OSHA Inspection: BROWN PRINTING COMPANY

Issued

May 27, 2003

Abate by

Nov 9, 2004

Penalty

Initial $4,500 · 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 employment and a place of employment which were free from
recognized hazards
that were likely to cause serious physical harm to employees, in that
employees were
required to perform tasks resulting in stressors that were causing, or
were likely to cause
musculoskeletal disorders (MSDs):
a)  On or about and continuing from January 30, 2003, sorters/sackers
reach, grasp
and lift stacks of magazines weighing up to 56 pounds. Employees bend and
reach in
order to place stacks of magazines onto pallets, which creates ergonomic
stressors
causing serious injuries to employees' backs and upper extremities.
Among other methods, feasible and acceptable abatement methods include the
following:
Engineering controls, including, but are not limited to, the following:
i.Place pallets to be loaded on scissor-lift tables which are accessible
to pallet
jacks. The use of lift tables will eliminate the need to bend over to place
bundles on the bottom levels of the pallet.
ii.Equip the lift tables with a turntable mechanism on top of the table so
that the
need for reaching can be significantly reduced.
iii.Remove backboards from any lines which utilize them. This will enable
employees to access all sides of the pallet and reduce the need for
reaching
and stretching.
Administrative controls, include, but are not limited to the following:
i. Implementation of a job rotation program in which employees would rotate
from sorter/sacker to a non-material handling position during their 12 hour
shift, if any are available.
ii.  Development of proper lifting techniques for employees to use when
lifting
and carrying materials to be stacked on a pallet. Train employees to take
smaller stacks.
iii. New employee work hardening policies which slowly work new employees
up
to a full 12 hour shift.
iv.Development of a monitoring program to ensure that all employees
continue to
use proper work practices.
Abatement should also include, the implementation of an ergonomics
management program
consisting of the following four elements:
1. Worksite analysis to recognize and identify existing cumulative trauma
disorders in the
workplace. This analysis should include development and use of an
ergonomic checklist and
employee questionnaire. Periodic surveys of the worksite shall be
conducted at least annually
to evaluate work practices and engineering controls. Employee
participation in the
ergonomics program should be encouraged.
2. Medical management which includes accurate recordkeeping of work-related
musculoskeletal disorders (WMSDs). The program should address early
recognition,
evaluation, and referral of WMSD cases, and should include conservative
treatment and
conservative return to work. Systematic worksite review by the medical
team should also be
included in the program.
3. Training and education of exposed employees, including methods to
evaluate the
effectiveness of the training. Re-training should be done annually, or as
operations change.
Training should address hazards associated with the job, the risks of
developing WMSDs,
symptoms of exposure, and how to prevent the occurrence of a WMSDs. A
supervisors'
training program should also be implemented to allow recognition of the
signs of WMSDs
and to reinforce the employer's ergonomic program.
4. Hazard prevention and control which includes engineering, work
practice,
and
administrative controls, and personal protective equipment where relevant.
a)  Engineering controls are designed by a qualified ergonomist and may
include work
station redesign, tool and handle redesign, and change of work methods.
The goal of
this program should be to make the job fit the person.
b)  Work practice controls are implemented which include proper work
techniques,
new employee conditioning, and monitoring and modifications as necessary to
minimize ergonomic stressors.
c)  Administrative controls are implemented which reduce the duration,
frequency,
and severity of exposure to ergonomic stress. These controls may include,
but are not
limited to, job rotation, reduction of repetitions, and preventative
maintenance of
related equipment. Personal protective equipment shall be evaluated to
determine any
contribution to ergonomic stress.
STEP 1: Submit to the Area Director a written plan to develop and
implement an ergonomic
management program and a detailed plan of abatement within 60 days
outlining a schedule
for the implementation of engineering and/or administrative measures to
control employee
exposure to stressors that were causing or likely to cause MSD's. 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:
1. Evaluation of engineering/administrative control 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.
Progress reports shall be submitted every 45 days thereafter.
STEP 2: Abatement shall have been completed by the implementation of
feasible
engineering
and/or administrative controls upon verification of their effectiveness in
achieving
compliance.
Abatement certification and documentation required within 10 days after
abatement date.
The certification shall include a statement that abatement is complete,
the date and method of
abatement, and state that employees and their representatives were
informed of this
abatement.  Abatement documentation shall include documents demonstrating
that abatement
is complete, such as evidence of the purchase or repair of equipment,
photographic or video
evidence of abatement or other written records.

Issued

May 7, 2003

Abate by

Jun 9, 2003

Penalty

Initial $1,800 · Current $5,880

Issued

May 7, 2003

Abate by

Jun 9, 2003

Issued

May 7, 2003

Abate by

Jun 9, 2003

Issued

May 7, 2003

Abate by

Jun 9, 2003

Issued

May 7, 2003

Abate by

May 9, 2003

Issued

May 7, 2003

Abate by

May 9, 2003

Issued

May 7, 2003

Abate by

May 9, 2003

Penalty

Initial $3,150

Issued

May 7, 2003

Abate by

May 9, 2003

Penalty

Initial $4,500 · Current $1,800 Reduced

Issued

May 7, 2003

Abate by

May 12, 2003

Penalty

Initial $1,350 · Current $720 Reduced

Issued

May 7, 2003

Abate by

May 9, 2003

Penalty

Initial $1,350 · Current $720 Reduced

Issued

May 7, 2003

Abate by

May 9, 2003

Penalty

Initial $1,000 · Current $1,000

Issued

May 7, 2003

Abate by

May 12, 2003