OSHA Inspection: ALLIANT FOODSERVICE

Issued

Jun 13, 2000

Abate by

Mar 13, 2001

Penalty

Initial $4,500 · Current $4,500

General-duty citation text

b.  Freezer Area Selectors:
i)  Redesign the warehouse storage rack system and the pallet jack so that
heavy
objects are located at an optimum lifting height which minimizes torso
flexion and
overhead reaches.  Optimal height is between chest and thigh level.
Recommendations to achieve these optimal heights include:  1) Utilizing
additional pallets as spaces to elevate the load;  2) Utilize palletizers
in the bins
Section 5(a)(1) of the Occupational Safety and Health Act of 1970:  The
of the racking system as well as on pallet jacks;  3) Utilize elevated
carts pulled
by tugs instead of pallet jacks;  4) Provide additional horizontal rack
cross
members to raise the bottom pallets off of the ground
ii)  Develop a ranking system to identify storage areas which require
hazardous
lifting tasks.  The ranking system should identify heavy and bulky objects
stored
at low locations as the most hazardous and light compact objects as least
employer did not
hazardous.  The storage locations of the most hazardous lifting tasks
should
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 the following hazardous ergonomic conditions:
a. Dry/Refrigerated Area Selectors (19 Employees):   Evaluation of this
task indicates
that employees are exposed to the ergonomic stressors of repetitive
be
clearly identified to stocking and picking employees.  An operation
procedure
should be developed to provide reorientation of those items identified as
creating
the most hazardous lifting tasks.  These locations should have the pallet
turned
and/or elevated as needed to maintain optimum lifting postures.
iii) Modify the bins at the end of the aisles so items can be accessed
lifting of packaged
from the
front and the side.  Move the stabilizing cross member so employees can
enter
the bin from the side as well as the front.  This modification will enable
employees to obtain heavy items from two sides and allow the load to be
lifted
and maintained close to the body.  Employees should have access to all
sides of
the pallet eliminating excessive reaches to pull and/or lift objects
toward the
goods weighing up to or in excess of 60 pounds.  Employees must repeatedly
body.
iv)  Install a track system which will allow the entire pallet of product
to
reach
forward, bend at the waist, and twist the torso to obtain the product from
palletized
supply located under over head racking.  Racking design requires lifts to
be performed
with the torso bent and the load held out and away from the body.  A
calculation of these
lifting tasks utilizing the NIOSH Lifting Guide Allowable Limits (1991)
be
pulled out of the bin.  This modification will permit the pallet to be
accessed
from all sides and allow the load to be lifted and maintained close to the
body,
eliminating the need for extended reaches and torso flexion.  The addition
of a
turntable will permit the rotation of the pallet 180 degrees, allowing
placement
indicates that the
back into the bin with the items previously in the back now easily
accessible from
the front.
v)  Install a platform having casters or wheels that palletized product
can be
placed onto.  This modification will permit the pallet to be pulled out
from the
bin providing access from all sides,  allowing the load to be lifted and
maintained
close to the body, and eliminating the need for extended reaches and torso
NIOSH Recommended Weight Limit for this task is consistently exceeded.
flexion.  THE wheels will permit the rotation of the pallet 180 degrees,
allowing
it to be placed back into the bin with the items previously in the back
now
These
easily
accessible from the front.
vi)  Provide a long handled tool to pull product closer to the front edge
of the
rack opening before it is lifted.
vii)  Educate the employees on the basics of body biomechanics and the
importance of maintaining the body in an ergonomically neutral position.
Torso
flexion should be limited to no more than 6 to 10 degrees from vertical.
Maximum reach distances of 16 to 18 inches forward are recommended and the
arms should be maintained in front of the body at all times minimizing
reaches
out to the sides.  The hands should not be elevated above shoulder height
and the
load should be maintained at waist level.  Employees should be trained on
the
hazards of repetitive torso flexion and reaches and made aware that the
weight
and positioning of an item is important to their safety.  The load should
be
maintained close to the body and the feet rotated, turning the entire
body,eliminating
twisting of the torso.  Employees should not lift multiple items raising
the weight of the  load to unacceptable levels, or reach to distant
locations to
access product and/or reach with a load in the hands to place product on a
pallet.
III.  MEDICAL MANAGEMENT which includes accurate record keeping of
ergonomic illness
cases.  The program shall address early recognition, evaluation and
referral of musculoskeletal
disorders (MSD) cases, and should include conservative treatment and
conservative return to
work, including work hardening prior to return to full duty.  The medical
management program
is to be established under the supervision of a physician or occupational
health nurse (OHN) with
training in the prevention and treatment of MSDs.  Systematic work site
review by the medical
practitioners shall also be included in the program.  Discrimination
against employees for
reporting or incurring a MSD shall be prohibited.  The program shall
include, but is not limited
to, the following elements in order to prevent and/or limit t he severity
and
exacerbation of
MSDS:
a)  Qualified health care providers shall be trained in the early
recognition, evaluation,
treatment, rehabilitation, and prevention of Musculoskeletal Disorders
(MSDSs), OSHA
record keeping requirements, and physical assessment of employees.
b)Health care providers shall perform a periodic workplace walk through
which ill
allow the identification of potential light duty jobs, and the direct
observation of
individual work practices in order to remain knowledgeable about operations
described by employees.  These walk through's shall be documented and
conducted when new jobs are established and/or as existing jobs change.
Appropriate assignments to light duty jobs will be made and tracking of
employees shall be performed to assure that an employee's medical
condition is
not aggravated or exacerbated.
c)  A written job analysis describing the ergonomic hazards found on each
job shall be
developed and made available to the health care providers.  The health
department shall
provide input to the development of the job analysis.   Periodic review
and revision of
the ergonomic job analysis shall be conducted for all existing jobs, for
all new jobs and
whenever existing jobs are modified.
d)  Surveillance shall be performed in order to identify jobs needing
intervention to
eliminate ergonomic hazards.  Surveillance shall be both passive, either
by reviewing
data such as illness records, and/or active, through administration of an
employee
symptom survey.  HEAlth care providers will provide input in this
surveillance to
identify high risk departments, production lines, and/or jobs.
e)  An evaluation shall be done to identify individuals with any sign or
symptoms of
MSDs allowing early treatment to limit the conditions' severity.  The
health care
provider should perform an MSD evaluation of employees assigned to jobs
with
known
ergonomic hazards or area found to have MSD problems by surveillance.  The
MSD
evaluation shall include inspection, palpation, range of motion (active,
passive, andresisted), and other pertinent maneuvers of the upper
extremities and back.  Such
evaluations shall be documented.
f)  Evaluations and treatment of employees with complaints consistent with
MSDs shall
be based on protocols shall be documented in writing, reviewed and updated
by a
knowledgeable party, usually a physician, on an annual basis.
Conservative medical
treatment shall be followed for initial symptoms and signs in order to
prevent increased
morbidity of cases.
If initial treatment of the MSD has not resulted in prompt improvement or
resolution of
the signs of symptoms, the employee shall be taken off the job causing the
problem, or
place on restrictions by the health care provider.  The restricted
employee
will be place
on appropriate jobs, consistent with their capability, which do not pose
parallel stressors,
by health care providers familiar with the job requirements.  Symptomatic
employees
shall be followed up to determine the effectiveness of the prescribed
treatment.
Employees with severe symptoms, positive physical findings, disorders, or
signs resistant
to treatment shall be immediately referred to physician for further
evaluation.  In no
event shall employees with signs of symptoms undergo conservative
treatment for longer
than two weeks without first being referred to a physician for evaluation.
Conservative therapy and time away from the job causing the problem
deserves and
adequate trial before surgical intervention is contemplated.
Recommendations for surgery
should be referred for a second opinion to a physician other than a
surgeon.  Appropriate
amount of time off work after surgery shall be assured.  A physical
evaluation of the
worker after time away from work, to assess work capabilities should be
performed to
ensure appropriate job replacement upon return to work.
If the employee is being medically followed for MSDs, the medical
department shall
review the ergonomic analysis of the job causing the problems.  If a job
has no
ergonomic analysis available, the job will be analyzed for ergonomic
stressors.
g)  The health care provider shall be responsible for entering the
appropriate information
onto the OSHA forms and should be adequately trained on OSHA's record
keeping
requirements.  Health care providers shall ensure the appropriate
documentation of
medical treatment (including self-administered treatment) and the
retention of such
documents.
h)  Evaluation of the medical management program should be performed on
aperiodic
basis to assure effectiveness of all of the elements.  A formal documented
