will
always be as close
to the employee's torso as possible.  Utilizing this type of device will
minimize the
amount of distance employees must reach when placing boxes on pallets and
will also
help reduce the amount of torso twisting.
(iii) Break down loads into smaller, lighter boxes.  Many companies have
reduced the
weight of their packaged products to no more than 40 pounds.
(iv) Provide a lift assist mechanism which will lift the box from the work
table and
load it onto the pallet.  There are several types of vacuum activated
mechanisms
which are also counterbalanced such that the effective weight which must
be lifted is
minimal with the tool providing all the lifting and lowering force
exertion.
Administrative controls should be implemented which reduce the duration,
frequency, and
severity of exposures to hazards that can not be materially reduced or
eliminated with
engineering controls.  These controls may include job rotation (taking
care to assure that the
employee is qualified for the rotated jobs and are "work hardened") and
ensuring adequate
crew sizes.
(i) Rotate all employees through all positions on this task (taking care
to assure that
the employee is qualified for the rotated jobs and are  work hardened).  A
rotation
scheme should be developed which allows employees to have periods of rest
for
affected muscles by rotating to jobs which utilize a different muscle
group.
(ii) Limit the amount of time employees must perform continuous lifting
tasks.
Employees are at considerably more risk of development of MSDs when they
perform
a lifting task for a full 8-hour shift even if standard rest and lunch
breaks are
provided.  The ideal would be to have no more than a one-hour lifting
session
separated by a non-lifting period of 1.2 times the lifting period or 72
minutes for a 60
minute lifting session.  More stressful, but still better than the
standard full work day
would be a session of not more than 2 hours with a non-lifting period of
0.3 times the
lifting period or 36 minutes for a 120 minute session
Work practice controls should be implemented which include proper work
techniques, new
employee conditioning, and monitoring and modifications as necessary to
minimize
ergonomic stressors.  Examples of work practice controls applicable to
this workplace may
include:
(i) Ensure adequate job training time to allow the employees to become
fully qualified
in their jobs.
(ii) Implement a work hardening program to ensure that all employees are
fully ready
to perform the task assigned to them.
(iii) Implement and monitor a knife sharpening program to ensure that all
employees
are aware of the importance of having adequately sharpened knives.
In addition to the above controls, work site analysis, education and
training are needed to
ensure that the controls that are implemented are meaningful and
effective.  These elements
are described in general below:
Worksite Analysis
Use worksite analysis to recognize and to identify existing ergonomic risk
factors so
that the appropriate controls may be implemented.  Worksite analysis may
also be
used to evaluate the effectiveness of controls after they have been
implemented.
Periodic surveys of the workplace shall be conducted at appropriate
intervals to
(a)  Stuffing/Hanging Hams: Evaluation of this task indicates that
evaluate work practices and engineering controls, including as jobs change
and/or new
workers assume these jobs.  Employee participation in the ergonomics
analysis should
be encouraged.  A consultant may be needed to perform a comprehensive
ergonomics
evaluation of your facility, if no one in the facility is qualified to
evaluate the
hazards.  When evaluating individual jobs, care should be taken to use the
appropriate
employees
forms for each job.  This may necessitate the development of standardized
forms and
performing this job were exposed to the ergonomic stressors of:
(1) Repetitive lifting of about 75 pounds of ham from a work table to a
rack.
A calculation of these lifting tasks, utilizing the Revised NIOSH Lifting
Equation, indicates that the Lifting Index (LI) for middle rack locations
is
about 2.5 times the Recommended Weight Limit (RWL) and can range up to
5.3 times the RWL for top rack locations, based on a 25 pound ham.   A LI
other evaluation tools to be used throughout the facility.
Training and Education
Training and education should be provided for exposed employees.  Methods
to
evaluate the effectiveness of the training should be developed.
Re-training should be
conducted annually and as operations change.  This re-training should be
performed
for all of your employees.  Training should address hazards associated
of 1 is equal to the RWL and loads at this weight or less are generally
with the job,
the risks of handling meat products, and the different methods and tools
available for
performing the jobs safely.  The training program for supervisors should
address the
need for them to insure that the incident is properly reported, the need
for them to
support restricted activity assignments of the employees and the various
jobs within
their departments that would qualify as restricted duty or that could be
considered safe for the majority of employees.  Most of the work population
modified to
meet a variety of restrictions.  Employees should also be aware of the
early
will be injured when the LI is 3 times the RWL or greater.  The risk of
injury
increases as the LI approaches 3.  Since all lifts performed exceed the LI
of 1
and at least 40of the lifts exceed an LI of 3, performance of this task
should
be considered hazardous.
(2) Repetitive torso flexion up to, or in excess of, 90 degrees to access
warning
signs of work related injuries and illnesses, as well as the appropriate
reporting and
post reporting procedures.
Medical Management
The medical management program is to be further developed and implemented
under
the guidance of an appropriately qualified occupational health
professional. (This may
and lift
be a licensed physician or registered professional nurse with specific
skills and
training in occupational health, ergonomics, and evaluation and treatment
of
musculoskeletal disorders.)  You will need to consult with the appropriate
State
licensing agency for information on professional scope-of-practice
criteria.  The
medical management system should be delivered consistently, effectively,
and in
accordance with acceptable standards of practice.  Your medical management
program
shall include, but is not limited to the following elements:
1.  All employees reporting injuries or illnesses will be asked whether
their medical
condition is caused or aggravated by work duties.  Where the employee
states that the
injury or illness is work related, and that case otherwise meets the
criteria forrecording, the case will be entered on the OSHA log pending
final determination of
cause.
2.  Educate all employees, supervisors and lead persons on the early signs
and
symptoms of MSDs.  All employees should receive annual refresher training
on these
issues.  Also stress the importance of early reporting of signs and
symptoms to the
safety coordinator.  A work hardening program should be implemented.  New
employees will be given an opportunity to condition their muscles and
tendon groups
prior to working at full capacity (minimum one week).  In addition, an MSD
examination will be performed on all production employees 1 month after
assignment
and at least every 2 years thereafter.  A symptoms survey should be
performed
annually.
3.  Establish a formal, documented tracking and surveillance program to
monitor
MSD trends in the plant and those employees who have contracted a MSD to
ensure
adherence to the above parameters.  This will also provide information
about the
effectiveness of other aspects of the employer's program in decreasing the
number
and severity of MSD cases.
4.  Employees shall not be discriminated against because they have
reasonable
requests to visit a medical facility or because they have a diagnosed MSD
and are
undergoing rehabilitation.  Additional supervisor training in
understanding MSDs may
be helpful.  All supervisors shall be discouraged from providing
disincentives for
reporting symptoms related to MSDs.  In addition, supervisors may need
additional
information and training related to the importance of adhering to
restrictions that have
been placed on an employee.
5.  Establish a process to ensure that restricted duty jobs are adequately
analyzed to
determine what conditions may be met upon assignment to those jobs.
Employees
with restrictions must be properly matched to only those jobs which can
accommodate
the requirements of their restrictions.
6.  Establish a process to evaluate the medical management program
periodically to
determine effectiveness of program elements and revise as needed.
Preventive Measures
1.  Provide employees with access to and early assessment of complaints by
a health
care professional, allowing for prompt and appropriate evaluation and
treatment.
Employees should receive timely and appropriate physician referrals when
needed.
2.  Allow affected muscle/tendon groups to heal after an MSD is diagnosed
with
appropriate restrictions, job placement, and/or time off.  The health care
professional
