OSHA Inspection: EXCEL CORPORATION

Issued

Dec 14, 1998

Abate by

Dec 14, 1999

Penalty

Initial $5,000 · Current $5,000

General-duty citation text

station which is to be used by an employee for more than a few hours
should be designed
to minimize stressful postures.
(ix) Modify the feed mechanism for the Cryovac machines such that product
is brought
all the way to the employee.  The conveyor belt should be extended or the
incline on the
rollers should be increased such that product will come all the way to the
Cryovac plates
Section 5(a)(1) of the Occupational Safety and Health Act of 1970: The
without the employee grabbing and lifting the product.  Using an extension
of the
conveyor would allow the transport of materials to be accomplished
mechanically.  The
employee would only be required to perform an arrangement function by
guiding the bagsonto the plates rather that lifting and dropping them onto
the plates.
Engineering Controls for Chuck Boner
(i) Lower the upper bone conveyor such that it can be accessed without
extended reaches.
employer did not furnish
employment and a place of employment which were free from recognized
hazards that were
causing or were 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
observed hazards
ii) Analyze the need to throw product and materially reduce or eliminate
the repetitive and
forceful nature of throwing.
(ii) Reduce the depth of the cutting block surface.  Employees using the
cutting block
should be able to perform the task without awkward postures.
Administrative controls should be implemented which reduce the duration,
frequency, and
severity of exposures to hazards that can not be materially reduced or
are summarized below:
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.
Keep evaluating your personal protective equipment (PPE) needs.  Ensure
that all P.E. is
maintained in good working condition.  State of the art changes in glove
types may necessitate
(a) Clod Puller: Employees performing the job of Clod Puller performed
additional replacement as better one become available.
repetitive and/or
prolonged elevation of the hand and arm, as well as the repetitive and/or
prolonged use
of forceful finger, arm, and shoulder exertions.  These hazards occurred
when employees
reached above shoulder height to perform cutting tasks, at the same time
they pulled the
meat downward using a meat hook held in the non-cutting hand.
Administrative Controls for Bagger/Stuffer
(I) Employees on the Cryovac lines should be rotated between stations
which pack heavy
and light product.
Administrative Controls for Chuck Boner
(I) Staffing at this position should remain at least the levels observed
during the
inspection.  This level seemed to provide most employees with time to
adequately sharpen
(b) Skirt Puller: Employees performing the job of Skirt Puller were
tools and perform tasks in an appropriate manner.  If production speeds
increase, staffing
should be adjusted appropriately.
(ii) Develop a work rotation where employees repeatedly move to different
locations along
the boning line.  Employees at the first position on the line may have
fewer breaks in
their work process since there is always fresh product to be worked on as
soon as they
exposed
are finished with their current task.  Employees at the end of the line
often have short
periods where they have no product, and thus rest breaks, due to the
efforts of employees
farther up the line.
Work practice controls are 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
fullyqualified in their jobs.
(ii) Fully implement your  Ramp In program or some other effective work
hardening
program to ensure that all employees are fully ready to perform the tasks
assigned to
them.
(iii) Monitor the knife sharpening program to ensure that all employees
are
aware of the
importance of having adequately sharpened knives.
Work Practice Controls for Clod Puller
(I) Use a two person system where one employee pulls the meat down and the
other
employee performs the cuts. These employees could rotate between the two
positions.
(ii) Leave the clod hanging onto the leg after it has been nearly removed.
It then can be
removed at another station with only a few knife strokes and dropped onto
a take-away
conveyor.  This will eliminate the need to support the weight of the clod
after it has been
removed from the bone and to provide force to throw it onto the conveyor.
Work Practice Controls for Chuck Boner
(I) Instruct employees to place the removed bone back on the main conveyor
and have
another employee remove it at the end of the conveyor at an ergonomically
designed
station.  This type of technique appears to be used in other areas of the
plant such as in
tender pulling where no elevated conveyor exists.  At this station the
large piece to be
trimmed is removed from the table, the tender is removed and both the
tender and the
remaining  large section are placed back on the table for processing
further down the line.
(ii) Instruct employees to lift the bone to the upper conveyor using the
cutting hand
instead of throwing the bone to the conveyor using the hook (non-cutting)
hand.  In most
instances viewed on the video documentation, using the knife hand
required  less flexion
of the shoulder and the lift was performed more smoothly and with less
force than when
the lift was performed with the hook hand.
(iii) Instruct employees to limit their forward reaches by using long
handled hooks to pull
meat from the conveyor.
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 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 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 forms for each job.  This may necessitate
assistance from
corporate safety and health professionals in using existing standardized
forms and other
evaluation tools throughout the facility.
