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II. PROGRAM ELEMENTS

An effective occupational safety and health program to address ergonomic hazards in the meatpacking industry includes the following four major program elements: worksite analysis, hazard prevention and control, medical management, and training and educa- tlon.

A. Worksite Analysis

Worksite analysis identifies existing hazards and conditions, operations that create hazards, and areas where hazards may develop. This also includes close scrutiny and tracking of injury and illness records to identify patterns of traumas or strains that may indi- cate the development of CTDs. (A recommended worksite analysis program for ergonomics is provided in Section 111. A.)

The objectives of worksite analysis, then, are to recognize identify, and correct ergonomic hazards.

1. The first step in implementing the analysis program should be a review and analysis of injury and illness records to accomplish the following:

a. Analyze medical, safety, and insurance records, including the OSHA-200 log and information compiled through the medical management program, for evidence of cumulative trauma disorders. This process should involve health care providers to ensure confi- dentiality of patient records.

b. Identify and analyze any apparent trends relating to particular departments, process units, job titles, operations, or work stations. (For a complete discus- sion, see Sections 111. A. and C.)

2. The worksite analysis should use a systematic method, such as the one provided in Section 111. A., to identify those work positions needing a quantitative analysis of ergonomic hazards. This analysis should do the following:

a. Use an ergonomic checklist that includes compo- nents such as posture, force, repetition, vibration, and various upper extremity factors. (See Section III. A.)

b. Identify those work positions that put workers at risk of developing CTDs.

c. Verify low risk factors for light duty or restricted activity work positions.

d. Determine if risk factors for a work position have been reduced or eliminated to the extent feasible.

e. Provide the results of such analyses to health care providers for use in assigning "light duty" jobs. (See Section III. C. for discussion of these types of jobs.)

f. Apply to all planned, new, and modified facilities, processes, materials, and equipment to ensure that workplace changes contribute to reducing or eliminat- ing ergonomic hazards.

3. The analysis of ergonomics hazards should be routinely performed and documented by a qualified person--ideally, an ergonomist; trained plant engi- neers, managers, health care providers, and affected employees should also contribute to the process.

4. Periodic surveys of the worksite should be conducted--at least annually, or whenever operations change--to identify new or previously unnoticed risk factors and deficiencies or failures in work practices or engineering controls, and to assess the effects of changes in the work processes.

Effective programs require a reliable system for employees to notify management about conditions that appear to be ergonomic hazards and to utilize their insight to determine appropriate work practice and engineering controls. This could be begun by a ques- tionnaire on ergonomic problems and issues and maintained through an active safety and health committee or other forms of regular employee partici- pation (e.g., a complaint log or suggestion book).

NOTE: After conducting a worksite analysis appro- priate for the size and conditions of the workplace, the employer may find that there are no significant ergo- nomic hazards or resulting CTDs in the establishment. If there are no hazards, the employer need not imple- ment the other program elements recommended by the guidelines. The employer should, however, continue current efforts to ensure workplace safety and health and should monitor changes in the workplace which might indicate ergonomic hazards.

B. Hazard Prevention and Control

Once ergonomic hazards are identified through the systematic worksite analysis discussed above. the next step is to design measures to prevent or control these hazards. Thus, a system for hazard prevention and control is the second major program element for an effective ergonomics program.

Ergonomic hazards are prevented primarily by effective design of the workstation, tools, and job. To be effective, an employer's program should use appro- priate engineering and work practice controls, personal protective equipment, and administrative controls to correct or control ergonomic hazards, including those identified in the following paragraphs:

1. Engineering Controls

Engineering techniques, where feasible, are the preferred method of control. The focus of an ergonom- ics program is to make the job fit the person, not to force the person to fit the job. This can be accom- plished by designing or modifying the work station, work methods, and tools to eliminate excessive exer- tion and awkward postures and to reduce repetitive motion.

a. Work Station Design. Work stations should be designed to accommodate the persons who actually work on a given job; it is not adequate to design for the "average" or typical worker.

Work stations should be easily adjustable and either designed or selected to fit a specific task, so they are comfortable for the workers using them.

The work space should be large enough to allow for the full range of required movements. especially where knives, saws, hooks, and similar tools are used.

b. Design of Work Methods. Work methods should be designed to reduce static, extreme, and awkward postures; repetitive motion, and excessive force. Work method design addresses the content of tasks performed by the workers. It requires analysis of the production system to design or modify tasks to elimi- nate stressors.

c. Tool and Handle Design. Tools and handles, if well-designed, reduce the risk of CTDs.

