OSHA Instruction CPL 2.88 JULY 2, 1990 Directorate Of Technical Support

Subject: Information Dissemination System for Ergonomic Inspections and Consultative Visits Resulting in Significant Benefits

A. Purpose. This instruction establishes procedures for collecting and disseminating information relative to ergonomic inspections and ergonomic consultative visits which have resulted in significant benefits to employers and their employees.

B. Scope. This instruction applies OSHA-wide.

C. Action. Regional Administrators shall ensure that the policy and procedures established in this instruction are adhered to for all ergonomic inspections and visits.

D. Federal Program Change. This instruction describes a Federal program change which affects State Programs. Each Regional Administrator shall:

1. Ensure that this instruction is promptly forwarded to each State designee, using the two-way memorandum.

2. Explain the content of this instruction to the State designee as requested.

3. Notify the State designees that they are encouraged but not required to participate in this program.

4. Ensure that State designees are asked to acknowledge receipt of this Federal program change in writing to the Regional Administrator as soon as the State's intention is known, but not later than 70 calendar days after the date of issuance (10 days for mailing and 60 days for response). This acknowledgment must include the State's intention to participate in the information dissemination system for ergonomic inspections and

OSHA Instruction CPL 2.88 JULY 2, 1990 Directorate of Technical Support

consultative visits resulting in significant benefits to employers and their employees.

5. Inform the State designees choosing to participate that they should coordinate procedures for submitting information to the Regional Administrators.

6. Inform the State designees that this Federal program change does not require a plan supplement.

E. Background. OSHA has initiated a program for certain ergonomic hazards. Valuable data relative to hazard identification and control are collected and placed in the case files including ergonomic solutions for specific operations. This potentially valuable information is rarely shared with employers, employees, and other interested groups. This instruction is intended to provide the mechanism for the collection and dissemination of ergonomic solutions within OSHA and to interested parties and organizations outside of OSHA.

F. Procedures. Each Regional Administrator shall be responsible for the development of brief, written summaries for selected ergonomic cases and ergonomic consultative visits and for their transmission to the Directorate of Technical Support at the National Office. All information WHICH IS A TRADE SECRET OR OTHERWISE CONFIDENTIAL must be removed from the summary report. Specific guidelines to be followed are set forth below:

1. Area Offices and Consultation Project Offices. Area Directors and Consultation Project Managers shall be adequately briefed on the goals of the project.

a. After an ergonomic inspection or visit has been completed, the Area Director or Consultation

OSHA Instruction CPL 2.88 JULY 2, 1990 Directorate of Technical Support

Project Manager, shall be responsible for writing a summary of the noteworthy investigations. The summary shall include the following elements:

(1) A short paragraph analyzing the hazard(s) identified, giving the apparent cause and related factors contributing to the existence of the hazard(s). Identify the related occupational health problem such as cumulative trauma disorder, hand-arm vibration exposure and lower back injury. Where appropriate, rough sketches, photographs, with explanatory detail, and/or reference to video tapes taken are encouraged;

(2) A short paragraph describing the corrective action(s) implemented by the employer. The description should include changes made in work station design, tools, material handling equipment, environment, personal protective equipment and employee retraining and job rotation. Where appropriate, provide sketches, photographs and/or videotape of the workplace after the corrective action was taken;

(3) A brief summary of significant benefits realized. Examples of such benefits are cost savings, the identification and successful solution to a unique ergonomic hazard, increased awareness of workplace safety and health, and injuries prevented or reduced by the recommended abatement methods. An estimate of cost savings should be determined based on reduced workers' compensation costs, medical services, time lost from work, and increased production, if appropriate; and

OSHA Instruction CPL 2.88 JULY 2, 1990 Directorate of Technical Support

(4) The number of employees who may possibly be benefited from the abatement method(s).

b. The summary shall not be forwarded to the Regional Office until the case has been closed.

2. Regional Offices. Although Area Directors and Consultation Project Managers are responsible for writing the first draft of the summary, the Regional Administrator shall ensure that the summary sent to the National Office meets the project goals.

a. Regional Administrators shall screen the summaries received from the Area Offices and select those to be forwarded to the Director, Directorate of Technical Support for possible publication.

b. At least one summary should be forwarded by each Regional Administrator semi-annually. Those judged to have the widest interest and greatest impact on preventing injuries should be given highest preference in the selection process.

c. Regional Administrators shall begin sending summaries to the Director, Directorate of Technical Support no later than the last day of the first quarter following the publication of this instruction.

d. The Regional Administrator shall transmit the selected summaries within 20 days of receipt from the Area Offices and Consultation Project Offices.