Training and Education should be provided for exposed employees.  Methods
to evaluate the
effectiveness of the training should be performed.  Re-training should be
conducted annually and
as operations change.  This re-training should be performed for all of
your employees and not
just for the managers, ergonomics monitors, and medical professionals.
Training should address
hazards associated 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 support restricted activity assignments of
the employees and the
various jobs within their department that would qualify as restricted duty
or that could be
modified to meet a variety of restrictions.  Employees should also be
aware
of the early warning
signs of work related injuries and illneses, 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 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:
All employees visiting the plant medical facility to report injuries or
illnesses
will be
asked whether their medical condition is caused or aggravated by work.
Where the
employee states that the injury or illness is work related, and that case
otherwise meets
the criteria for recording, the case will be entered on the OSHA log
pending final
determination of cause.
Continue educating all employees, supervisors, and foremen on the early
signs and
symptoms of MSDs.  All employees should receive annual refresher training
on these
issues.  Also continue to stress the importance of early reporting of
signs and symptoms
to the medical department.   A work hardening program will 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.
Establish a formal, documented tracking and surveillance program to
monitor MSD trendsin 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 employers program in decreasing the number and severity of
MSD cases.
Employees shall not be discriminated against because they have made
to repetitive
reasonable requests
to visit the medical facilities 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
reaching to elevated and extended locations, often while performing
placed on an
employee.
forceful pulling
motions or supporting materials in the hands.  These hazards occur while
repeatedly
reaching up and away from the body to trim material from the inside of the
carcass and
to support this material while transporting it from the carcass to the
take away conveyor.
(c) Bagger - Stuffer: Employees performing the Bagging - Stuffing jobs
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.
Establish a process to evaluate the medical management program
periodically to determine
were exposed to
effectiveness of program elements and revise as needed.
Preventive Measures
Provide employees with access to and early assessment of complaints by an
on-site health
care professional, allowing for prompt and appropriate evaluation and
treatment.
Employees should receive timely and appropriate physician referrals when
needed.
Allow affected muscle/tendon groups to heal after a MSD is diagnosed with
appropriate
repetitive and/or prolonged periods of reaching to elevated and extended
locations, often
while supporting loads in the hands.  These hazards occurred while
repeatedly accessing
bags for meat packing, arranging and aligning meat on conveyors, placing
paper over
meat with exposed bone prior to bagging, accessing meat to be stacked on
fixtures,
placing bags over the snouts at the end of rams and fixtures prior to
restrictions, job placement, and/or time off. The health care professional
who is
responsible for the medical management program, in collaboration with the
treating health
care professional(s), shall determine the exact number of days off of
work.  These
decisions will be subject to each workers individual response.  The
on-site health care
professional must be involved in assuring that employees are returning to
bagging, and to
appropriate jobs
or reassigned to another job.
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 process that ensures accuracy, completeness,
and consistency
access bagged meat to be placed on the Cryovac.  Additionally, employees
of the information documented by health care providers in individual
health records.
performed
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 employees condition. Ensure a process
is in place to
provide occupational health staff with training commensurate with task of
conducting job
analyses and in determining appropriate job placement.
3. After a 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 process to evaluate a worker upon return to work after time
away for surgery
or rehabilitation to assess work capabilities and ensure appropriate job
placement.
MULTI-STEP ABATEMENT SHALL BE AS FOLLOWS:
Step 1Implementation of an ergonomics program for worksite analysis,
medical
management, and training and education, as detailed in items 1-3 above.
ABATEMENT DATE3/16/99
Step 2Submit 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 CAUSE MSD'S.  SIXTY (60) DAY
PROGRESS REPORTS ARE REQUIRED DURING THE ABATEMENT
PERIOD.
ABATEMENT DATE3/16/99
Step 3Implementation of engineering, administrative, and work practice
controls.
ABATEMENT DATE12/14/99
ELEMENTS FOR 5(a)(1) JUSTIFICATION:
The 5(a)(1) elements are found on Page III-8 of the F.I.R.M.
1.  The employer failed to keep the workplace free of a hazard to which
employees of
that employer were exposed:
The employees in this facility were exposed to ergonomics risk factors
(including but not
limited to repetitive motions, high force, compressive force, and awkward
posture) resulting
in the subsequent development of upper extremity, cumulative trauma
disorders.
The
employees use a wide variety of meat cutting/handling tools (Knives,
hooks, and bagging
machines).  The employer has been experiencing steadily increasing
incidence rates for
cumulative trauma disorders (CTDs) since 1995 (1995 CTD rate was 22.9 and
the 1998
CTD rate was 32.1 as of June 1, 1998).  Upon initial calculation, it
appeared that the
employers severity rates for CTDs were decreasing.  After performing a
review of the
recordkeeping a 1904.2 violation has been recommended for discrepancies in
their OSHA
200 recordkeeping program.  This reduces the confidence in the employers
records.
Observed deficiencies included failure to record instances of CTDs as well
as failure to
record large numbers of restricted days.  Both of these have a direct
correlation to the
severity calculations.  It is a very likely that the employers severities
are not decreasing.
Six jobs in the Fabrication Department were analyzed for ergonomics risk
factors.
Some of
these jobs are listed in the attached recommended violation.  Since
January 1, 1997 the
employer has reported 22 CTD surgeries in 19 months.  A private
Occupational health
physician was hired to perform review of the employers medical records.
He has identified
areas where cases may have been worsened or exacerbated by the ergonomic
stressors present
in this workplace.
The following chart summarizes the employers rate experience.
1995199619971998Plant LWDII19.821.123.932.7CTD IR22.926.829.032.1CTD
LWDI8.18.310.915.2CTD Severity
LWD42.34.23.80CTD Severity
RWD360.8430.2506.8191.4
It is likely that this data is not correct as there were observed
violations of recordkeeping
practice at this facility.
2.  The hazard was recognized:
The employer is clearly aware of the ergonomics stressors in their
facility.
Gene Guerrero is
the employers ergonomics program coordinator.  He transferred from another
Excel plant in
December of 1997.   Excel Corporation was previously cited in their Friona
and Plainview
Texas plants for 5(a)(1) violations for ergonomics.  They have direct
knowledge of the
hazards based on these citations and the accompanying corporate settlement
agreements for
these citations.  See attachments J and K.
The employers ergonomics coordinator performs evaluations of their injury
and illness
records in an effort to identify their high risk jobs.  They identified
some of the same jobs
that our rates identified.  The employers ergonomics program has been
included in this
package and it clearly addresses how to identify, track, and manage
ergonomics cases.  See
attachment D.
Even though the employer has not had a private program evaluation
performed, they have a
contract with Clayton Environmental Services (formerly ErgoTech) to
perform annual
training for their managers and medical staff related to the
identification and control of
ergonomic conditions and cases.
3.  The hazard was causing or was likely to cause death or serious
physical harm:
The employees at Excel Corporation have daily, continuous exposure to
ergonomic stressors
which are leading to subjective symptoms and clinical manifestations of
CTDs.  In the past
22 months there have been at least 22 CTD surgeries.   For the six jobs
being analyzed, 54
of the employees who have reported CTDs since 1996 were observed to have
objective
physical findings at the time of their first report.  This information can
be found in
Attachment C of the Support Documentation.
4.  There was a feasible and useful method to correct the hazard:
The employer has made some adjustments and changes based on the function
of the
corporate ergonomics program.  Attachment G in the documentation lists
some of these
changes.  A large number of these changes are not really related to
ergonomic controls, but
are more general safety and housekeeping controls.  These are recognized
as being helpful
for employee working conditions but have little to do with the control of
repetitive forceful finger exertions, often with the wrist in a non
ergonomic
stressors.  A large engineering project is currently underway in the
employers bagging
department.  The employer has indicated  that the primary reason for this
change is in order
to cut 22 positions and increase production efficiency.
The employer has been cited before for ergonomics.  In 1995 the company
plants in
Plainview, and Friona, Texas received 5(a)(1) citations for ergonomics.
The employer settled
neutral work posture.
with OSHA for abatement in each of those cases.  The employer should have
been
implementing these controls in the Fort Morgan plant.  Even though the
settlement
These hazards occur while lifting and placing bags onto sealing plates of
the Cryovac
machine and when using long handled hooks to pull meat into position.
(d) Chuck Boner: Employees performing the job of Chuck Boner performed
repetitive,extended reaches and/or throwing of product into an elevated
conveyor.
Among other methods, some feasible and acceptable abatement methods to
correct these hazards
agreement
was not applicable to the Fort Morgan plant, several of the ergonomic
issues are substantiallysimilar if not the same and could be controlled.
See Attachment J of supporting
documentation.
Dave Schmidt OSHAs Office of Statistics provided information relative to
the downward
trends of CTD incidence rates in this industry.  In 1991 the average CTD
incidence rate for
include the implementation of the following controls:
SIC Code 2011 (red meat packing) was 14.9.  The most recent statistics are
available for
1996 and indicate an average CTD incidence rate of 9.2.  Clearly this is
evidence of the
increasing numbers of improvements being made by the employer to abate
these hazards.
(See Attachment I).achment
Engineering controls designed by a qualified ergonomist should be
implemented where applicable.
These may include, but are not limited to work station redesign, 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 elimnate hazards), not vice versa.
Examples of engineering
controls applicable to this workplace include:
Engineering Controls for Clod Puller
(i) Ramp the chain so employees can perform the beginning cuts without
elevating their
shoulders.  As the vertical location of the cuts moves down the leg, the
chain could rampup to maintain the work area at heights that do not
elevate employees risk for the
development of musculoskeletal disorders.
(ii) A movable floor similar to the one used at many of the gut tables may
be provided
to allow employees to maintain one standing position as the chain is
ramped.  To make
this control fully effective, an mechanism is needed to pull the clod down
in a way that
materially reduces or eliminates extended reaches.
(ii) Provide work station heights that allow cuts to be made without
awkward postures,
such as repetitive, extended reaches.
(iii) Design a meat hook that allows the employee to stay in a safe
orientation with the
cutting location on the clod.
(iv) Move the take-away conveyor closer to the employees such that the
clod will fall
directly onto the conveyor rather than requiring the employee to let it
drop from the bone,
hold it with the hook, and then toss it onto the conveyor.  Figure #5
shows an example
of round dropping where the round is dropped directly onto the conveyor
after it is
removed.  This station should also be further analyzed to design solutions
to materially
reduce or eliminate extended reaching.
(v) Use an automated system, similar to that used to remove the feather
bone, for removal
of the clod.  A chain attached to the meat could provide the downward
force which would
allow the employee to perform only the necessary cutting actions for
removal of the meat.
Engineering Controls for Skirt Puller
(i) Elevate the current platform to reduce extended reaches while making
cuts.
(ii) Extend and widen the current platform such that employees do not need
to hang off
the end to perform cuts.  This will allow employees to move close enough
to the carcass
so they can perform the needed cuts without the need for extended reaches
of the arm.
(iii) Provide a conveyor under the carcass so the skirt can be dropped
instead of lifted and
carried to the conveyor.
Engineering Controls for Bagger/Stuffer
(i) Reposition bag stands so they are in improved orientation to the
employee and the
product being bagged.  Many of the bag stands were elevated much higher
than was
needed and were placed much further away from the employee than was
necessary.   In
Figure #13 the employee can access the bags while keeping the hands below
shoulder
height while keeping the elbows in fairly close to the torso.
(ii) Reposition packing fixtures and conveyors so they present meat to the
baggingemployees at positions where healthy work  postures can be
maintained.  In Figure #14
the packing fixture is elevated to the point where the bag can be placed
over the fixture
and the meat pushed into it while the employee works with minimal elbow
abduction and
limits the amount of forward torso flexion.
(iii) Provide appropriate height adjustable stands for all employees that
are working on
the bagging lines.  Stands should be adjustable such that all employees
can perform their
tasks while limiting forward reaches.
(iv) Consider the employees relationship to the entire work station when
placing work
materials.  Many of the work stands observed were too low to provide safe
access to bags,
but were in proper alignment for access to the meat.  Others were in
better alignment for
the bags, but required the employee to bend forward and reach to place the
bag over the
inserting snout or to reach to access meat which was to be packed.  All
aspects of the task
must be considered in their entirety when developing an ergonomic control
strategy.
Employee input, with respect to these controls is needed to assure that
hazards have been
abated.
(v) Provide diverters on conveyor lines to push materials over to
employees so they do
not need to use extended reaches.  Diverters can essentially reduce the
width of wide
conveyors such that extended reaches are not necessary.
(vi) Use a narrower conveyor whenever possible.  Much of the reaching and
hazardous
lifting is needed so employees can reposition and move meat items on
conveyors.
These
conveyors are much wider than necessary.  The conveyor at right in Figure
#15 is
significantly narrower than the one on the left but still has plenty of
room for any product
that is produced by the fab unit.  Use of a narrower conveyor as shown in
this picture will
allow a  reduction in the distances that employees must reach and in many
cases could
be the difference between extending or not extending an employees arms.
(vii) Some long hooks should be designed with a T-handle or L-handle.  The
use of these
types of hooks would allow employees to maintain a neutral wrist posture
when exerting
force.
(viii) When temporary work stations are created they should be given the
same care and
consideration as is given to permanent work stations.  Temporary work
stations may
become permanent, but never receive additional consideration for their
hazards.  Any

Issued

Dec 14, 1998

Abate by

Jan 16, 1999

Penalty

Initial $7,000 · Current $7,000

Hazardous substances 0170

Issued

Dec 14, 1998

Abate by

Jan 6, 1999

Penalty

Initial $7,000 · Current $7,000

Hazardous substances 0170

Issued

Dec 14, 1998

Abate by

Dec 27, 1998

Penalty

Initial $7,000 · Current $7,000

Hazardous substances 0170

Issued

Dec 14, 1998

Abate by

Jan 6, 1999

Penalty

Initial $7,000 · Current $7,000

Hazardous substances 0170

Issued

Dec 14, 1998

Abate by

Dec 27, 1998

Penalty

Initial $2,000 · Current $2,000

Hazardous substances 2260

Issued

Dec 14, 1998

Abate by

Dec 27, 1998

Hazardous substances 2260

Issued

Dec 14, 1998

Abate by

Dec 17, 1998

Issued

Dec 14, 1998

Abate by

Jan 16, 1999