OSHA Inspection: MERILLAT INDUSTRIES, INC.

Issued

May 30, 1990

Abate by

Mar 31, 1993

Penalty

Initial $420 · Current $210 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 death
or serious physical harm to employees in that employees were exposed to:
(A) EXCESSIVE ERGONOMIC STRESS CAUSED BY REPETITIVE MOTIONS OF THE HANDS
ARMS, AND WRIST WHICH ARE RESULTING IN DISABLING CUMULATIVE TRAUMA
DISORDERS TO A SIGNIFICANT NUMBER OF INDIVIDUALS PERFORMING ASSEMBLY
OPERATIONS ON THE BASE, WALL, SPECIALS AND FRAMELESS LINES. CASES OF
CARPEL TUNNEL SYNDROME, TENOSYNOVITIS, TENDONITIS AND OTHER STRAINS
OF THE HANDS, WRISTS, ARMS, AND SHOULDERS WERE RECORDED ON THE OSHA
FORM 200. THERE ARE FEASIBLE ENGINEERING, ADMINISTRATIVE, AND MEDICAL
APPROACHES TO PREVENT OCCURRENCES OF CUMULATIVE TRAUMA DISORDERS.
AMONG OTHER METHODS, A FEASIBLE AND ACCEPTABLE ABATEMENT PROGRAM TO
REDUCE CUMULATIVE TRAUMA DISORDERS WOULD INCLUDE THE FOLLOWING:
1) IN ALL AFFECTED DEPARTMENTS:
a) EDUCATION AND TRAINING OF EMPLOYEES IN THE RECOGNITION OF ERGONOMIC
STRESSORS PRESENT IN THEIR JOBS, TRAINING IN THE SYMPTOM RECOGNITION
OF CUMULATIVE TRAUMA DISORDERS, AND TRAINING IN THE POSTURES,
STRETCHES, WORKSTATION ADJUSTMENTS AND WORK PRACTICES THAT ARE KNOWN
TO REDUCE THE INCIDENCE OF CUMULATIVE TRAUMA DISORDERS.
b) EDUCATION AND TRAINING FOR SUPERVISORS IN THE ABOVE, SUPERVISOR
RESPONSIBILITY TO NOTE AND CORRECT POOR WORK PRACTICES.
c) ROTATION OF WORKERS AMONG JOBS THAT REQUIRE THE USE OF DIFFERENT
MUSCLE GROUPS AND ARE NOT THEMSELVES THE CAUSE OF REPETITIVE MOTION
INJURIES.
d) ALLOW NEW OR REASSIGNED EMPLOYEES TO CONDITION THEIR MUSCLE/TENDON
GROUPS PRIOR TO WORKING AT FULL CAPACITY.
e) SET UP A MEDICAL MANAGEMENT PROGRAM TO MONITOR EMPLOYEES AND PREVENT
EARLY SYMPTOMS FROM PROGRESSING TO INJURIES. THIS PROGRAM SHALL
INCLUDE: ENCOURAGING EARLY REPORTING OF INJURIES AND DISORDERS,
INSTITUTING A FORMAL, DOCUMENTED TRACKING AND SURVEILLANCE PROGRAM TO
MONITOR INJURY TRENDS IN THE PLANT, PROVIDING ADEQUATE TREATMENT OF
ERGONOMIC-RELATED CASES, INCLUDING NOT REASSIGNING EMPLOYEES TO A JOB
UNTIL IT HAS BEEN MODIFIED TO MINIMIZE THE HAZARDS THAT RESULTED IN
THE INJURY, ALLOWING ADEQUATE TIME OFF FOR HEALING AFTER SURGERY OR
OTHER INTERVENTION AND UTILIZING PHYSICAL THERAPISTS AND/OR
MYOTHERAPISTS TO DEVELOP AND IMPLEMENT CONSERVATIVE TREATMENT
MEASURES AND DETECTION OF EARLY SYMPTOMS.
f) HIRING OF A PROPERLY TRAINED ERGONOMIC CONSULTANT TO: REVIEW OSHA
AND OTHER RECOMMENDATIONS MADE, PERFORM A SYSTEMATIC EVALUATION WITH
REGARD TO EXISTING AND NEW WORK PRACTICES AND, WORKSTATION DESIGN FOR
ALL OPERATIONS WITH CUMULATIVE TRAUMA DISORDER HAZARDS, RECOMMEND
ENGINEERING AND ADMINISTRATIVE CONTROLS, ERGONOMICALLY ASSESS NEW
EQUIPMENT OR WORKSTATION LAYOUT IN THE PLANNING STAGES BEFORE
EXPOSING EMPLOYEES TO POTENTIAL CUMULATIVE TRAUMA STRESSORS.
g) SET UP AN ERGONOMIC TEAM CONSISTING OF MEMBERS FROM MANAGEMENT,
ENGINEERING, SAFETY, MEDICAL AND EMPLOYEES TO: EVALUATE HEALTH DATA,
DETERMINE JOB ANALYSIS PRIORITIES, AND INTERVENTION STRATEGIES, AND
EVALUATE AND MODIFY INTERVENTION STRATEGIES.
FEASIBLE AND ACCEPTABLE ABATEMENT METHODS FOR SPECIFIC ERGONOMIC HAZARDS
NOTED IN THE ASSEMBLY AREAS MIGHT INCLUDE BUT ARE NOT LIMITED TO THE
FOLLOWING:
2) IN BASELINE ASSEMBLY: CLAMPING OPERATIONS
a) REDESIGN GLUE GUN TO ALLOW USER TO MAINTAIN A NEUTRAL WRIST POSITION
AND EDUCATE OPERATORS ON THE IMPORTANCE OF MAINTAINING A NEUTRAL
WRIST WHILE PERFORMING REPETITIVE MOTIONS.
b) REDESIGN NAILGUN INCORPORATING A POWER GRIP TO ALLOW THE USE TO
MAINTAIN A NEUTRAL WRIST.
c) REALIGN STORAGE AREAS FOR FEED STOCK SO IT REACHES ABOVE SHOULDER
HEIGHT OR BENDING OVER IS NOT NECESSARY.
d) REALIGN WORK SURFACE TO ALLOW FOR NEUTRAL WRIST WHILE PERFORMING
JOB TASKS.
e) EDUCATE WORKERS IN PROPER LIFTING TECHNIQUES.
f) PROVIDE RUBBER MALLETS FOR EMPLOYEES TO USE WHEN FORCE IS REQUIRED
FOR FITTING COMPONENTS, DISCOURAGE EMPLOYEES FROM USING HANDS AS
POUNDING INSTRUMENTS.
g) REALIGN WORK SURFACES FOR EASIER ACCESS WITHOUT EXCESSIVE REACHES.
h) HAVE EMPLOYEES ONLY DO THEIR HALF OF THE CABINET TO ELIMINATE
EXCESSIVE REACHES.
i) EVALUATE THE FEASIBILITY OF RAISING THE WORK STATION FOR EARLY STAGES
OF CABINET CONSTRUCTION AND LOWERING IT FOR THE FINAL STAGES.
3) IN BASELINE DEPARTMENT, SUB ASSEMBLY
a) EDUCATE THE WORKERS ON THE IMPORTANCE OF MAINTAINING A NEUTRAL WRIST
WHILE PERFORMING REPETITIVE MOTIONS.
b) REPOSITION WORKER IN FRONT OF CABINETS FOR TASKS DONE WITHIN THE
CABINET TO REDUCE BENDING OVER AT THE WAIST TO INSTALL HARDWARE.
c) HAVE DRAWERS COME IN ON A CONVEYOR AT WAIST HEIGHT TO MINIMIZE
BENDING.
d) USE TWO-MAN TEAMS TO INSTALL DOORS, HAVE ONE HOLD THE DOOR IN
POSITION WHILE THE OTHER SECURES THE DOOR IN PLACE.
e) STACK DRAWERS ON PALLETS THAT COULD BE PLACED ON LIFTING TABLES TO
PREVENT BENDING.
f) DESIGN A CLAMP ON HINGE SO THE DOOR DOES NOT NEED TO BE HELD WHILE
THE SCREWS ARE SECURED.
g) PROVIDE A SIDE BAR FOR SCREW GUNS SO BOTH HANDS CAN BE USED DURING
THE OPERATION.
h) PROVIDE MOVABLE PLATFORMS TO BRING EMPLOYEES UP TO A LEVEL THEY CAN
PERFORM THE JOB IN AN ERGONOMICALLY SAFE MANNER.
i) EDUCATE THE OPERATORS ON THE IMPORTANCE OF MAINTAINING A NEUTRAL
WRIST WHILE PERFORMING REPETITIVE MOTIONS.
4) IN WALL DEPARTMENT: CLAMPING OPERATIONS
a) SAME PROBLEMS AND RECOMMENDATIONS AS SEEN IN CLAMPING OPERATIONS IN
BASE LINE DEPARTMENT.
5) IN WALL DEPARTMENT: ASSEMBLY
a) SUSPEND SCREWGUN FROM AN ASSIST SLING TO REDUCE FORCE REQUIRED TO
LIFT GUN.
b) REMOVE BOXES FROM UNDER CONVEYOR TO ALLOW EMPLOYEES TO GAIN BETTER
ACCESS TO WORK AREA.
6) IN SPECIALS DEPARTMENT: CLAMPING OPERATIONS.
a) REPOSITION EQUIPMENT TO ALLOW ACCESS TO ALL SIDES OF THE CABINET
WITHOUT THE NEED FOR EXTREME REACHES.
b) PROVIDE STOOLS OR PLATFORMS TO ALLOW THE WORKER TO ELEVATE THEMSELVES
AND GAIN BETTER ACCESS TO THE WORK STATION, TILT WORKPIECE OR OTHER
REDESIGN.
7) IN BASE DEPARTMENT, SPECIALS: CLAMP OPERATOR.
a) EDUCATE THE WORKERS IN THE IMPORTANCE OF MAINTAINING A NEUTRAL WRIST
POSITION WHILE PERFORMING REPETITIVE MOTIONS.
b) REPOSITION WORK AS TO ELIMINATE THE NEED FOR EXTENDED REACHES.
