OSHA issues PSM Citations @ Food Plant (NH3 & $8K)

On Dec. 2, 2016, OSHA issued citations to a poultry processing facility for five serious safety violations, including one issued as a violation of the OSH Act’s general duty clause. Two hazard alert letters were issued on Dec. 2, 2016. OSHA’s inspection began on June 3, 2016, after the employer reported that a worker suffered a finger amputation while operating a packaging machine. Inspectors found serious violations associated with electrical and process safety management hazards, and deficiencies with the procedures meant to prevent accidental machine start-up or movement, known as lockout/tagout, which contributed to the amputation. They also found that workers were exposed to musculoskeletal stressors as they performed tasks requiring repetitive, forceful motion for extended periods of time, and often in awkward positions.  The agency issued one hazard alert letter for medical management practices in place at the facility that prevent appropriate standards of care, increase the likelihood of workers developing serious musculoskeletal disorders, restrict referrals to physicians, and discourage employees from reporting symptoms and injuries.

The other hazard alert letter warned about the company’s storage of incompatible chemicals.

Citation 1 Item 1

Type of Violation: Serious; $12,471

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 Debone DS and NS: On or about June 3, 2016 and at times prior and since, employees performed 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 Cutter, Wing Cutter, Breast Puller, Breast Trimmer, Tenders Scorer, Tenders Trimmer, and Tenders Puller. b) Cone Debone DS and NS: On or about June 3, 2016 and at times prior and since, employees on the cone debone line perform tasks that require torso twisting and manually handling chickens onto the cone line conveyor 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.

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. Load cone, shoulder cut, wing cut, breast pull, breast trim, tender score, tender trim, tender pull – Adjustable height platforms should be individual stands, adjustable to the appropriate height for the employee, have a foot rail to alleviate the stress of standing. Adjust the stands in between rotations to ensure that employees are working with minimal stressors caused by awkward shoulder and hand 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. Shoulder cut, tender score – Provide knives with ergonomic handles designed for repetitive tasks to reduce awkward hand postures. Increase knife sharpening frequency on and off the lines to reduce force requirements to less than 10% of maximum grip strength. Position the on-line sharpener to reduce reaching and minimize non-neutral shoulder and hand postures.
3. Wing cut – Evaluate the knives and handle orientation and provide the most appropriate tool to employees.
4. Breast trim, tender trim – Provide scissors with small, medium and large handles. Handles should be contoured and soft to avoid contact stress with the finger. Replace scissors when dull or at least every 4 hours.
5. 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 can’t 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.
6. 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 torso twisting and 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. Breast Pull – Reduce the force to pull the breast from the bone by getting more complete shoulder cuts and not allowing the meat to get too cold.
2. 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) since 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.
3. 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 multidisciplinary, 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 should 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. Injuries that do not have adequate time to recover take more time to heal or become more serious injuries. Employees must understand the importance of early reporting of musculoskeletal disorders and must receive treatment that is consistent with accepted practices in occupational medicine.
5. 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. 

Citation 1 Item 2

Type of Violation: Serious; $5,881

29 CFR 1910.303(b)(7)(iv): There were damaged parts that could adversely affect safe operation or mechanical strength of the equipment, such as parts that were broken, bent, cut, or deteriorated by corrosion, chemical action, or overheating:

1. On or about August 31, 2016, the employer failed to replace or repair damaged parts which could adversely affect safe operation of the electrical equipment, in that the cover plate for an electrical 120-volt receptacle was not affixed to the metallic outlet box, exposing employees operating the powered foot control to electrical shock hazards.

Citation 1 Item 3

Type of Violation: Serious; $12,471

29 CFR 1910.147(c)(4)(i): Procedures were not developed, documented and utilized for the control of potentially hazardous energy when employees were engaged in activities covered by this section:

1. D/S Tray Pack Line #4 – On or about June 3, 2016, the employer failed to ensure that employees engaged in servicing and maintenance, to include but not limited to troubleshooting and inspection, of the OSSID machine utilized documented energy control procedures, exposing employees to moving machine parts and nip points.

PSM Citations

Citation 1 Item 1

Type of Violation: Serious; $7,839

29 CFR 1910.119(d)(3)(ii): The employer did not document that equipment complies with recognized and generally accepted good engineering practices (RAGAGEP):

1. Engine Room No. 2 – On or about June 30, 2016, the employer was not in compliance with RAGAGEP exposing employees to hazards posed by a potential ammonia release:
   1. Only one ammonia sensor was installed inside this room.
   2. Only one alarm the annunciated visually was installed inside this room. No other alarms were installed outside an entrance to this room.
   3. The automatic exhaust system was impeded as inoperable manual intake louvers, rather than louvers with dampers of a fail-open power-closed type, were used.

Pursuant to 29 CFR 1903.19, the employer must submit abatement certification, required within 1O 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. Provide listed electrical equipment for these rooms or provide documentation of compliance with the referenced ANSl/ASHRAE Standard as abatement. Follow ASHRA 15 and the International Institute of Ammonia Refrigeration (IIAR) Bulletin No. 111 for guidance on the installation of ammonia sensors & alarms, and ventilation intake louvers.

Note: The American National Standards Institute I American Society of Heating, Refrigeration and Air-Conditioning Engineers Standard (ANSl/ASHRAE Standard 15-2013, Safety Standard for Refrigeration Systems) precludes ammonia machine rooms from being classified as Class 1, Division 2 locations if the provisions contained in section 8.12(h) of the same Standard are not met.

Citation 2 Item 1

Type of Violation: Other-than-Serious; $1,100

29 CFR 1910.132(h)(1): Except as provided by paragraphs (h)(2) through (h)(6) of this section, the protective equipment, including personal protective equipment (PPE), used to comply with this part, was not provided by the employer at no cost to employees:

1. On or about August 31, 2016, the employer was not providing PPE, such as equipment for hearing protection, hand protection, and eye protection, at no cost to employees.

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