US. DEPARTMENT OF LABOR OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION Cleveland Area Of?ce Region 6393 Oak Tree Blvd, Suite 203 Independence, Ohio 44131?6964 September 29, 2016 Tim More Case Farms Processing, Inc. 1925 30th Street NE Canton, OH 44705 RE: Inspection #1137126 Dear Mr. More: An inspection of your workplace and evaluation of your injury and illness records at 1925 30th Street NE, Canton, Ohio beginning on April 4, 2016 disclosed the following conditions which are consistent with employee injuries and illnesses which can be caused by ergonomic risk factors/stressors observed in your facility: Employees working on the cone line in the debone area are exposed to ergonomic risk factors/stressors including, but not limited to: awkward postures; high hand forces; elevated rates of repetition; lack of rest; and cold temperature. Since 2012, workers performing cone line tasks have experienced work-related injuries and pain to areas of the body including, but not limited to: hands, wrists, arms, shoulders, and back. Injuries experienced to the hands and wrists include diagnoses of tendonitis, tenosynovitis, and carpal tunnel Multiple ergonomic risk factor analyses indicate that these jobs present elevated risk for the development of work?related musculoskeletal disorders speci?cally distal upper extremity (DUE) disorders cumulative trauma disorders (CTDS). The investigation also revealed that many workers in this area are experiencing or have recently experienced signs or pain and discomfort such as burning, numbness, tingling, and swelling in areas of the body such as the ?ngers, palm of the hand, wrists, forearms, elbows, shoulders, neck, upper back, low back, and legs) that may be Consistent with the development of U.S. DEPARTMENT OF LABOR OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION Cleveland Area Of?ce Region 6393 Oak Tree Blvd, Suite 203 Independence, Ohio 44131-6964 Risk Factor Summarv A more in depth explanation of these stressors/risk factors are discussed below: Awkward postures Postures on the cone line were often noted to include raised shoulders, raised upper arms, abducted (pulled away from the body) upper arms, torso flexion torso side bending, torso twisting, torso side bending, extended reaches, ulnar (non-thumb side) wrist deviation, wrist ?exion, wrist rotation, neck ?exion, and neck side bending. High hand forces Employees interviewed provided estimated normalize peak hand forces utilizing a visual analogue scale (0?10) with verbal anchors (0 corresponding to ?no effort? 10 corresponding to 100% maximum effort?) for both hands. For reference, relevant verbal anchors included: 0 (nothing at all), 2 (weak/light), 3 (moderate), 5 (strong/heavy), 7 (very strong), and 10 (almost maximum). This scale correlates to the percent of an employee?s maximum voluntary contraction (MVC, aka maximum grip force). Force estimates ranged between 20% and 80% MVC for the cutting/task dominant hand. General guidelines for hand force work design are 20% MVC for repetitive work and 10% MVC for highly repetitive work]. Elevated rates of repetition Employees interviewed also provided estimated hand activity level ratings utilizing a visual analogue scale (0-10) with verbal anchors (0 corresponding to ?hands idle most of the time no regular pauses? 10 corresponding to ?rapid steady motion dif?culty keeping up or continuous exertion?) for both hands. For reference, relevant verbal anchors included: 4 (slow steady motion many brief pauses), 6 (steady motion infrequent pauses), 8 (rapid steady motion few pauses), and 10 (rapid steady motion dif?cult to keep up). These estimations were validated and/ or adjusted utilizing video analysis that determined the percent of the work cycle where force is likely greater than 5% of MVC (duty cycle). Validated/adjusted hand activity level ratings varied between 5 and 7 for the cutting/task dominant hand. The number of exertions per minute for the cutting/dominant hands were determined to be: cone loader (37), shoulder cut (19), 2nd shoulder cut (16), wing roller (35), breast puller (33), tender cutter (60), tender puller (42), breast inspector (35). Lack of rest These job tasks are comprised of highly repetitive, short duration, movements with few opportunities for periods of recovery. The upper limbs (?ngers, hands, wrists, forearms, upper arms, and shoulders) were observed to be in a steady and often time rapid motion allowing for very few periods of rest. Of most concern was the U.S. DEPARTMENT OF LABOR OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION Cleveland Area Of?ce Region 6393 Oak Tree Blvd, Suite 203 Independence, Ohio 44131-6964 ?nding that employees working on the cone lines do not commonly rotate to other job positions between cone line positions, between ?mirror positions? on the opposite cone line, or