c) HAVE EACH MEMBER OF THE TEAM DO THE NAILING ON THEIR SIDE OF THE
CABINET.
d) REDESIGN THE NAILGUN TO INCORPORATE A POWERGRIP.
e) SUSPEND NAILGUN ON SLING TO REMOVE STRESS FROM THE OPERATOR SUPPORT
OF TOOL.
f) PROVIDE STEPS SO EMPLOYEE CAN GAIN ELEVATION IN RELATION TO WORK
SURFACE.
8) IN BASE DEPARTMENT: LAZY SUSAN CLAMPING OPERATORS
a) REPOSITION WORK TO GAIN BETTER ACCESS TO PREVENT NEED TO MAKE
EXTENDED REACHES WITH WRIST DEVIATIONS.
b) REDESIGN CLAMP AND OTHER TABLE TO ALLOW TILTING OR ROTATION FOR
EASIER ACCESS.
c) EDUCATE THE OPERATORS ON THE IMPORTANCE OF MAINTAINING A NEUTRAL
WRIST WHILE PERFORMING REPETITIVE MOTIONS, EXPECIALLY DURING GLUING
TASKS WHICH SEEM TO HAVE EXCESSIVE INWARD/OUTWARD ROTATION OF
FOREARMS.
9) IN FRAMELESS DEPARTMENT: PREASSEMBLY
a) REPOSITION WORK TO GAIN BETTER ACCESS TO PREVENT NEED TO MAKE
EXTENDED REACHES WITH WRIST DEVIATIONS.
b) PROVIDE MALLETS TO SEAT MATERIALS INTO THEIR PROPER POSITIONS AND
DISCOURAGE THE USE OF HANDS AS POUNDING INSTRUMENTS.
10)IN FRAMELESS DEPARTMENT: CLAMP OPERATOR
a) REPOSITION WORK FOR BETTER ACCESS BY WORKER, POSSIBLY BY PROVIDING
A ROTATING TABLE TO ELIMINATE EXTENDED REACHES WITH RAISED AND
ABDUCTED ELBOWS AND FLEXED WRISTS.
b) DEVELOP A NAILGUN THAT UTILIZES A POWER GRIP.
c) EDUCATE THE EMPLOYEES ON THE IMPORTANCE OF MAINTAINING A NEUTRAL
WRIST WHILE PERFORMING REPETITIVE MOTIONS, ESPECIALLY DURING GLUING
OPERATIONS.
d) PROVIDE A GLUE GUN WITH A POWER GRIP.
11)IN FRAMELESS DEPARTMENT: DRAWER RAIL INTALLATION.
a) PLACE BINS OF MATERIALS UNDER WORK BENT OR OTHER REDESIGN TO
MINIMIZE REACH.
b) PUT MATERIALS ON TURNTABLE SWIVEL SO WORK ITEM CAN BE EASILY ROTATED
TO THE WORKER.
c) PROVIDE A COLLAR FOR THE HANDLE OF THE SCREWDRIVER SO THE WORKER CAN
USE THE FLESHY PART OF THE HAND TO PUSH TOOL.
12)IN FRAMELESS DEPARTMENT: CLIP INSERTION.
a) BRING RAW MATERIALS IN AT HIGHER LEVELS BY PROVIDING LIFT TABLE AND
RAISE THE CONVEYOR TO ELIMINATE EXCESSIVE BENDING AT THE WAIST.
13)IN FRAMELESS DEPARTMENT: SMALL WALL UNIT ASSEMBLY.
a) BRING RAW MATERIALS IN AT HIGHER LEVELS BY PROVIDING LIFT TABLE AND
RAISE THE CONVEYOR TO ELIMINATE EXCESSIVE BENDING AT THE WAIST.
b) PROVIDE A BENCH OR TABLE FOR ASSEMBLY NEARER TO CONVEYOR TO ELIMINATE
THE CARRY.
14)IN SPECIALS DEPARTMENT: WALL CORNER CLAMP OPERATION
a) REALIGN WORK FOR BETTER ACCESS BY WORKER BY PROVIDING TILTING OR
ROTATING TABLE OR OTHER REDESIGN.
b) EDUCATE THE WORKER ON THE IMPORTANCE OF MAINTAINING A NEUTRAL WRIST
WHILE PERFORMING REPETITIVE MOTIONS.
c) DEVELOP A NAILGUN THAT UTILIZES A POWER GRIP.
d) REORIENTATE WORK FOR BETTER ACCESS BY WORKER.
e) PROVIDE STEPS OR PLATFORMS TO ELEVATE WORKER IN RELATION TO WORK.

Issued

May 3, 1990

Abate by

Jun 7, 1990

Penalty

Initial $360

Issued

May 3, 1990

Abate by

May 6, 1990

Penalty

Initial $420 · Current $420

Issued

May 3, 1990

Abate by

Jun 27, 1990

Penalty

Initial $420 · Current $420

Hazardous substances 8111

Issued

May 3, 1990

Abate by

Jun 17, 1990

Penalty

Initial $420 · Current $420

Hazardous substances 8111

Issued

May 3, 1990

Abate by

May 15, 1990