tracking and
surveillance program to monitor musculoskeletal disorder trends in the
plant and to
follow those employees being treated for MSDs shall be instituted.
IV.  TRAINING AND EDUCATION for employees.  Training should address the
hazards
associated with the job, the risk factors which cause musculoskeletal
disorders (MSDs), and how
ergonomic stressors are causing or are likely to cause cumulative trauma
to prevent the occurrence of MSDs including the use of engineering and
administrative controls
and their maintenance.  retraining should be performed at least annually
and/or as operationschange.  Supervisors who have the day to day
responsibility for monitoring and enforcing the
companies ergonomics program should receive additional training sufficient
to assure
competency in the oversight of the program and control measures within
their areas of
responsibility.  Methods to evaluate the effectiveness of the training
disorders to the
shall be developed and
implemented.
back, shoulder, lower extremities, and/or upper extremities as evidenced
by a review of
the company's injury and illness records from 1997 to the time of
inspection, which
document that a significant number of musculoskeletal disorders have been
caused by
exposure to these stressors.
b.  Freezer Area Selectors (3 Employees):   Evaluation of this task
ABATEMENT OF THE CITATION SHALL BE ACCOMPLISHED IN
ACCORDANCE WITH THE FOLLOWING SCHEDULE:
STEP I:SUBMIT TO THE AREA DIRECTOR IN WRITING A DETAILED
PLAN, INCLUDING A TIME TABLE, ON HOW ABATEMENT
METHODS I, II, AND IV OUTLINED ABOVE WILL BE INIIATED
AND/OR EVALUATED.
DATE DUE:08/21/00
STEP II:SUBMIT TO THE AREA DIRECTOR A WRITTEN, DETAILED PLAN
OF ABATEMENT OUTLINING A SCHEDULE FOR THE
indicates that
IMPLEMENTATION OF ENGINEERING AND/OR
ADMINISTRATIVE MEASURES TO REDUCE ERGONOMIC RISK
FACTORS OF STRESSORS THAT HAD CAUSED OR WERE LIKELY
TO CAUSE MUSCULOSKELETAL INJURIES AS REFERENCED IN
THIS CITATION.  THIS PLAN SHALL INCLUDE, AT A MINIMUM,
TARGET DATES FOR THE FOLLOWING ACTIONS WHICH MUST
BE CONSISTENT WITH THE ABATEMENT DATES REQUIRED BY
THIS CITATION:
employees are exposed to the ergonomic stressors of repetitive lifting of
packaged goods
weighing up to, or in excess of 60 pounds.  Employees must repeatedly
reach forward,
bend at the waist, and twist the torso to obtain the product from
palletized supply located
under over head racking.  Racking design requires lifts to be performed
with the torso
bent and the load held out and away from the body.  A calculation of these
(1)  EVALUATION OF ENGINEERING /ADMINISTRATIVE
CONTROLS OPTIONS;
(2)  SELECTION OF OPTIMUM CONTROL METHODS AND
COMPLETION OF DESIGN;
(3)  PROCUREMENT, INSTALLATION, AND OPERATION OF
SELECTED CONTROL MEASURES; AND
(4)  TESTING AND ACCEPTANCE OR MODIFICATION-
REDESIGN OF CONTROLS.
All proposed control measures shall be approved for each particular use
lifting tasks
by an ergonomist,
industrial hygienist, or other technically qualified person.  30-day
progress reports are required
during the abatement period.
* NOTE- The 30 day requirement for the submission of progress reports may
be
lengthened or shortened depending on the length of the overall abatement
period.
Monitoring inspections could also be scheduled, if so desired by the AREA
DIRECTOR.
DATE DUE:09/12/00
STEP III:SUBMIT TO THE AREA DIRECTOR IN WRITING ACTION TAKEN
SHOWING REDUCTION IN MUSCULOSKETAL INJURIES.  90 DAY
PROGRESS REPORTS ARE REQUIRED DURING THE ABATEMENT
PERIOD.
DATE DUE:09/12/00
12/16/00
03/13/00
STEP IV:ABATEMENT SHALL HAVE BEEN COMPLETED BY THE
IMPLEMENTATION OF FEASIBLE ENGINEERING CONTROLS
AND/OR ADMINISTRATIVE CONTROLS UPON VERIFICATION OF
THEIR EFFECTIVENESS IN ACHIEVING COMPLIANCE.
DATE DUE:03/13/01
*** Certification and Documentation of Abatement Required ***
utilizing the NIOSH Lifting Guide Allowable Limits (1991) indicates that
the NIOSH
Recommended Weight Limit for this task is consistently exceeded.  These
ergonomic
stressors are causing or are likely to cause cumulative trauma disorders
to the back,
shoulder, lower extremities, and/or lower extremities as evidenced by a
review of the
company's injury and illness records from 1997 to the time of inspection,
which
document that a significant number of musculoskeletal disorders have been
caused by
exposure to these stressors.
ABATEMENT METHODS
Feasible means to correct these hazards include continuing the development
and implementation
of a comprehensive written ergonomics management program, monitored by a
qualified
professional trained in ergonomics, and a comprehensive medical management
program
monitored by a qualified health care provider, which utilizes the
following elements:
I. WORK SITE ANALYSIS to recognize and identify existing ergonomic illness
checklists and
employee questionnaires.  Frequent surveys of the workplace shall be
conducted by a qualified
professional trained in ergonomics to identify and evaluate ergonomic
stressors and the work
practices and engineering controls needed for their abatement.  The survey
shall include a job
analysis of all high risk, restricted duty, and other jobs used within an
