At its facility, Respondent converts paper products into finished products such as rolls of toilet paper and paper towels. The paper products are run through machinery operated by Respondent’s employees. One of these machines is the R74 Line Rewinder (Rewinder) machine. The Rewinder transforms a 10-foot by 10-foot giant roll of toilet paper into the smaller more commonly sized roll of toilet paper. The Rewinder will take paper from the 10-foot roll, sometimes combine plies of paper, sometimes emboss the paper, and then wrap the finished paper onto the commonly sized cardboard roll, apply glue, and cut the paper to finish the product. Every now and then, the material within the Rewinder tears and/or jams. Respondent’s employee must clear the jam and/or rethread the paper within the Rewinder, which typically is a solitary task that takes six to seven minutes to do. To accomplish this task, the operator shuts down the Rewinder from inside the control panel (where he had been controlling the machine); he then leaves the control panel, enters the Rewinder itself through an interlock gate, leaving the gate door open, and manually unjams and/or rethreads the paper.
With the interlock gate door open, the employee is unable to operate the Rewinder except to “jog” or to “reset” it. “Jogging” the machine is “moving the Rewinder slowly, at a creep speed, and done to make sure the paper getting cut in the Rewinder is cut properly, to allow tape on the paper to come off, or pulling paper that is not long enough to meet the other paper.” The employee himself “jogs” the machine from inside the Rewinder and then finishes the rethreading task.
Once the unjamming and/or rethreading task is complete, the operator then must “reset” the Rewinder before restarting the Rewinder so that the machine runs properly. Unlike jogging, the “reset” function is performed on the outside of the Rewinder, inside the control panel, by pressing the “reset” button. To perform the “reset,” the employee has “to go to the settings, recycle it and home it.” The “reset” function was described as follows: