OSHA Inspection: PARIS ACCESSORIES, INC.

Issued

Jan 15, 1988

Abate by

Jan 15, 1989

Penalty

Initial $560 · Current $560

Hazardous substances 8880

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 exposed to
repetitive strain injuries from repeated motion of the hands, wrists and
arms. These exertions caused, aggravated or precipitated repetitive
motion disorders, including carpal tunnel syndrome and tendonitis, among
employees engaged in the following operations:
a) Pickers (Line Pullers) working in the MSC Department on or about
8/19/87.
b) Trimmers working in the Armenti Department, on or about 8/19/87.
Among other methods, one feasible and acceptable abatement method to
correct this hazard is the implementation of a comprehensive repetitive
strain injury prevention program. This program should include at a
minimum, the following elements:
d) Continue with your present plans to provide scheduled employee break
periods at greater frequency than the current two (2) - ten (10)
minute breaks per day.
e) Reevaluate existing work allowances and production standards with
consideration of the economics of potential compensation costs for
repetitive strain injuires at these high risk operations.
4) Implementation of control measures for reducing biomechanical forces.
The following specific methods should be considered at the cited
operations:
a) Minimize "pinch grips" used by MSC pickers by having them employ a
grip which utilizes the first two fingers- not the thumb.
b) Continue to utilize the spring loaded handkerchief folding aids that
were recently installed at the pickers' work tables.
c) Utilize spring loading trimming scissors with plastic handles
ergonomically designed to spread forces over the entire surface of
the scissors grip.
d) Install foot rails at the pickers' work stations to reduce low back
stress while these employees perform their work tasks in a standing
position.
5) Implementation of control measures to increase adjustability of
position into the job and reduce awkward postures. The following
specific method should be considered at the cited operations:
a) Provide adjustable chairs which allow for chair height adjustments
every 15 to 30 minutes as a means of changing stresses on the arms
and minimizing forward leaning of the employees. Sit/stand options
should also be encouraged at the picking operation.
6) Training sessions to familiarize workers with and appreciate the
types of movements and postures which precipitate cumulative trauma
disorders.
7) Implementation of a workplace education and awareness program aimed
at the maintenance of musculoskeletal health and prevention of
injuries. Specific efforts should be expended in identifying and
reducing obstacles that prevent or deter a worker with symptoms from
reporting them.
8) Implementation of a medical surveillance and treatment program for
employees exposed to repetitive motion hazards. This program should
contain the following elements and be readily accessible to all
employees working at high risk jobs:
a) Pre-employment examinations with special attention to medial nerve
distribution, muscular aberrations and wrist flexability; including
both strength and stamina testing along with a review of employee
work histories relative to repetitive truama disorders.
(Note: To minimize abuse of such placement procedures, it is necessary
to identify the high-risk jobs and quantify the required job-demands.
Workers should be matched to jobs as a function of the specific job
demands and worker capacities.)
b) Medical examinations and counseling of employees as soon as symptoms
generally associated with repetitive trauma disorders are reported.
Detailed examinations of each employees' specific work history should
be performed, and medical treatment, including ice therapy, anti-
inflamatory medications and exercise therapy, should be considered
where appropriate. Employees should be alerted to the minimal
effectiveness of surgical interventions, especially when returning
to a job with high risk factors.
c) Employees should be prohibited to return to their former jobs
following surgery until the work environment has been modified to
the extent that the risk of recurrent injury has been minimized.
d) Follow-up of mild cases of impairment to ensure that medical
treatment and job changes have been effective.
ABATEMENT NOTE:
STEP 1 - Effective administrative protection, such as employee education
and training, medical surveillance and treatment, job rotation,
etc., shall be provided as an interim protective measure until
feasible engineering or permanent administrative controls can
be implemented which will reduce employee exposure to nominal
risk.
STEP 2 - Submit to the Area Director a written, detailed plan of
abatement outlining a schedule for the implementation of
engineering or administrative measures to control employee
injury due to repetitive motion tasks. This plan shall include
at a minimum, target dates for the following actions which must
be consistent with the dates required by this citation.
1) Ergonomic evaluation of the repetitive motion tasks that employees
are performing at the cited operations
2) Evaluation of applicable control measure(s).
3) Procurement, installation and operation of selected control measures.
4) Monitoring to assure effective utilization of the control measure(s).
Ninety (90) day progress reports are required during the abatement
period.
STEP 3 - Abatement shall have been completed by implementation of
feasible engineering or administrative controls, upon
verification of their effectiveness in reducing the
occurrence of repetitive strain injuries.

Issued

Jan 15, 1988

Abate by

Jan 18, 1988

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Jan 25, 1988

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Jan 25, 1988

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Jan 20, 1988

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Apr 16, 1988

Issued

Jan 15, 1988

Abate by

Apr 16, 1988

Issued

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Abate by

Apr 16, 1988