administrative controlscheme.  The job analysis shall specifically
identify all ergonomic stressor and the body part
affected.   Employees on restrictive duty shall not be placed on jobs
where conditions exist that
could re-injure body parts being protected by a restricted duty assignment
or on jobs which when
performed with restricted capacity place excessive strain on another body
part.  Employee
participation in the program should be encouraged through a mechanism such
as a safety
committee.
II.  HAZARD PREVENTION AND CONTROL which includes the development and use
of
engineering, work practice and administrative control measures, and
personal protective
equipment, where deemed relevant.
1)  Engineering controls are to be designed by a qualified professional
trained in
ergonomics and may include work station redesign, tool redesign, and
changes in work
methods.  The goal of this program is to make the task fit the person.
Examples of
control measures applicable to the cited work tasks listed above may
include but are not
limited to the following:
a. Dry/Refrigerated Area Selectors:
i)  Redesign the warehouse storage rack system and the pallet jack so that
heavy
objects are located at an optimum lifting height which minimizes torso
flexion and
overhead reaches.  Optimal height is between chest and thigh level.
Recommendations to achieve these optimal heights include:  1) Utilizing
additional pallets as spaces to elevate the load;  2) Utilize palletizers
in the bins
of the racking system as well as on pallet jacks;  3) Utilize elevated
carts pulled
by tugs instead of pallet jacks;  4) Provide additional horizontal rack
cross
members to raise the bottom pallets off of the ground
ii)  Limit the weight of items handled manually through cooperative
efforts with
suppliers or through in-house techniques.   Ideally, manually handled items
should weigh no more than about 40 pounds.
iii)  Develop a ranking system to identify storage areas which require
hazardous
lifting tasks.  The ranking system should identify heavy and bulky objects
stored
at low locations as the most hazardous and light compact objects as least
hazardous.  The storage locations of the most hazardous lifting tasks
should be
clearly identified to stocking and picking employees.  An operation
procedure
should be developed to provide reorientation of those items identified as
creating
the most hazardous lifting tasks.  These locations should have the pallet
turned
and/or elevated as needed to maintain optimum lifting postures.
iv) Modify the bins at the end of the aisles so items can be accessed from
the
front and the side.  Move the stabilizing cross member so employees can
enter
the bin from the side as well as the front.  This modification will enable
employees to obtain heavy items from two sides and allow the load to be
lifted
and maintained close to the body.  Employees should have access to all
sides ofthe pallet eliminating excessive reaches to pull and/or lift
objects toward the
body.
v)  Install a track system which will allow the entire pallet of product
to be pulled
out of the bin.  This modification will permit the pallet to be accessed
from all
sides and allow the load to be lifted and maintained close to the body,
eliminating
the need for extended reaches and torso flexion.  The addition of a
turntable will
permit the rotation of the pallet 180 degrees, allowing placement back
into the bin
with the items previously in the back now easily accessible from the front.
vi)  Install a platform having casters or wheels that palletized product
can be
placed onto.  This modification will permit the pallet to be pulled out
from the
bin providing access from all sides,  allowing the load to be lifted and
maintained
close to the body, and eliminating the need for extended reaches and torso
flexion.  THE wheels will permit the rotation of the pallet 180 degrees,
allowing
it to be placed back into the bin with the items previously in the back
now easily
accessible from the front.
vii)  Provide a long handled tool to pull product closer to the front edge
of the
rack opening before it is lifted.
viii)  Educate the employees on the basics of body biomechanics and the
importance of maintaining the body in an ergonomically neutral position.
Torso
flexion should be limited to no more than 6 to 10 degrees from vertical.
Maximum reach distances of 16 to 18 inches forward are recommended and the
arms should be maintained in front of the body at all times minimizing
reaches
out to the sides.  The hands should not be elevated above shoulder height
and the
load should be maintained at waist level.  Employees should be trained on
the
hazards of repetitive torso flexion and reaches and made aware that the
weight
and positioning of an item is important to their safety.  The load should
be
maintained close to the body and the feet rotated, turning the entire body,
eliminating twisting of the torso.  Employees should not lift multiple
items raising
the weight of the  load to unacceptable levels, or reach to distant
locations to
access product and/or reach with a load in the hands to place product on a
pallet.