OSHA Inspection: SHAW'S SUPERMARKETS, INC.

Issued

Jan 21, 2015

Abate by

Mar 27, 2015

Penalty

Initial $7,000 · Current $0 Reduced

General-duty citation text

OSH ACT of 1970 Section (5)(a)(1): 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 full time warehouse employees performing selecting tasks in the warehouse facilities, are required to perform manual material handling tasks involving ergonomic risk factors including but not limited to, forceful exertions, repetitive motions, twisting, bending, and awkward postures and combinations thereof that had caused or were likely to cause musculoskeletal disorders (MSDs):   Location: Warehouse  On or about July 23, 2014, employees performing selecting tasks were required to perform tasks involving repeatedly lifting, reaching, twisting, and bending, when selecting items for orders, loading them onto pallets, and then wrapping the pallets. The evaluation of these manual lifting tasks indicates that employees are exposed to hazards that cause and are consistent with development of MSDs, including back, shoulder, and neck strains and sprains.   ABATEMENT METHODS: While some ergonomic related risk factors can be reduced or eliminated 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 factors. Examples of such measures include but are not limited to as follows:     1.      Provide an ergonomic assessment, by a certified professional ergonomist, industrial engineer, or other qualified professional, of the manual material handling tasks.  The ergonomist, or other qualified professional, shall make recommendations for reducing or eliminating ergonomic risk factors from the work of the employees performing Manual Material Handling (MMH) tasks in the position of order selector after his/her review of the MMH tasks and other physical factors. The ergonomics assessment should be repeated whenever conditions of order selection change (e.g., new product, new packaging, new slotting, or reported MSD injury or illness).      2.      Have a certified professional ergonomist or other competent person, review order selector ergonomics training to ensure its effectiveness.      3.      The company should consider labor/management ergonomics teams (e.g., one team for grocery and another for freezer and teams for 1st and 2nd shift).  Management should assign a person to lead the company-wide ergonomics program 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 among order.     4.      Engineering controls are to be designed by a qualified ergonomics professional and may include workplace redesign, work station redesign, equipment or tool redesign.  The goal is to make the job task fit the worker.  Examples of control measures applicable to the observed job-specific tasks may include, but are not limited to, the following:     a.       Implement changes to the racking system and pallet jacks to minimize exposure to the hazards of MMH.                                                                   i.       Reduce forward torso bending, twisting, and extended reaching by raising the height of the shelf that the product is located on so lifts can be performed between mid-thigh and mid-chest height.  This is especially important for product that is in excess of 40 pounds or is particularly bulky, oversized, or unstable.  When placing palletized items in selecting slots care should be taken  to ensure that the top level of palletized products stored in the slots do not exceed the shoulder height of the order selector.         1.      Elevate the height of the product to be lifted by providing a fixed height platform on which to place palletized loads.  This will raise the lowest levels of the load to a more desirable height.   Care must be taken not to raise the load to heights which increases the risk while removing the upper levels.  Several wooden pallets secured together and stacked on each other is one possibility to provide such a platform.   2.      Store very heavy items on a stand in an open area (without rack) to provide access to all sides of the pallet.  Also when an order has several layers of the same item such as water, consider mechanically adding layers to an order instead of manually picking.  3.      For very heavy or awkward products consider providing height-adjustable palletizers or scissors lifts that will automatically raise the lifting height when the product is unloaded.  These have the advantage of lowering the height of the top level of the palletized load while still raising the height of the lowest levels of the palletized load.  4.      Use pallet jacks or fork lifts with height adjustable forks which can be raised to reduce the forward torso bending and twisting while loading the bottom layers of the order.  5.      Eliminate the lowest level of case flow rack picking slots.  Reduce the need to lift from below mid-thigh or above shoulder height.                                                                 ii.      Reduce torso bending, twisting, and extended reaching by improving access to product before lifting.  Train workers to move product close to their body before it is lifted.  This is especially important for those products that present an increased risk to order selectors because of weight, size, or the frequency of the pick.     1.      Leave slots on the end of aisles open to allow order selectors to pick from the side as well as the front of the slot.  2.      Provide adequate access to and around pallets within the slot by increasing the slot width and height so order selectors can enter the slot without forward torso bending or twisting.  Consider removing double cross-beams on second level slotting shelves to improve posture and access.  3.      Improve access to products located at the back of pallets by spinning the pallet, or provide a platform with casters which can be manually rolled from the slot and turned, or by removing and turning pallets with fork lifts.      a.       Consider measures such as ergo-spins/labor hour, slots in need of an ergo-spin at breaks.    b.      Consider the possibility of using pallet disc turntables under pallets that contain heavy, bulky, and/or frequently picked products to improve posture and reduce extended reaching.     4.      Require the use of pick sticks and provide time to use the pick stick for cases that are not within easy reach.  Pick sticks reduce extended reaches by allowing product to be pulled closer to the body before it is lifted.     b.      Develop and implement measures to reduce the force order selectors must exert to perform non-lifting tasks.                                                                   i.      Acquire automated plastic stretch wrap stations.  With these stations the order selector deposits a filled pallet onto a turn table and the load is automatically wrapped.                                                              ii.      If loads must be manually wrapped, modify the tools and working techniques to reduce physical stress to the order selectors.                                                            iii.      Provide smaller, lighter, and narrower rolls of plastic wrap to order selectors.  This will decrease the weight and require less force when pulling plastic wrap from the roll.                                                             iv.      Reduce force requirements on the hand/wrist by providing appropriate ergonomic knives (i.e., utility, retractable box cutter) for cutting wrapping plastic.      c.       Work cooperatively with suppliers to modify the properties of products including the weight, size, bulk, hand coupling, and resistance to movement.  Improving the characteristics of the product will reduce the risk of injury to the order selectors.                                                                     i.      Packaging should have handles or cutouts to ensure good hand coupling.                                                              ii.      Packages should be no wider than approximately shoulder width.                                                            iii.      Packages should weigh no more than approximately 40 pounds.                                                            iv.      Slip sheets should be placed between layers of plastic-wrapped cases (tray packs) so order selectors can slide product close to the body before it is lifted.      5.      Administrative controls should be implemented to reduce the duration, frequency, and magnitude of the order selector?s exposure to ergonomics risk factors.  These controls may include, but are not limited to job rotation, work rest scheduling, reduction of repetitive task rate through additional staffing, or the reduction of work quotas.  For any administrative control measure, a detailed job and task analysis must be performed to assure that other stressors, body part movements, or musculoskeletal system usage is not present at a magnitude that would be beyond the capability of the worker.  Examples of controls which may be used at this site includes:     a.       Develop work processes and train order selectors to recognize job-specific ergonomic hazards and perform their tasks with minimum stress to the body.                                                                   i.      Implement and enforce cube weight restrictions when building a palletized load.  These restrictions limit the weight that can be placed at certain heights of the palletized load.  Consider establishing a maximum pallet height and place a pole with a maximum height marker on the pallet jack, if an order goes above the marker consider allowing the selector to get another pallet.                                                              ii.      Improve access to cases by removing stretch wrap and banding before product is placed in the pick slots.  Consider providing more time for porters to improve slot accessibility and housekeeping.                                                             iii.      Implement a slotting committee to identify and propose less physically demanding slots for products and provide this information into the rotation and ergonomic assessment projects and plans.                                                            iv.      Provide ergonomic awareness training to order selectors, as well as other employees working in the facility, which teaches employees basic ergonomics principles, ergonomics hazard recognition, proper work methods, practices and techniques, recognition of signs and symptoms of MSDs, and the importance of their early reporting.                                                              v.      Provide job-specific training to order selectors on ergonomics principles, early reporting of symptoms, safe manual materials handling practices, and how to use ergonomic controls.     1.      Train and enforce the layer picking technique that requires all the cases from a layer to be picked from one layer before removing the cases from the next layer. A pick stick is needed to reach cases beyond easy reach.  2.      Demonstrate the importance of starting the order with the forks of the pallet jack raised to the highest level.  3.      Demonstrate how to position the pallet jack close to the picking slot to reduce carrying of cases from the slot to the selection pallet.  4.      Train order selectors to avoid lifting more than one item at a time if the total weight of the lift exceeds a specified weight.  This is generally 35 to 50 pounds, but may vary depending on analysis of the manner in which the task is performed.  Train and encourage two-handed lifting vs. one-handed lifting.     b.      Design work schedules and order selection rates to provide periods for rest and recuperation.                                                                   i.      Schedule breaks for order selectors to recover from local and whole body fatigue.  For employees working on 10 hour shifts, consider providing a longer break after 8 hours of work.                                                              ii.      Use a certified professional ergonomist, industrial engineer, or other qualified professional to determine the risk factors of tasks that can be used for a rotation.  Develop policies so order selectors can rotate through other jobs and/or tasks, which produce less stress.  Periods of work-rest may be appropriate if they utilize different muscle groups.         c.       Develop overtime polices to minimize the risk of over-exertion.                                                                   i.      Before assigning employees to work overtime ask for volunteers first.                                                              ii.      Assign overtime to employees who are not experiencing or recovering from MSDs.                                                            iii.      If possible, assign overtime consisting of working more days in the week rather than working longer hours during the days.                                                            iv.      Provide additional rest to order selectors, or incorporate additional lunch periods into the day if extended day overtime is to be worked.     d.      Improve recordkeeping on the OSHA 300 logs by providing increased accuracy, for example specifically describe the location of the recordable injury or illness to assist in discovering ergonomic problems and by tracking the progress in solving these problems.  Ensure all work related injuries are reported.  Ensure employees are properly trained on how to report injuries and that employees are not discouraged from reporting injuries due to complicated processes or systems.     e.       Implement an incentive program that focuses on positive safety action.  Avoid incentives to work faster, such as additional pay or early release from work.  These incentives are production focused and may result in employees taking unnecessary short cuts or using improper ergonomic technique which potentially leads to unsafe acts.  Ensure that any incentive programs do not discourage reporting of injuries, illnesses, or symptoms.       6.      Work Practice     a.       When an improper lifting technique is observed by the supervisor, there should be immediate intervention and training to correct the improper technique.  Ensure through proper training and formal enforcement of safe lifting rules, and that the order selectors do the following: bring product to the body before lifting, avoid torso bending and twisting while lifting, avoid extended reaching across pallets, avoid one-handed lifting, and product lift only one item at a time.   b.      Implement work practice controls for conditioning and ramp-in of new employees, injured employees returning to the job, and/or employees returning from leave or other absences.    c.       Provide order selectors with appropriate warm-up exercises and a period of time at the beginning of a shift and after lunch to perform the warm-up exercises.      7.      Provide personal protective equipment (PPE) such as high friction gloves to order selectors that can help reduce force requirements of job-specific order pulling/selection tasks involving repetitive lifting/handling of cases.     8.      Medical Management       a.       Develop and implement a mechanism for early reporting of signs and symptoms of MSDs.  Training order selectors to understand the mechanism of MSD progression and the importance of early recognition and reporting of signs and symptoms of work-related MSDs.  The proposed strategy can help reduce the incidence and severity of work-related MSDs.  b.      Provide appropriate light duty jobs that are consistent with medical restrictions.  c.       Designate a medical provider who is familiar with selector tasks to provide tailored fitness-for-duty and job accommodation recommendations to management.  This is likely to speed recovery and reduce disability.