OSHA Inspection: UNION BEER DISTRIBUTORS

Issued

Feb 13, 2013

Abate by

May 6, 2013

Penalty

Initial $7,000 · Current $3,500 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 causing or likely to cause muscular skeletal disorders death or serious physical harm to employees in that employees were required to perform manual material handling:     a) Beginning on or about August 16, 2012 and continuing through the present.  Employees working as delivery drivers and helpers were exposed to risk factors that are causing or likely to cause Musculoskeletal Disorders (MSDs).  Employees were required to perform material handling tasks associated with the delivery of beverage cases, kegs and pallets of product involving MSD risk factors such as, but not limited to, forceful exertions, repetitive motions, and awkward postures occurring for prolonged durations.    ABATEMENT:  While some risk factors can be eliminated or reduced by implementing a single means of abatement, in most cases a process that includes analysis of the worksite, medical management, training and education of employees (in both recognition of injury and avoidance of injury), and hazard prevention and control will provide the most effective method of addressing the risk factors.  The employer may adopt measures that are effective in reducing or eliminating the risk factors, such as the recommendations from the July 1996 NIOSH document Ergonomic Intervention for the Soft Drink Industry.  Hazard prevention and control include implementation of feasible engineering controls, where possible, prior to implementing administrative and work practice controls.      Engineering Controls:    1.	The company should develop and implement measures to minimize the force employees must exert to perform their tasks.  a.	Springs on trailer doors should be balanced so they require minimal force exertion when opening and closing.    b.	Provide regular maintenance of the rear door and ramp systems of the trucks including proper cleaning and lubrication of the door rollers and roller tracks, ramp tray rollers, and spring lift mechanisms.  c.	Periodically replace ramps if the traction nodules (spikes) appear to wear to the point where adequate traction no longer can be achieved.  d.	Require all sites to have slides, or carry portable slides when kegs must be delivered down stairs.     2.	The company should provide employees with delivery hand trucks that reduce the risk to workers from forceful exertions and awkward postures.  These modifications include but are not limited to:  a.	Delivery hand trucks equipped with brakes that can help reduce force required to keep loads under control when on ramps, steep inclines and/or stairs.  b.	Delivery hand trucks with adjustable height load platform or toe plate so that loading/unloading can be done at about waist height to address awkward posture of the workers including repetitive torso bending and twisting when loading/unloading the hand trucks.   c.	Delivery hand trucks equipped with larger hard pneumatic wheels.   These wheels roll more easily over rough terrain and over areas with gaps such as storm drains or cracks in sidewalks or streets.  Pneumatic wheels operate better over softer non-paved surfaces.  1. Delivery hand trucks with pneumatic wheels must be maintained to have recommended air pressure in both wheels at all times.  d.	Delivery hand trucks should have a securing strap or elastic cord to hold loads in place so workers can maintain better body postures while going down stairs.  e.	Use delivery hand trucks with fold away back wheels which minimize the amount of weight employees need to support when traveling over longer distances.  f.	Provide padding on extender bars which often rest on the forearms of employees during transport.  g.	Provide stair climbing delivery hand trucks with replaceable low-friction polymer glide bars for delivering the beer products into the basements of the establishments on the delivery list.  h.	Develop and implement a preventive maintenance schedule for the delivery hand trucks and ramps.     3.	The company should provide the beer delivery workers with appropriate ergonomic knives (i.e., utility, retractable box cutter) for cutting wrapping plastic before loading cases onto the hand trucks.    4.	The company should consider providing portable curb blocks or ramps that can help reduce force exerted by workers when moving the heavily loaded delivery hand trucks over sidewalk curbs and/or other obstacles.    5.	The company should consider using lightweight alternatives to heavy wooden pallets such as:  a.	Plastic pallets which are lighter; more space efficient and do not present a hazard from slivers or nails.  They require much less force exertion while lifting/handling and nest to take up less space in the trailer so they are not an impediment to proper body posture.  b.	Slip sheets, or similar technologies, instead of pallets when organizing loads within the delivery trucks.  These are extremely light and take up almost no space.  This may allow at least some of the loads to be placed on the delivery hand trucks without lifting them from the pallet.    6.	The company should consider acquiring new trailers over time, that have a lower deck height or which can kneel when at the delivery site thus decreasing the slope of the ramp and the force exerted to bring loads to ground level.      7.	Elevate palletized loads to reduce the amount of bending required to lift products from the bottom levels of the pallet.  