OSHA Instruction CPL 2.88 JULY 2, 1990 Directorate of Technical Support

3. National Office. The Directorate of Technical Support shall review and evaluate the summaries received from the Regions. The summaries to be published shall then be selected and forwarded to the Director, Office of Information and Consumer Affairs (OICA).

a. The Director, Directorate of Technical Support will collect, organize, and maintain a file of all summaries submitted. This file will be made available to the Director, OICA, and to other OSHA offices.

b. A minimum of one summary will be published and distributed (using an existing mailing list) bimonthly by the OICA.

4. A format for the summary page is attached to this instruction. Appendix A is a sample copy of an ERGOFACTS for your information.

5. Recipients of the summaries may use them in any way they choose. They are not copyrighted, and permission is not required to reproduce them. Users are requested, however, to credit OSHA, U.S. Department of Labor.

Gerard F. Scannell Assistant Secretary

Distribution: National and Regional Offices State Designees 7(c)(1) Project Managers All Compliance Officers

OSHA Instruction CPL 2.88 JULY 2, 1990 Directorate of Technical Support

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

PROJECT RECORD

Document type:

7 (c)(1) consultation visit file 18(b) State case file

Type of Business: (SIC)

Size: (# of employees) Operation and Hazard Description:

Control Method(s):

Summary of Significant Benefits:

ERGOFACTS U.S. DEPARTMENT OF LABOR OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

Meatpackers "Pulling the Paddle Bone" Create Undue Ergonomic Stress

The Problem

Several recognized ergonomic risk factors (stressors) -- repetitive motions, awkward postures, and forceful exertions -- were present in one operation present in beef packing houses.

This operation involves pulling the paddle bone (part of the scapula) away from the shoulder or chuck of the animal. Several workers complained of substantial pain; thus, a video tape analysis was performed on this job. As the meat is conveyed past the workers, they hook the meat and pull it to themselves, and do minor fat trimming. They then scribe or cut around the paddle bone to separate it as much as possible from the meat. These cuts require both pushing and pulling the knife with the blade extending from the little finger side of the hand. The workers then literally rip the meat from the bone by hooking it first with the left and then the right hand. They use their forearm to brace against the meat and continue to tear at the meat with the other hand. They then grasp the neck of the bone with one hand and pull with great force while pounding the hook into the gap between the meat and bone.

After more cuts are made to separate the bone completely the bone is discarded to a conveyor. The entire operation requires about thirty seconds to complete. The workers at these positions experienced low back pain, pain in both shoulders, and severe pain in both hands. The tasks exposed workers to ergonomic stressors that caused cumulative trauma disorders. These included repeated deviations of the wrists, shoulders, and back. High pushing and pulling forces at the hand and elbow and repeated pounding of the palm area of the hook hand were also significant stress contributors.

The Solution

The task was modified by changing it into two jobs. As the meat is conveyed by the work stations the first worker scribes the bone as before but does not attempt to separate the bone from the meat. A second worker places a circular hook over the neck of the bone and this hook is chained to the floor. As the conveyor and attached meat continues to move, the slack in the chain is taken up and the bone is pulled away from the meat mechanically. The bone is then removed from the hook and placed on another conveyor.

The Benefits

The workers on these jobs are no longer exposed to the excessive ergonomic stress previously present. The manning for the job remains essentially the same as several workers were performing the task; however, they are now free to rotate between the jobs to provide some variety and reduce their exposure to any remaining force and repetition stressors. The costs were less than $300 per work station for materials and installation. The workers all felt that the changes made their job much less demanding and at no loss of output.

ErgoFacts provides a brief summary of the results of an employer's recognition of the need for workplace safety and health assistance. In some instances these situations were recognized by enforcement officials during an inspection. Such assistance can identify and help the employer correct workplace hazards, develop or improve on effective safety and health management system, or both. Contact the OSHA office in your area for additional information on the consultation program.