OSHA Inspection: AMERICAN STANDARD, INC.

Issued

Jan 19, 2001

Abate by

Mar 8, 2001

Penalty

Initial $4,500 · Current $3,375 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 employees
were required to perform tasks involving hazards resulting in risk factors
that had caused, were
causing, or were likely to cause musculoskeletal disorders (MSDs) of the
hand, arm, shoulder
and back. Instances of the physical work conditions and risk factors
observed appear below:
a)Nutec Department/Spraying:  On or about 7/20/00, workers performed tasks
which exposed them to the following ergonomic hazards:
1.Repetitively lifting the hand above shoulder height to: (i) position the
spray gun so as to spray the top and upper areas of the product, (ii) to
spray the interior of the bowl section and (iii) to perform other necessary
tasks on the upper areas of the product, such as wiping it off with a
sponge.
2.Manually supporting the spray gun and attached hoses for prolonged
periods of time. The arm is frequently lifted away from the side of the
body to repetitively reach the upper areas of the product.
3.Bending of the wrist while repeatedly exerting finger force to activate
the
spray gun and repeatedly rotating the forearm to spray the bowl and other
hard to access areas. Bending of the wrist and rotation of the arm increase
as upper areas of the product are sprayed.
4.Repetitively lifting product up to 74 pounds while assuming awkward
postures such as bending the torso forward or reaching and lifting with the
arms to place product on the spraying stand or on the Langley carts.
b)Nutec Department/Kiln loading/unloading:  On or about 7/20/00, employees
performed tasks which exposed them to the following ergonomic hazards:
1.Loading. Repetitively applying force to lift (two-worker lift) product
weighing up to 74 pounds while assuming awkward postures such as
extending the hands above the head to reach the top shelf of the kiln rack.
2.Placing styrofoam pieces and support blocks under the toilets while
assuming awkward postures such as reaching above head height.
3.Unloading. Repetitively applying force to lift (unassisted) product
weighing about 70 pounds while assuming awkward postures such as
reaching above head height to grasp the product from the top shelf. The
worker rotates the product with the shoulders to stack it on the finishing
pallet.
Among other methods, some feasible and acceptable abatement methods to
correct
these hazards include implementation of the following controls:
1.Provide automated, robotic spray booths for the Nutec department so
product can be coated mechanically. Use of an automated or robotic
system will eliminate all of the manual hand spraying hazards as hand
spraying will no longer be performed.
2.Sprayers should have product placed on adjustable height positioners, to
eliminate elevated arm postures and torso bending. The positioner should
be both height and tilt adjustable and allow product rotation by the
operator. This type of device can be lowered for ease of product loading
and for spraying of the upper areas. The positioner can then elevate the
product so the lower areas can be sprayed. After all spraying is
completed, the product can again be lowered for removal and reloading
of new product. This type of device will eliminate the use of elevated arm
postures and lifting of heavy product using awkward body postures. It will
also significantly reduce the amount of bending in the wrist while
performing spraying operations.
3.Sprayers should be provided with a spray gun which has the supply hoses
suspended from above. This will allow the sprayers to use the guns
without the need for constant lifting and moving of the hoses.
4.Sprayers should be provided with both foot and hand activation points for
the spray gun. This change will provide periods of rest and recuperation
since it will limit the need to perform repeated and/or prolonged finger
and hand exertions.
5.Alternatively, the static load created by the trigger on the spray
nozzle can
be eliminated by providing a foot-operated control. Such control would
need to be flush with the standing surface when activated to avoid
awkward postures while standing.
6.Provide an alternative to or modify the Langley cart. This cart forces
all
employees involved in the transfer of greenware to reach well above
shoulder height to load the top level and to bend at the waist to load the
bottom level. The sprayers already have significant stress to the shoulder
and back from their spraying tasks and performing the loading and
unloading tasks, using these carts, further exacerbates the hazard that
they
experience. Alternatives might include:
a. Use of conveyors to move product from one location to another,
especially between the casting and spraying departments.
b.Securing greenware to a captive pallet (e.g., a setter) that can be
mechanically handled. The mechanical device could be one that
can be rolled by the operator.
c.Hinging the upper shelf of the current cart so lower shelves can be
loaded while minimizing the bending to the torso. Some of the
torso bending currently performed is necessary because employees
reach under the upper shelf to gain proper access. Hinging this
shelf back out of the way, will provide less restriction to access.
d.Use of a cart with a single shelf at a height where loading can be
performed while keeping the hands between about waist height and
mid chest height. Elevating the bottom shelf of the current cart
would be a possibility if the current upper shelf were hinged so it
could be pushed back out of the way when loading larger product.
This would allow the possibility of using both shelves for smaller
product such as basins and then pushing the top shelf out of the
way for larger product such as toilets.
e.Use of the height adjustable truck that uses a pneumatic piston or
other device to raise or lower the loading height. The raise/lower
device could be used to lower the upper shelf until it is at about
waist height. After the upper shelf is filled the mechanism could
be activated and the shelf could be raised, allowing the lower shelf
to be loaded. Unloading would be accomplished in essentially the
opposite sequence.
f.Use of a rack that can move up and down (e.g., an elevator as
used in another department) or a lift platform to bring the worker
to the appropriate height. Another approach is to load a shelf at a
desirable working height and then mechanically loading the shelf
into the kiln rack.
7.Educate all employees about body positioning and lifting implications.
Training will emphasize proper techniques and increase the understanding
of the importance of avoiding harmful and hazardous postures and
procedures. Generally, proper ergonomic design will allow the employee
to work at a standing task without bending forward at the waist and with
the elbows maintained in close to the body. All tasks should be performed
in front of the employee so twisting of the body is minimized. Tasks
performed with the hand should be designed so the wrist is not bent either
up or down, or to either side while the fingers are being used.
Training can also be useful for management since it can assist them in
encouraging proper work techniques and will increase their knowledge of
the subject allowing them to make better purchasing and workorganization
decisions. Maintenance personnel can also benefit from this
type of training since they often have the best mechanical skills at the
work site and can be an invaluable source of ideas about development of
new tools or equipment modifications that can reduce the hazard to the
employees.
8.Finally, developing an organizational framework for an ergonomics
program that provides for: Management leadership; Employee involvement
in all aspects of the program; Job hazard analysis and control; Training;
Musculoskeletal disorder management; and Program evaluation.
NOTE:ABATEMENT DOCUMENTATION REQUIRED FOR THIS ITEM.
See page 2,"Notification of Corrective Action" for instructions.

Issued

Jan 19, 2001

Abate by

Jan 24, 2001

Penalty

Initial $1,800 · Current $1,350 Reduced

Issued

Jan 19, 2001

Abate by

Jan 24, 2001

Penalty

Initial $1,350 · Current $1,013 Reduced

Issued

Jan 19, 2001

Abate by

Jan 24, 2001

Issued

Jan 19, 2001

Abate by

Mar 8, 2001

Penalty

Initial $2,250 · Current $1,688 Reduced

Issued

Jan 19, 2001

Abate by

Mar 8, 2001

Issued

Jan 19, 2001

Abate by

Mar 8, 2001

Issued

Jan 19, 2001

Abate by

Mar 8, 2001

Penalty

Initial $1,350 · Current $1,013 Reduced

Issued

Jan 19, 2001

Abate by

Mar 8, 2001