This could be accomplished by placing the products on pallet on top of each other.    8.	The company should investigate providing fans or other cooling ventilation devices in trailers to reduce worker fatigue caused by summertime heat.    Administrative Controls:      1.	Loads should be arranged at the warehouse and at the job site to minimize the risk to the employee from awkward postures, forceful exertions and high repetitions of lifts.  Some specified interventions include:  a.	The company should ensure that various beer products are packaged, packed and/or arranged according to customer order to minimize the amount of sorting, lifting, and awkward postures required at the delivery site.  b.	The company should ensure coordination between the workers loading beer products onto the trucks (loaders) and the beer product delivery workers (driver and helpers) so that product is placed and arranged for easy and efficient removal at the customer site.  1.	The company should consider providing a load map that can help identify the location of various beer products in the trucks without their visual verification.  c.	Instruct employees to reduce the amount of product placed on a delivery hand truck when going down stairways.    2.	Delivery sites should be evaluated by management to identify and remediate hazards.  Management shall:    a.	Make workers aware of identified hazards.  b.	Develop a mechanism for workers to report new hazards that may develop over time.  c.	Periodically re-evaluate sites when new hazards are identified.  d.	Coordinate with owners of the site to alleviate hazards whenever possible.  e.	Consider the hazards of the site when developing delivery schedules.    2.	Deliver to more hazardous sites earlier in the day when employees are rested.  3.	Spread the more hazardous sites out between all routes so no one group of employees is subjected to excessive strain.  4.	Provide additional employees or appropriate tools (i.e., stair climber delivery hand trucks) to those sites identified as hazardous.    3.	The company should work with suppliers to ensure that the hazard created by the products is minimized.  These include but are not limited to:  a.	Beer cases/boxes/kegs are equipped with appropriate (wide, strong) handles/cut-outs that can help reduce force requirements and improve working postures associated with the job-specific tasks involving repetitive lifting/handling of various beer products.    4.	The company should consider assigning a person to manage the companys efforts aimed at the reduction of risk and prevention of MSDs in the workplace. The proposed strategy can help reduce the risk and prevent the occurrence of MSDs primarily among workers involved in performing manual materials handling tasks.    5.	The company should institute a better communication system so management can become better aware of problems and employees are notified of changes and improvements.  a.	The company should consider setting-up a safety committee aimed at eliminating unsafe conditions, identifying improvements, reviewing incidents and accidents and ensuring effective communication.    b.	The company should implement a formal written hazard, repair, and incident reporting system to improve overall safety performance.  c.	The company should consider implementing safety alerts to improve response to incidents and accidents by sharing information that describes the event and the preventive measures that are put in place.    6.	The company should instruct employees to avoid stacking the beer cases too high on the delivery hand trucks as it can impair visibility during beer product delivery to establishments on the delivery list.    7.	Two or more employees should team-up to lift loads such as kegs which are too heavy for a single employee if they are being stacked or placed on shelves.    Training:      1.	The company should provide ergonomics awareness training to all workers.  Training should consist of: basic ergonomics principles, ergonomics hazard recognition, problem solving skills, proper work methods, practices and techniques as well as personal protection on the job.  The ergonomics awareness training should be provided on a regular basis (not less than annually and at initial hire).  Furthermore, periodic assessment and evaluation of effectiveness of the training and modification of its content, format and/or delivery mechanism if needed is essential in making the training an effective tool aimed at reducing the risk and preventing MSDs in the workplace.    2.	The company should consider providing job-specific ergonomics training to teach the workers proper manual materials handling methods, practices and techniques. The proposed strategy can help to reduce the risk and prevent exposure to the identified ergonomics risk factors associated with the job-specific beer delivery tasks as well as other materials handling tasks regularly performed in the companys warehousing facility.  If needed, the training must be provided in languages that the workers can fully understand.    3.	The company should consider providing job-specific ergonomics refresher training to the workers on a regular annual basis.    Medical Management    1.	The company should consider developing and practically implementing a mechanism for early reporting of signs and symptoms of MSDs, as well as, making the workers aware of the mechanism and the importance of early recognition and reporting the signs and symptoms of work-related MSDs.  The proposed strategy can help reduce the incidence and severity of work-related MSDs.