shall determine the exact number of days off of work.  These decisions
will be subject
to each worker's individual response.  The health care professional must
be involvedin assuring that employees are returning to appropriate jobs or
reassigned to another
job.
3.  Establish a process to ensure that appropriate health care providers
with training in
early recognition, evaluation, treatment, rehabilitation, and prevention
of MSDs are
used to develop and implement conservative treatment measures upon
detection of
symptoms related to MSDs.  Establish a process that ensures accuracy,
completeness,
and consistency of the information documented by health care providers in
individual
health records.
Treatment of MSD Cases
1.  Appropriate evaluation, treatment, referral, and follow-up of
employees with
complaints consistent with MSDs will be based on specific, concise
protocols
triggered by the medical history and physical assessment.
2.  Establish a process to ensure appropriate assignment of restricted or
accommodated work that does not further exacerbate the employee's
condition.
Ensure a process is in place to provide occupational health professionals
with training
commensurate with task of conducting job analyses and in determining
appropriate job
placement.
3.  After an MSD surgery, allowing time off work for the healing of
muscle/tendon/nerve groups is essential.  The exact number of days off
work is
subject to individual variation and up to the discretion of the treating
health care
professional (or physician).
4.  Establish a process to evaluate a worker upon return to work after
time away from
surgery or rehabilitation to assess work capabilities and ensure
appropriate job
placement.
Multi-step abatement shall be as follows:
STEP 1
Implementation of an ergonomics program for worksite analysis, medical
management, and
training and education, as detailed above.
STEP 2
Submit to the Area Director a written, detailed plan of abatement
outlining a schedule for the
implementation of the engineering, administrative, and work practice
controls.
All proposed
control measures shall be approved for each particular use by a person
trained in the
evaluation of workplace conditions which case MSDs.  Sixty (60) day
progress reports are
required during the abatement period.
STEP 3
Implementation of engineering, administrative, and work practice controls.
Abatement Note:  Abatement certification and documentation are required
for this item (see
enclosed "Sample Abatement Certification Letter").tion
20 to 30 pound hams from transportation tubs.
(3)  Repetitive reaching out and away from the torso to access and lift 20
to 30
pound hams from transportation tubs.
(4)  Repetitive and forceful finger exertions to lift 20 to 30 pound hams
out of
tubs using a meat hook.
(5) Repetitive contact trauma to the sides of the fingers to lift 20 to 30
pound
hams out of tubs using a meat hook.
(b)  Hanging Bacon/Brine Injector:  Evaluation of this task indicates that
employees
performing this job were exposed to the ergonomic stressors of:
(1)  Repetitive torso flexion up to, or in excess of, 90 degrees to access
and
lift 8 to 12 pound bacon slabs from transportation boxes and/or tubs.
(2) Repetitive elevated reaches, up to or in excess of shoulder height, to
lift
8
to 12 pound bacon slabs to feed conveyors for brine injectors and hanging
racks.
(3) Repetitive and forceful finger exertions to lift 8 to 12 pound bacon
slabs
out of boxes or tubs using a meat hook.  (4) Repetitive contact trauma to
the sides of the fingers to lift 8 to 12 pound
bacon slabs out of boxes or tubs using a meat hook.
(c)  Boning Line: Evaluation of this task indicates that employees
performing this job
were exposed to the ergonomic stressors of:
(1)  Repetitive forceful shoulder exertions to pull 20 to 30 pound hams
over a
stop bar at the beginning of the boning line.
(2) Repetitive and forceful finger exertions to pull 20 to 30 pound hams
over a
stop bar at the beginning of the boning line using a meat hook.
(3) Repetitive contact trauma to the sides of the fingers to pull 20 to 30
pound
hams over a stop bar at the beginning of the boning line using a meat hook.
(d)  Boxing/Packaging: Evaluation of this task indicates that employees
performing
this job were exposed to the ergonomic stressors of:
(1) Repetitive lifting of boxes weighing up to 50 pounds from a packing
table,
scale, or conveyor to a pallet placed on the floor.  A calculation of these
lifting tasks, utilizing the Revised NIOSH Lifting Equation, indicates
that the
Lifting Index (LI) for the first tier of boxes placed on a pallet is about
4 times
the Recommended Weight Limit (RWL) based on a 50 pound box.
(2) Repetitive torso flexion, up to 90 degrees, to place 10 to 50 pound
boxes
on pallets.
(3) Repetitive reaching out and away from the torso, up to or in excess of
16
inches to place 10 to 50 pound boxes on pallets.
(4) Repetitive twisting of the torso up to 30 degrees to place 10 to 50
pound
boxes on pallets.
(5) Additionally, employees performed repetitive forceful hand and wrist
exertion when filling, sealing and labeling boxes.
Among other methods, some feasible and acceptable abatement methods to
correct these
hazards include the implementation of the following controls:
Engineering controls designed by a qualified ergonomist should be
implemented where
applicable.  These may include, but are not limited to, work station
design, tool and handle
redesign, and the change of work processes.  The goal of these controls
should be to make
the job fit the person (to materially reduce or eliminate hazards), not
vice versa.  Examples
of engineering controls applicable to this workplace include:
Engineering Controls for Ham Stuffer/Hanger(i)  Provide a Lifter/Tilter
which
will lift and tilt the supply tub such that hams will
tumble to the employee.   Such a device is available from commercial
vendors and
will lift the tub while tipping it toward the worker.  This motion raises
the elevation
of materials within the tub and allows the materials to slide or tumble
down toward
the employee eliminating, or greatly reducing, the need to bend forward at
the waist
or to reach.  Utilization of such a device will allow employees to maintain
ergonomically neutral postures during the entire work shift.
Additionally, since the
hams will be elevated and moved closer to the employee, the need for
forceful
exertions with the hook should be greatly reduced.  Some lifts and
transfers of hams
with this type of workstation may not require the use of hooks at all.
(ii)  Provide a mechanical lifting device to move hams from the work table
to the
racks.  This type of device could be in the form of a pivot mounted strong
arm or
could be supported overhead by  I beams.  After hams have been placed on
the
bar,
the bar could then be attached to the lifting device which would use a
mechanical lift
to raise the bar and hams into position.  Employees would simply position
the load
onto the rack with all lifting and lowering being performed by the
mechanical device.
(iii) Discontinue use of the top and bottom levels of the loading racks.
These
positions require extended reaches over head and torso flexions which
greatly increase
the hazard of the task.  The middle three levels of the rack can be used
with the torso
in a much more neutral posture which greatly reduces the risk of injury
when loading
the racks.
(iv) Develop a new work station which incorporates a scissors lift to
raise and lower
the rack so employees can load all five levels while maintaining their
bodies in an
ergonomically neutral posture.  The overall station would need to be
elevated
or the
scissors lift would need to be placed in a cutout in the floor so when the
lift was fully
lowered, the top level of the rack is at about waist height.  Then as the
rack is filled,
it could be elevated so the lower levels of the rack could be loaded
without the use of
torso flexions.
(v) Develop a new rack which has support arms protruding out from the
rack, such
that hams could be placed onto the rack one at a time.   With this type of
rack, each
ham would be lifted individually which would limit the amount of weight
each
employee lifts to about 20 to 30 pounds.
(vi) Provide a stirrup design of hook as an alternative for employees who
may be
experiencing contact trauma to the insides of their fingers from the T
handle design.
This type of hook has a bar which runs across the palm of the handle and
is attached

Issued

Dec 7, 1999

Abate by

Jun 20, 2000

Penalty

Initial $1,063 · Current $1,063

Issued

Dec 7, 1999

Abate by

Jun 20, 2000

Issued

Dec 7, 1999

Abate by

Mar 10, 2000

Issued

Dec 7, 1999

Abate by

Jun 20, 2000

Penalty

Initial $850 · Current $850

Issued

Dec 7, 1999

Abate by

Jun 20, 2000

Issued

Dec 7, 1999

Abate by

Dec 27, 1999

Penalty

Initial $638 · Current $638

Issued

Dec 7, 1999

Abate by

Dec 20, 1999

Issued

Dec 7, 1999

Abate by

Dec 27, 1999

Issued

Dec 7, 1999

Abate by

Dec 27, 1999

Issued

Dec 7, 1999

Abate by

Dec 27, 1999

Penalty

Initial $638 · Current $638

Issued

Dec 7, 1999

Abate by

Dec 27, 1999

Issued

Dec 7, 1999

Abate by

Jan 10, 2000

Issued

Dec 7, 1999

Abate by

Jan 10, 2000

Hazardous substances 8111

Issued

Dec 7, 1999

Abate by

Dec 10, 1999