For any tool, a variety of sizes should be available to achieve a proper fit and reduce ergonomic risk. The appropriate tool should be used to do a specific job. Tools and handles should be selected to eliminate or minimize the following stressors:

* Chronic muscle contraction or steady force.

* Extreme or awkward finger/hand/arm positions.

* Repetitive forceful motions.

* Tool vibration.

* Excessive gripping, pinching, pressing with the hand and fingers.

For examples of engineering controls achievable in the meat industry to eliminate extreme and awkward postures and excessive force and to reduce repetitive motion in the meat industry, see Section III. B.

2. Work Practice Controls

An effective program for hazard prevention and control also includes procedures for safe and proper work that are understood and followed by managers, supervisors, and workers. Key elements of a good work practice program for ergonomics include proper work techniques, employee conditioning, regular moni- toring, feedback, maintenance, adjustments and modifications, and enforcement.

a. Proper Work Techniques. A program for proper work techniques, such as the following, includes appropriate training and practice time for employees:

* Proper cutting techniques, including work meth- ods that improve posture and reduce stress and strain on extremities.

* Good knife care, including steeling, and the regu- lar sharpening or steeling of knives.

* Correct lifting techniques (proper body mechan- ics).

* Proper use and maintenance of pneumatic and power tools.

* Correct use of ergonomically designed work stations and fixtures.

b. New Employee Conditioning Period. Jobs in the meat industry will usually require conditioning, or break-in, periods, which may last several weeks. New and returning employees should be gradually inte- grated into a full workload as appropriate for specific jobs and individuals. Employees should be assigned to an experienced trainer for job training and evaluation during the break-in period. Employees reassigned to new jobs should also have a break-in period.

c. Monitoring. Regular monitoring at all levels of operation helps to ensure that employees continue to use proper work practices. This monitoring should include a periodic review of the techniques in use and their effectiveness, including a determination of whether the procedures in use are those specified; if not, then it should be determined why changes have occurred and whether corrective action is necessary.

d. Adjustments and Modifications. Modify work practice controls when the dynamics of the workplace change. Such adjustments include changes in the following:

* Line speeds.

* Staffing at position.

* Type, size. weight, or temperature of the product handled .

3. Personal Protective Equipment (PPE)

PPE should he selected with ergonomic stressors in mind. Appropriate PPE should be provided in a vari- ety of size. should accommodate the physical requirements of workers and the job, and should not contribute to extreme postures and excessive forces. The following factors need to be considered when selecting PPE in the meat industry:

a. Proper fit is essential. For example, gloves that are too thick or that fit improperly can reduce blood circulation and sensory feedback, contribute to slip- page. and require excessive grip strength. The same is true when excessive layers of gloves are used (e.g., rubber over fabric, over metal mesh, over cotton). The gloves in use should facilitate the grasping of the tools and knives needed for a particular job while protecting the worker from injury.

b. Protection against extreme cold (less than 40 degrees Fahrenheit in most meat operations) is neces- sary to minimize stress on joints.

c. Braces, splints, back belts, and other similar devices are not PPE. See Section III. C., "Medical Management Program."

d. Other types of PPE that may be selected for (e.g., arm guards) should not increase ergonomic stressors.

4. Administrative Controls

A sound overall ergonomics program includes administrative controls that reduce the duration, frequency. and severity of exposures to ergonomic stressors.

a. Examples of administrative methods include the following:

* Reducing the total number of repetitions per employee by such means as decreasing production rates and limiting overtime work.

* Providing rest pauses to relieve fatigued muscle- tendon groups. The length of time needed depends on the task's overall effort and total cycle time.

* Increasing the number of employees assigned to a task to alleviate severe conditions, especially in lifting heavy objects.

* Using job rotation, used with caution and as a preventive measure, not as a response to symptoms. The principle of job rotation is to alleviate physical fatigue and stress of a particular set of muscles and tendons by rotating employees among other jobs that use different muscle-tendon groups. If rotation is utilized, the job analyses must be reviewed by a quali- fied person to ensure that the same muscle-tendon groups are not used.

* Providing sufficient numbers of standby/relief personnel to compensate for foreseeable upset condi-

tions on the line (e.g., loss of workers).

* Job enlargement--see the guidance on "Design of Work Methods" given in Sections II. B. 1. and III. B.

b. Effective programs for facility, equipment, and tool maintenance to minimize ergonomic stress and include the following measures:

* A preventive maintenance program for mechani- cal and power tools and equipment, such as powered knives and saws, to verify that they are in proper working order and within original manufacturer's spec- ifications. This may include vibration monitoring.

* Perform maintenance regularly and whenever workers report suspected problems. Sufficient numbers of spare tools should be available to facilitate regular maintenance.

* A specific knife sharpening program. Sharp knives should be readily available.

* Effective housekeeping programs to minimize slippery work surfaces and related hazards such as slips and falls.

C. Medical Management

Implementation of a medical management system is the third major element in the employer's ergonomics program. Proper medical management is necessary both to eliminate or materially reduce the risk of development of CTD signs and symptoms through early identification and treatment and to prevent future problems through development of information sources.

Thus, an effective medical management program for CTDs is essential to the success of an employer's ergonomics program. In an effective program, health care providers will be part of the ergonomic team, interacting and exchanging information routinely in order to prevent and properly treat CTDs.

The guidelines describe the elements of a medical management program for CTDs and related ergonomic issues to ensure early identification, evaluation. and treatment of signs and symptoms; and to aid in their prevention. Each plant should establish standard procedures for the medical management of work- related illnesses or injuries.

A physician or occupational health nurse (OHN) with training in the prevention and treatment of CTDs should supervise the program. Each work shift should have access to health care providers in order to facili- tate treatment, surveillance activities, and recording of information. Where such personnel are not employed full-time, the part-time employment of appropriately trained health care providers is recommended.

The medical management program should address the following issues:

* Injury and illness recordkeeping.

* Early recognition and reporting.

* Systematic evaluation and referral.

* Conservative treatment.

* Conservative return to work.

* Systematic monitoring.

* Adequate staffing and facilities.

Recommendations for medical management of CTDs are evolving rapidly, and health care providers should monitor developments on the subject.

(See Section III. C. for a full description of a recommended program for the medical management of CTDs in meatpacking establishments.)

D. Training and Education

The fourth major program element for an effective ergonomics program is training and education. The purpose of training and education is to ensure that employees are sufficiently informed about the ergon- omic hazards to which they may be exposed and thus are able to participate actively in their own protection. Employees should be adequately trained about the employer's ergonomics program.

Training and education are critical components of an ergonomics program for employees potentially exposed to ergonomic hazards. Training allows managers, supervisors, and employees to understand ergonomic and other hazards associated with a job or production process, their prevention and control, and their medical consequences.

A training program should include the following individuals:

* All affected employees.

* Engineers and maintenance personnel.

* Supervisors.

* Managers.

* Health care providers.

The program should be designed and implemented by qualified persons. Appropriate special training should be provided for personnel responsible for administering the program.

The program should be presented in language and at a level of understanding appropriate for the individ- uals being trained. It should provide an overview of the potential risk of illnesses and injuries, their causes and early symptoms, the means of prevention, and treatment .

The program should also include a means for adequately evaluating its effectiveness. This might be achieved by using employee interviews, testing, and observing work practices, to determine if those who received the training understand the material and the work practices to be followed.

Training for affected employees should consist of both general and specific job training:

1. General Training

Employees who are potentially exposed to ergon- omic hazards should be given formal instruction on the hazards associated with their jobs and with their equipment. This includes information on the varieties of CTDs, what risk factors cause or contribute to them, how to recognize and report symptoms, and how to prevent these disorders. This instruction should be repeated for each employee as necessary. OSHA's experience indicates that, at minimum, annual retrain- ing is advisable.

2. Job-Specific Training

New employees and reassigned workers should receive an initial orientation and hands-on training prior to being placed in a full-production job. Training lines may be used for this purpose. Each new hire should receive a demonstration of the proper use of and procedures for all tools and equipment. The initial training program should include the following:

* Care, use, and handling techniques for knives.

* Use of special tools and devices associated with individual work stations.

* Use of appropriate guards and safety equipment, including personal protective equipment.

* Use of proper lifting techniques and devices.

On-the-job training should emphasize employee development and use of safe and efficient techniques. (See also the section on "New Employee Conditioning Period" under Work Practice Controls, II. B. 1. b.)

3. Training for Supervisors

Supervisors are responsible for ensuring that employees follow safe work practices and receive appropriate training to enable them to do this. Super- visors therefore should undergo training comparable to that of the employees, and such additional training as will enable them to recognize early signs and symp--- toms of CTDs, to recognize hazardous work practices, to correct such practices, and to reinforce the employ- er's ergonomic program, especially through the ergonomic training of employees as may be needed.

4. Training for Managers

Managers should be aware of their safety and health responsibilities and should receive sufficient training pertaining to ergonomic issues at each work station and in the production process as a whole so that they can effectively carry out their responsibilities.

5. Training for Engineers and Maintenance Personnel

Plant engineers and maintenance personnel should be trained in the prevention and correction of ergo- nomic hazards through job and work station design and proper maintenance, both in general and as applied to the specific conditions of the facility.