OSHA Inspection: ALLEN HARIM FOODS, LLC

Issued

Jun 15, 2015

Abate by

Jul 5, 2017

Penalty

Initial $7,000 · Current $7,000

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 serious physical harm to employees, in that employees were required to perform manual tasks involving ergonomic risk factors including, but not limited to, excessive force and exertion, repetitive motions, and awkward postures resulting in ergonomic stressors that caused or are likely to cause musculoskeletal disorders (MSDs) including, but not limited, to tendonitis, carpal tunnel syndrome, trigger thumb, and shoulder pain.        a) Cone Deboning (departments 665/765/664): On or about January 26, 2015 and at times prior and since, employees on the cone deboning line perform tasks that require torso twisting and lifting in a repetitive motion for extended periods of time and often in awkward positions exposing employees to ergonomic stressors that cause MSDs. The positions include, but are not limited to, Cone Loader;      b) Cone Deboning (665/765/664): On or about January 26, 2015 and at times prior and since, employees perform tasks that require the use of scissors and/or knives to remove chicken parts, fat, and cartilage in a repetitive, forceful motion for extended periods of time and often in awkward positions exposing employees to ergonomic stressors that cause MSDs. The positions include, but are not limited to, 1st and 2nd Shoulder Cut, Wing Cutter, Breast Puller, Tender Scorer, and Tender Clipper;      c) Tray Pack (658/758): On or about January 26, 2015 and at times prior and since, employees perform tasks that require the use of a knife to split chicken breasts and the use of scissors to trim fat, cartilage, and bone from chicken breasts in a forceful motion for extended periods of time and often in awkward positions, exposing employees to ergonomic stressors that cause MSDs. The positions include, but are not limited to, Breast Splitter and Breast Trimmer.    Feasible and acceptable means of abatement include but are not limited to:  engage in a process that includes analysis of the worksite, medical management of employee symptoms and injuries, training and education of employees in both recognition of injury and avoidance of injury, and hazard prevention and control to determine and implement the most effective methods of addressing the ergonomic hazards and an assessment of the effectiveness of the process.    The employer may adopt any measures that are effective in reducing or eliminating the risk factors for MSDs.  Specific feasible methods for abating the ergonomic hazards include, but are not limited to:    Engineering Controls:  1. Adjustable height platforms: These platforms should be individual stands and easily adjustable. Adjust the stands in between rotations to ensure that employees are working with minimal stressors caused by awkward positions. Train employees on how work height affects neutral posture. During new employee training, employees should demonstrate that they adjust the work platform to a height that minimizes neck, back, shoulder and wrist non-neutral postures. Consider numbering the slots on the work platform stand, so height adjustments can be easily replicated.  2. Evaluate work stations to determine the proper design of the stations to reduce reaching and twisting. Evaluate the position of the skinner conveyor belt in 664 to eliminate awkward postures such as twisting.    3. Provide scissors and knives with ergonomic handles designed for repetitive tasks. Scissor handles should be contoured and soft to avoid contact stress on the fingers. Provide scissors in multiple sizes to fit the employees? hands as well as left and right-handed models. Increase knife sharpening frequency on and off the lines.  4. Evaluate the knives and other tools available to cut wings and provide the most appropriate tool to employees.   5. Evaluate position of knife and scissor sharpeners to allow employees to use easily and often and to reduce employee reaching and minimize non-neutral positions. The sharpeners should be below shoulder height and maintained regularly.   6. Develop a knife and scissors sharpening program to include a schedule for replacing knives and scissors for every department, inspection procedures to ensure sharpness, proper sharpening techniques, and procedures for employees to request sharpening or a new tool if it cannot be sharpened by them. Include spare knives and scissors on the lines so that dull or worn ones can be removed immediately. Develop and introduce knife and scissor replacement standards that specify end of life indicators for triggering replacement. Replace knives and scissors as needed based on usage. Employees should be trained on the program, frequency of sharpening, and how to properly sharpen. Worn knives and scissors should be taken out of service immediately.  7. Install a training line so that new hires, temporary employees and employees learning new tasks can be trained on the proper position, height, and technique without the stress of keeping up with the line speed. Develop a work hardening program so that employees are on the training line for a progressively increased amount of time in order to strengthen muscles and reduce soreness and pain.      Administrative Controls:  1. Educate all employees including management about basic ergonomics principles and proper body positioning. Training should be conducted prior to assignment and periodically throughout the year to reinforce the importance of the ergonomic measures ,and their wellbeing. Training should emphasize proper techniques including work height and grip and increase the understanding of the importance of avoiding harmful and hazardous postures and procedures. New hires and temporary employees should be trained on how to work in neutral postures, to keep wrists straight, use of maximum grip strength, and why deviations from these positions lead to injuries. Training should also be conducted for management (line leaders and supervisors included) because they can assess and encourage proper work techniques. Training will also increase their knowledge of the subject allowing them to make better purchasing and work organization decisions. Maintenance personnel also need this type of training since they often adjust and maintain equipment, to include workstations, 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.  2. A rotation schedule should be developed, written, and implemented for each department with ergonomic stressors in order to minimize employees being rotated to positions with similar muscle use and tool use. Bonus positions should be included in this rotation. Rotations should be to other tasks to prevent continuous use of tools such as knives and scissors.  Incorporate micro-breaks during each task rotation to allow employees time to stretch and rest muscles.    Ergonomic Program and Medical Management:  1. Conduct an ergonomic assessment, by a certified professional ergonomist, industrial engineer, or other qualified professional, of the deboning and tray pack tasks and jobs.  The ergonomist, or other qualified professional, shall provide a job hazard analysis and recommendations for reducing or eliminating ergonomic risk factors from the work of the employees performing repetitive hand activity. The company should implement controls to eliminate the hazard or reduce the hazard to more acceptable levels.   2. Develop a participatory ergonomics team.  The composition of the team should be multi-disciplinary, including at least four hourly employees, union representation, plant management, engineering, maintenance, medical, and safety. The team should receive base training to achieve a basic competence in ergonomic hazard identification, principles, and risk reduction approaches with ongoing training and education. The team should solicit employee suggestions and follow-up on resolution to the suggestions.  The team should provide input to changes in layout and hand tool selection. The committee should consult a certified professional ergonomist or other qualified professional to review repeated concerns and conduct independent and joint audits.  3. An outside expert in medical management protocols shall review the medical management protocols for treating musculoskeletal injuries and education for employees on early reporting. The review of the protocol should include recommendations for alternate duty (e.g., time on alternate tasks/reassignment options for restricted duty) and appropriate indicators necessary to refer employees to a doctor or specialist. The expert should conduct initial plant EMT training and follow-up training.  The expert should provide an annual review of trends in the Protocol log and recommend changes in the protocol based on the trends.   4. Allow employees who report musculoskeletal pain or who are on work restrictions due to a musculoskeletal injury to be reassigned to tasks with no, little, or different ergonomic stressors.

Issued

Jun 15, 2015

Abate by

Apr 5, 2017

Penalty

Initial $5,000 · Current $1,500 Reduced

General-duty citation text

29 CFR 1910.37(b)(4): Signs were not posted along the exit access indicating the direction of travel to the nearest exit and exit discharge when the direction of travel to the exit or exit discharge was not immediately apparent:    a) Allen Harim Harbeson Plant, Harbeson, DE, Deboning I - On or about 5/21/15, the employer did not post signs indicating the direction of travel to the nearest exit and exit discharge where exit routes were not apparent and exit signs were not visible.          Note: Pursuant to 29 CFR 1903.19, the employer must submit abatement certification, required within 10 days after abatement date.  The certification shall include a statement that abatement is complete, date and method of abatement, and states employees and their representatives were informed of this abatement.

Issued

Jun 15, 2015

Abate by

Apr 5, 2017

Penalty

Initial $5,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.37(b)(6): Each exit sign was not illuminated to a surface value of at least five foot-candles (54 lux) by a reliable light source and be distinctive in color:    a) Hallway Exit sign between Receiving Area and Killing area - On or about 12/17/14, the employer failed to ensure the exit sign was illuminated by a reliable light source.       b) Exit sign in scalder room - On or about 12/17/14, the employer failed to ensure the exit sign was illuminated by a reliable light source.      c) Exit sign adjacent to Debone I - On or about 5/21/15, the employer failed to ensure the exit sign was illuminated by a reliable light source.          Note:  Note: Pursuant to 29 CFR 1903.19, the employer must submit abatement certification, required within 10 days after abatement date.  The certification shall include a statement that abatement is complete, date and method of abatement, and states employees and their representatives were informed of this abatement.

Issued

Jun 15, 2015

Abate by

Apr 5, 2017

Penalty

Initial $5,000 · Current $1,500 Reduced

General-duty citation text

29 CFR 1910.147(c)(6)(ii): The periodic inspection certification of energy control procedures did not contain the required documentation on identification of the machine or equipment, inspection date, employees included, and the person performing the inspection.    a) Harbeson Plant, Maintenance Department - On or about 5/7/15, the employer failed to ensure periodic inspection certification of energy control procedures.  The energy control book did not contain required documentation of inspection date, employees included and the person performing the inspection for the skinner machine and other equipment.      Note:  Pursuant to 29 CFR 1903.19, the employer must submit abatement certification, required within 10 days after abatement date.  The certification shall include a statement that abatement is complete, date and method of abatement, and states employees and their representatives were informed of this abatement.

Issued

Jun 15, 2015

Abate by

Apr 5, 2017

Penalty

Initial $3,000 · Current $3,000

General-duty citation text

29 CFR 1904.32(a)(1): Review the OSHA 300 Log to verify that the entries are complete and accurate, and correct any deficiencies identified;    a) Allen Harim Harbeson Plant, Harbeson, DE- On or about December 17, 2014, the employer failed to verify that the OSHA 300 log entries for the year 2014 were complete, accurate, and failed to correct any deficiencies identified.      Note: Pursuant to 29 CFR 1903.19, the employer must submit abatement certification, required within 10 days after abatement date.  The certification shall include a statement that abatement is complete, date and method of abatement, and states employees and their representatives were informed of this abatement.

Issued

Jun 15, 2015

Abate by

Apr 5, 2017

Penalty

Initial $3,000 · Current $0 Reduced

General-duty citation text

29 CFR 1904.32(b)(3): The employer did not certify an OSHA 300A Form or equivalent.     a) Allen Harim Harbeson Plant, Harbeson, DE- On or about 4/22/2015, the employer failed to certify the annual summary of work-related injuries and illnesses, OSHA 300A Form or equivalent, recorded in the OSHA 300 logs for the year 2014.    Note: Pursuant to 29 CFR 1903.19, the employer must submit abatement certification, required within 10 days after abatement date.  The certification shall include a statement that abatement is complete, date and method of abatement, and states employees and their representatives were informed of this abatement.