off of the cone lines all together). Another concern was that employees on the cone line commonly work on shifts longer than 8 hours. The only scheduled breaks are two 15 minute breaks, a 30 minute lunch, and an extra 15 minute break if overtime is incurred. Cold temperatures The temperature on the cone line was noted to be between 40 and 50 degrees Fahrenheit. Cold temperatures are known to exacerbate because the vasoconstriction response reduces blood ?ow to the distal upper extremities, including the wrist and ?ngers. Risk Factor Analyses Nine cone line positions were analyzed using three established ergonomic stressor/risk factor evaluation tools: (1) The for Hand Activity (TLV), (2) the Rapid Upper Limb Assessment (RULA), and (3) the Strain Index (SI). The TLV is considers the ratio between normalize peak hand force (NPF) and hand activity level (HAL) [ratio and represents conditions to which it is believed nearly all workers may be repeatedly exposed without adverse health effectsz. RULA is a survey method for the investigation of work?related upper limb disorders and allows for assessment of the postures of the neck, truck and upper limbs along with the muscle function and the external loads experienced by the body. A coding system is used to generate an action list which indicates the level of intervention required to reduce the risks of injury due to physical loading on the operator3. The Strain Index (SI) assesses jobs for risk of WMDs of the DUE, speci?cally the hand, wrist and elbow. The tool assesses six job risk factors for each arm through the assignment of categories linked to numerical ratings4. A summary of the results of these analyses by position is provided below. Also included are observations of potential work station work process challenges that are likely leading to observed awkward postures: US. DEPARTMENT OF LABOR OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION Cleveland Area Office Region 6393 Oak Tree Blvd, Suite 203 Independence, Ohio 44131-6964 (1) Cone Loader (line Assessment Scores Score Interpretation Contributing factors tool 1.0 TLV of 0.78. Risk factors Hand forces (40% MVC) and conservative 1.0 (R) present at a magnitude likely to values for hand activity level (6) result in the development of work- WMDs (DUE disorders CTDs). RULA 7 out of 7 Investigate and change Raised shoulder, raised upper arm, abducted immediately upper arm, lower arms working across the midline/to the sides of the body, extended reaches, neck ?exion, neck twisting/side bending, wrist twisting/bending/deviations, trunk twisting/side bending, repetition 122 Scores 7 are probably hazardous Intensity of exertion, duration of exertion, efforts per minute, hand/wrist postures, speed of work, and duration of task per day Notes: (L) or (R) indicates hand speci?c scores; Aindicates task dominant cutting/grabbing hand Maior workstation work process observations - cone loader: a) Awkward postures (including raised inner shoulder, raised inner upper arm, abducted inner upper arm, extended outer arm reach, torso ?exion, torso side bending) appeared to be primarily driven by the fact that the left and right hand sides of the workstation were on uneven horizontal planes resulting in the worker being too high in terms of the receiving bin on the right side and too low in terms of interaction of the cone on the left side. In addition, there was no work platform height adiustabilitv in this location. (2) 1St Shoulder Cut (line Assessment Scores Score Interpretation Contributing factors tool 2.0 (L) TLV of 0.78. Risk factors Hand forces (80% MVC) and conservative 2.0 present at a magnitude likely to values for hand activity level (6) result in the development of work- WMDs (DUE disorders CTDs). RULA 7 out of 7 Investigate and change Raised shoulders, raised upper arms, abducted immediately upper arms, lower arms working across the midline/out to the sides of the body, extended reaches, neck ?exion, neck twisting/side bending, wrist twisting/bending/deviations, trunk twisting/side bending, repetition SI Scores 7 are probably hazardous Intensity of exertion, duration of exertion, efforts per minute, hand/wrist postures, speed of work, and duration of task per day Notes: (L) or (R) indicates hand speci?c scores; Aiigiicates task dominant cutting/grabbing hand OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION US. DEPARTMENT OF LABOR Cleveland Area Office Region 6393 Oak Tree Blvd, Suite 203 Independence, Ohio 44131?6964 Maior workstation work process observations - 1St shoulder cut a) 13) Awkward postures (including raised shoulders, raised upper arms, abducted upper arms) appeared to be primarily driven by the fact that there was no work platform height adiustability in this location resulting in the worker being too low in terms of their interaction with the cone when utilizing the cutting method observed. Cutting arm/hand/wrist awkward postures (including wrist twisting/bending/deviation, raised upper arm, abducted upper arm, raised shoulder) appeared to also be driven by the orientation of the grip on the knife and the method of cutting. (3) 2nd Shoulder Cut (line Assessment Scores Score Interpretation Contrib?uting factors tool RULA 7 out of 7 Investigate and change Raised shoulders, raised upper arms, abducted immediately upper arms, lower arms working across the midline/out to the sides of the body, extended reaches, neck ?exion, neck twisting/side bending, wrist twisting/bending/deviations, trunk ?exion, trunk twisting/side bending, repetition SI values unable to obtain an employee estimate of hand force intensity necessary to determine the exact score; HAL not applied for the same reason Mai or workstation work process observations - 2nd shoulder cut: a) b) Awkward postures (including raised shoulders, raised upper arms, abducted upper arms) appeared to be primarily driven by the fact that there was no work platform height adiustabilitv in this location resulting in the worker being too low in terms of their interaction with the cone when utilizing the cutting method observed. Cutting arm/hand/wrist awkward postures (including wrist twisting/bending/deviation, raised upper arm, abducted upper arm, raised shoulder) appeared to also be driven by the orientation of the grip on the knife and the method of cutting. U.S. DEPARTMENT OF LABOR OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION Cleveland Area Of?ce Region 6393 Oak Tree Blvd, Suite 203 Independence, Ohio 44131?6964 (4) Wing Roller (line Assessment Scores Score Interpretation Contributing factors tool 1.0 (L) TLV of 0.78. Risk factors Hand forces (50% MVC) and conservative 1.3 present at a magnitude likely to values for hand activity level (5 and 6) result in the development of work- WMDs (DUE disorders CTDs). RULA 7 out of 7 Investigate and change Raised shoulder, raised upper arm, abducted immediately upper arm, lower arms working across the midline/out to the sides of the body, neck ?exion, neck twisting/side bending, wrist twisting/bending/deviations, trunk twistingside bending, repetition SI Scores 7 are probably hazardous Intensity of exertion, duration of exertion, efforts per minute, hand/wrist postures, speed of work, and duration of task per day Notes: (L) or (R) indicates hand speci?c scores; Aindicates task dominant cutting/grabbing hand Maior workstation work process observations - wing roller: a) Cutting arm/hand/wrist awkward postures (including wrist twisting/bending/deviation, raised upper arm, abducted shoulder, raised upper arm) appeared to be primarily driven by the in-line style of knife handle. (5) Breast Puller (line Assessment Scores Score Interpretation Contributing factors tool TLVW 1.0 TLV of 0.78. Risk factors Hand forces (30% MVC) and conservative 1.0 present at a magnitude likely to values for hand activity level (7) result in the development of work- WMDs (DUE disorders! CTDs). RULA 7 out of 7 Investigate and change Raised shoulders, raised upper arms, abducted immediately upper arms, extended reaches, neck twisting/side bending, wrist twisting/bending/deviations, trunk ?exion, trunk t_wisting/side bending. repetition SI Scores 7 are probably hazardous Intensity of exertion, duration of exertion, efforts per minute, hand/wrist postures, speed of work, and duration of task per dav Notes: (L) or (R) indicates hand specific scores; Aindicates task dominant cutting/grabbing hand Major workstation i work process observations breast puller: a) Awkward postures (including raised shoulders, raised upper arms,,abducted upper arms, torso ?exion, extended reaches) appeared to be primarily driven by the fact that the height adiustable platform being utilized did not adLust high enough resulting in the worker being too low in terms of their interaction US. DEPARTMENT OF LABOR OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION Cleveland Area Of?ce Region 6393 Oak Tree Blvd, Suite 203 Independence, Ohio 44131?6964 with the cone. There were other height adjustable platforms on the line that were capable of being adjusted to higher orientations. b) Awkward postures (including extended reaches, torso ?exion) appeared to also be driven by the distance from the edge of the work station to the work. 0) Prolonged contact stress that results from holding scissors while pulling the breast meat from the bone. (6) Tender Cutter (line Assessment Scores Score Interpretation Contributing factors tool 1.3 (L) TLV of 0.78. Risk factors Hand forces (40 - 70% MVC) and 2.3 present at a magnitude likely to conservative values for hand activity level (7) result in the development of work- WMDs (DUE disorders CTDs). RULA 7 out of 7 Investigate and change Raised shoulders, raised upper arms, abducted immediately upper arms, neck ?exion, neck twisting/side bending, wrist twisting/bending/deviations, trunk ?exion, trunk twisting/side bending, repetition SI Scores 7 are probably hazardous Intensity of exertion, duration of exertion, efforts per minute, hand/wrist postures, speed of work, and duration of task per day Notes.? (L) or r7?) indicates l-iaudspecifie scores: ?indicates toss dominant from! Maior workstation 7? work process observations tender cutter: a) Awkward postures (including raised holding shoulder, raised upper arms, abducted upper holding arm) appeared to be primarily driven by the fact that the height atliustabie platform being utilized {lid not adiust high enough resulting in the worker being too low in terms of their interaction with the cone. b) Cutting hand/wrist aWkward postures (including wrist twisting/bending/deviation, raised upper arm) appeared to also be driven by the in-line stvle of knife handle. U.S. DEPARTMENT OF LABOR OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION Cleveland Area Office Region 6393 Oak Tree Blvd, Suite 203 Independence, Ohio 44131?6964 (7) Tender Puller (line Assessment Scores Score Interpretation Contributing factors tool RULA 6 out of 7 Investigate and change soon Raised shoulders, raised upper arms, abducted upper arms, extended reaches, neck twisting/side bending, wrist twisting/bending/deviations, trunk ?exion, trunk twisting/side bending, repetition SI values likely.>7, unable to obtain an employee estimate of hand force intensity necessary to determine the exact score; not applied for the same reason Maior workstation work process observations tender puller: a) Awkward postures (including raised shoulders, raised upper arms, abducted upper arms) appeared to be primarily driven by the fact that the ?ght adiustable platform being utilized did not adiust high enough resulting in the worker being too low in terms of their interaction with the cone. b) Awkward postures (including extended reaches, torso ?exion, raised upper arms, abducted upper arms) appeared to also be driven by the distance from the edge of the work station to the work ?in-coming? cones). (8) Breast Inspector (line Assessment Scores Score Interpretation Contributing factors tool TLV 1.0 TLV of 0.78. Risk factors Hand force (40% MVC) and conservative present at a magnitude likely to value for hand activity level (6) result in the development of work- WMDs (DUE disorders CTDs). RULA 7 out of 7 Investigate and change Raised upper arms, abducted upper arms, immediately extended reaches, neck flexion, neck twisting/side bending, wrist twisting/bending/deviatibns, trunk flexion, trunk twisting/side bending, repetition SI Scores 7 are probably hazardous Intensity of exertion, duration of exertion, efforts per minute, hand/wrist postures, speed of work, and duration of task per day Notes: (L) or (R) indicates hand speci?c scores; "indz'cates task dominant cutting/grabbing hand U.S. DEPARTMENT OF LABOR OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION Cleveland Area Office Region 6393 Oak Tree Blvd, Suite 203 Independence, Ohio 44131-6964 (9) Breast InSpector (line Assessment Scores Score Interpretation Contributing factors tool TLV 0.2 (L) TLV of 0.78 and AL of 0.56. Hand forces (10 - 20% MVC) and 0.4 Acceptable level of risk. conservative values for hand activity _level (5) RULA 7 out of 7 Investigate and change Raised shoulders, raised upper arms, abducted immediately upper arms, extended reaches, lower arms working across the midline/to the sides of the body, neck ?exion, neck twisting/side bending, wrist twisting/bending/deviations, trunk ?exion, trunk twisting/side bending, repetition SI 7 (L) Scores 7 are probably hazardous Intensity of exertion, duration of exertion, efforts per minute, hand/wrist postures, speed of work, and duration of task per day Notes: (L) or (R) indicates hand specific scores; Aindicates task dominant cutting/grabbing hand Maj or workstation work process observations breast inspectors: a) Awkward postures (including torso twisting, torso side bending, neck twisting, neck side bending) appeared to be primarily driven by the fact that product tubs were located behind and to the side of the workers. b) Awkward postures (including extended reaches, torso ?exion, raised upper arms, abducted upper arms, raised shoulders) appeared to be primarily driven by the distance from edge of the workstation to the center of the conveyor and the difference in height between the conveyor and the conveyor table. Additional concerns: 0 There was no formal ergonomics program/process in place to help identify and correct ergonomics challenges. Fundamental elements of successful ergonomics programs/processes that appeared to be missing included, but may not be limited to: Looking for signs of I Building in-house expertise to address ergonomic hazards and related concerns. Evaluation of work tasks to identify ergonomic risk factors/stressors. U.S. DEPARTMENT OF LABOR OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION Cleveland Area Office Region 6393 Oak Tree Blvd, Suite 203 Independence, Ohio 44131-6964 I Analyses of work tasks to evaluate the magnitude of ergonomic risk factors/stressors. Training on ergonomic risk factor/stressor awareness, the of and the importance of early reporting and treatment of WMSD signs and I Implementation and evaluation of controls such as engineering and administrative controls. 0 The administrative control of ob rotation was not being implemented for workers on the cone-line. It was determined that workers normally worked in assigned positons (day-to-day and hour-to-hour) without rotating to jobs/tasks with different demands. A formal job rotation program with the goal of reducing the duration of exposure of risk factors (repetition, force, awkward postures, cold) and allowing workers to rest particular groups of muscles and tendons was not in place. In addition, workers reported commonly working shifts longer than 8 hours. I ?Mouse-trap? style knife de-burring units were located on a rail near shoulder level for most workers. The vertical orientation of these units required the cone line workers to twist and deviate their wrists? when repeatedly performing knife de-burring motions during their shifts. In the interest of workplace safety and health, I recommend that you voluntarily take the necessary steps to materially reduce or eliminate your employees? exposures to the conditions listed above. While some ergonomics risk factors can be reduced or eliminated by implementing a single means of abatement, in most cases a process utilizing components, such as the following, will provide an effective method of addressing the risk factors. These components include: accurate injury and illness recordkeeping; medical management and treatment for employees suffering work-related injuries; work place analysis of obs and tasks to assess hazards and the steps to abate them; engineering, administrative, and work practice controls or actions to materially reduce or eliminate the hazards; and education and training of workers and management. If an ergonomic risk factor is to be addressed on an incremental basis to determine the effectiveness of a speci?c control strategy believed to provide a proteCtive solution, it is important to track and 10 U.S. DEPARTMENT OF LABOR OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION Cleveland Area Office Region 6393 Oak Tree Blvd, Suite 203 Independence, Ohio 44131?6964 evaluate the effectiveness of the results in a timely manner, and to timely implement additional control measures if initial controls fail to eliminate or materially reduce worker exposures. We have examined available information on the risk factors related to these jobs/tasks, as well as any of your efforts to address ergonomic hazards. The evaluation suggests the following actions be taken to deal with these conditions: Formal Ergonomics Program Development Considerations Establish a formal ergonomics program to better assist in the identification and correction of ergonomic problems, to better involve managers and employees at all levels, and to integrate ergonomics as part of the company?s overall safety and health program. Fundamental aspects of a formalized ergonomics program often include, but are not limited to, the following elementss: 1) Set the stage for action: Determine and express management commitment toward identifying and reducing/eliminating ergonomics risk factors/stressors. Develop and promote a policy statement on ergonomics that: Treats ergonomic efforts as furthering the company?s goals of maintaining and preserving a safe and healthful work environment for all employees; - Expects full cooperation of the total work-force (managers, supervisors, employees, and support staff) in working together toward realizing ergonomics improvements; 0 Assigns lead roles to designated persons who are known to ?make things happen?; 0 Gives ergonomic efforts priority with other cost reduction, productivity, and quality assuranCe activities; and 0 Has the support of the local union or other worker representatives. 2) Track and trend challgge areas: Look for signs of work-related MSD problems by evaluating OSHA Form 300 logs, workers? compensation claims, company ?rst-aid logs, and incident investigation forms to identify and trend MSDs. ll US. DEPARTMENT OF LABOR OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION Cleveland Area Of?ce Region 6393 Oak Tree Blvd, Suite 203 Independence, Ohio 44131-6964 3) Include the'fundamentals in ergonomics training: Provide employees (managers and non-managers at all levels) with training on ergonomic risk factor/stressor awareness MSD signs, and risk factors) and the importance of early reporting of MSD signs and Provide selected individuals with training on ergonomic job analyses (risk identi?cation) and control measures (problem solving). Provide training on ergonomic principles related to workstation height, reach envelopes, and use of knives and scissors. 4) Determine the location and severity of ergonomic risk factors/stressors in the facility and implement controls when necessary; Evaluate jobs/tasks to identify the presence and extent of ergonomic risk factors/stressors. Develop and implement corrective change through engineering or administrative controls when necessary. Administrative controls should be relied on when engineering control options have been exhausted, to support engineering controls that have already been implemented, or as a temporary measure until permanent engineering solutions can be developed and implemented. 5) Develop and promote a venue for discussing ergonomic challenges, implementing controls/solutions, and evaluating the effectiveness of changes made: Establish an ergonomics committee involving worker and management representatives to assist in managing activities such as conducting ergonomic job/task analyses and championing/evaluating corrective changes. 6) Develop effective protocols for treating WMSD Periodically evaluate the medical staff for adherence to the treating protocols and the effectiveness in reducing WMSD Cone Line Control Considerations 1) Installing height adjustable platforms on the cone loader, 1St shoulder cut, 2nCl shoulder cut positions to raise each worker so that the angles between the lower and upper arms (inner elbow angles) are between 85 and 100 degrees and also so that the upper arms/shoulders are not abducted and raised elbows down and close to the b0dy)6. Ensure that height adjustable platforms at other positions are capable of being adjusted high enough to reduce awkward postures in the shoulders, upper arms, and lower arms. 2) Utilizing ?dagger style? knife grip and cutting method for the ISI shoulder cut and 2nd 12 U.S. DEPARTMENT OF LABOR OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION Cleveland Area Office Region 6393 Oak Tree Blvd, Suite 203 Independence, Ohio 44131?6964 shoulder cut positions. This may reduce awkward postures wrist bending/deviation, raised upper arm, abducted shoulder, raised shoulder) as well as the forces necessary to hold onto the knife during cutting. Utilizmg a bent handle knife for the w1ng roller and tender cutter :33. positions. (This would eliminate/reduce ulnar wrist deviation ,1 during cuts. [(153.5 Raising the front halves receiving bins for the cone loader positions. This would reduce awkward postures neck ?exion, torso ?exion, torso side bending, and extended reaches). Adding ?drop chutes? in the conveyor table for the wing roller position to direct removed wings to a lower conveyor. This would eliminate/reduce repetitive motions and grip forces associated with the rotation or ??ipping? motion of the non-cutting hand/wrist when tossing wings unto the conveyor beyond the cones. Adding ?drop chutes? in the conveyor table and relocating the product tubs for the breast inspector position in order to direct the product through chutes and into the tubs. This would eliminate/reduce the torso twisting associated with accessing the tubs located behind the worker. Matching the height of the conveyor with the conveyor table for the breast inspector position. This may reduce grip forces sliding product versus'pinching and grabbing product) and awkward postures raised upper arms). Providing cut-outs in the conveyor tables. Thiswould reduce extended reaches and torso ?exion by allowing the workers to get closer to the cones, especially when workers are reaching for ?in-coming? cones. Re-orienting ?mouse-trap? style knife de?burring units slot entry at a 45 to 90 degree angle). This would reduce upper arm abduction and wrist deviation when de- burring knives. 10) Reducing the width of the conveyor for the breast puller position. This would reduce extended reaches and torso ?exion by allowing the worker to get closer to the cone. Reducing hand forces (grasp forces and grip forces) and hand activity levels 13 U.S. DEPARTMENT OF LABOR OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION Cleveland Area Of?ce Region 6393 Oak Tree Blvd, Suite 203 Independence, Ohio 44131-6964 (work/rest ratios) as much as feasible so that conditions below the for Hand Activity can be achieved. Note: Where sustained non?neutral postures e. wrist ?exion, extension, wrist deviation, 0r forearm rotation) and low temperatures exist, reduction to levels below the ?action limit? 0ftl1e for Hand Activity is recommendedz. Ideas for reducing hand force: i. Ensuring the consistent and uniform use of the sharpest knives possible through the utilization of quantitative knife sharpness testing technology. This technology can evaluate and help re?ne knife sharpening techniques and knife change out schedules to better ensure the sharpness of the knives being utilized in the facility. ii. Ensure that gloves are good ?tting not too loose to increase grip force and not too tight to restrict blood Loose ?tting gloves can reduce hand strength capabilities by up to 40%6. Textured knife handles improve grip and reduce hand force. iv. Knife handles with hand straps allow the Worker to maintain control of the knife while relaxing the ?ngers on the handle. v. Utilizing cutting motions that allow for the wrist to be in neutral, power grip postures. vi. Adding warm water stations to remove grease from the handles of knives6. One method for increasing rest time Within the tints,r cvcle: i. Adding additional positions to maintain current line speeds. 12) Developing and implementing a formal job/task rotation program with the goal of reducing the duration of exposure of risk factors (repetition, force, awkward postures, cold) and allows rest and recovery for particular groups of muscles and tendons. Avoid rotation between hand-intensive jobs/tasks that have similar or increased levels force and muscle movement requirements6. 14 U.S. DEPARTMENT OF LABOR OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION Cleveland Area Office Region 6393 Oak Tree Blvd, Suite 203 Independence, Ohio 44131-6964 13) Increasing the frequency an duration of scheduled rest breaks throughout the shift. Cross train employees and provide ??oater? workers to allow for periodic breaks between scheduled breaks. You may voluntarily provide this Area Of?ce with progress reports on your efforts to address these conditions. Attached is a list of references and resources that may be of assistance to you in preventing in your workplace. Under current inspection protocol, we may return to your work site in approximately one year to further examine the conditions noted above. Sincerely @115 Area Director 15 U.S. DEPARTMENT OF LABOR OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION Cleveland Area Of?ce Region 6393 Oak Tree Blvd, Suite 203 Independence, Ohio 44131-6964 References 1 Eastman Kodak Company [2004]. Kodak?s Ergonomic Design for People at Work. 2nd ed. Hoboken, NJ: John Wiley and Sons. ZACGIH [2016]. 2016 and Threshold Limit Values for Chemical Substances and Physical Agents and Biological Exposure Indices. Cincinnati, OH: American Conference of Governmental Industrial Hygienists. 3McAtamney and Corlett EN. A Survey Method for the Investigation of Work? Related Upper Limb Disorders.? Applied Ergonomics 24(2): 91-99 (1993). 4Moore and Garg A. ?The Strain Index: A Proposed Method to Analyze Jobs for Risk of Distal Upper Extremity Disorders.? American Industrial Hygiene Association Journal 56: 443- 459 (1995). 5NIOSH Publication No. 97-117 ?Elements of Ergonomics Programs: A Primer Based on Workplace Evaluations of Musculoskeletal Disorders? (1997). 17/ 6Poultry Safety and Health Committee Task Force [1986]. Repetitive motion disorders, the medical ergonomics training program, a guide for the poultry industry. Ergon omics Training Programpdf Other Resources Occupational Safety and Health Administration Safety and Health T0pics Page for ?Ergonomics: Prevention of Musculoskeletal Disorders in the Workplace?. OSHA [1993]. Ergonomics Program Management Guidelines for Meatpacking Plants. 123mm] OSHA [2013]. Prevention of Musculoskeletal Injuries in Poultry Processing. U.S. Poultry Egg Association?s ?Ergonomics at Work? training materials. l6 U.S. DEPARTMENT OF LABOR OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION Cleveland Area Of?ce Region 6393 Oak Tree Blvd, Suite 203 Independence, Ohio 44131-6964 U.S. Poultry Egg Association?s ?Poultry Industry Workplace Safety Issue Kit?. NIOSH Publication 97-141 ?Musculoskeletal Disorders and Workplace Factors: a Critical Review of Epidemiologic Evidence for Work-related Musculoskeletal Disorders of the Neck, Upper Extremity, and Low Back? (1997). NIOSH [2013]. Health Hazard Evaluation Report: ?Evaluation of Musculoskeletal Disorders and Traumatic Injuries Among Employees at a Poultry Processing Plant?. By Musolin K, Ramsey J, Wassell J, Hard D, Mueller C. Cincinnati, OH: U.S. Department of Health and Human Services, Centers for Disease Control and Prevention, National Institute for Occupational Safety and Health, NIOSH HHE Report No. 2012-0125-3204. NIOSH [2015]. Health Hazard Evaluation Report: ?Evaluation of Carpal Tunnel and Other Musculoskeletal Disorders Among Employees at a Poultry Processing Plant?. By Ramsey J, Musolin K, Mueller C. Cincinnati, OH: U.S. Department of Health and Human Services, Centers for Disease Control and Prevention, National Institute for Occupational Safety and Health, NIOSH HHE Report No. 2014-0040-3232. North American Meat Institute [2013]. American Meat Institute Fact Sheet: ?Worker Safety in the Meat and Poultry Industry?. l7 U.S. DEPARTMENT OF LABOR OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION Cleveland Area Office Region 6393 Oak Tree Blvd, Suite 203 Independence, Ohio 44131-6964 September 29, 2016 Tim More Case Farms Processing, Inc. 1925 30th Street NE Canton, OH 44705 RE: Inspection #1137126 Dear Mr. More: An OSHA inspection was conducted at your workplace located at 1925 30th Street NE, Canton, Ohio on April 4, 2016. Based on this inspection, the following recommendation is being provided to enhance employee safety and health: The inspection included an assessment of your establishment?s employee musculoskeletal injury and illness experience since your company acquired the establishment in March of 2012. This involved the evaluation of OSHA recordkeeping forms (3 003, 3013, and 300as) as well as review of workers? compensation forms, company incident reports, employee medical records, and ?rst?aid logs for evidence of musculoskeletal disorders (MSDs). This assessment revealed evidence of not recording multiple work-related injuries and illnesses on your establishment?s OSHA forms 300, 301, and 300a for multiple years (2012 2014). Examples of cases for which the preponderance of the evidence made available indicates that the injury or illness likely met one of the general recording criteria for work-related cases as outlined in 29 CFR 1904.7 involving days away from work, restricted work, or transfer to another job and/0r medical treatment beyond ?rst aid) are included in Table A1 attached to this letter. 29 CF 1904.33(a) requires employers to save the OSHA forms 300, 300a, and 301 for ?ve years following the end of the calendar year that these records cover. In addition, 29 CFR requires employers to update their stored OSHA 300 Logs to include newly discovered recordable injuries and illnesses and to show any changes that have occurred in the classi?cation of previously recorded injuries and illnesses. US. DEPARTMENT OF LABOR OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION Cleveland Area Of?ce Region 6393 Oak Tree Blvd, Suite 203 Independence, Ohio 44131-6964 This assessment also revealed evidence of numerous cases of employees being referred to outside medical services for treatment of reported MSD injuries/illnesses for which there appeared to be no documented follow-up by your company employer was not in possession of employee medical records relating to the referral). 29 CFR 1910.1020(d) requires employers to preserve and maintain employee medical records. You are advised to review and update your retained OSHA form 3003 to include any unrecorded work-related injuries and illnesses that meet criteria for recording. As part of this process, please note that: 1. Impact of workers? compensation outcome on recordability: 29 CFR 1904.0 contains a note that ?recording or reporting a work-related injury, illness, or fatality does not mean that the employer was at fault, that an OSHA rule has been violated, or that the employee is eligible for workers? compensation or other bene?ts?. The rules for compensability under workers? compensation differ from state to state and do not have an effect on whether or not a case needs to be recorded on the OSHA for 300. Many cases will be OSHA recordable and compensable under workers? compensation. However, some cases will be compensable but not OSHA recordable, and some cases will be OSHA recordable but not compensable under workers? compensation (see FAQ 0-2, 2. Impact of employer imposed work restriction and/0r job transfer on recordability: Work restriction and/or job transfer imposed by the employer as the result of a work-related injury or illness will normally be recordable*. According to 29 CFR restricted work occurs when, as the result of a work?related injury or illness: (1) you keep the employee from performing one or more of the routine functions of the employee?s job. or from working the full workdav that he or she would have otherwise been scheduled to work if it occurs beyond the day on which the injury occurred or illness began; or (2) a physician or other licensed healthcare professional recommends that the employee not perform one or more of the routine functions of their job, or not work the full workday that they would otherwise have been scheduled to do work if it occurs beyond the day on which the injury occurred or illness began. US. DEPARTMENT OF LABOR OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION Cleveland Area Of?ce Region 6393 Oak Tree Blvd, Suite 203 Independence, Ohio 44131-6964 According to 29 CFR transfer to another job occurs when you assign an injured or ill employee to a job other than their regular job for part of the day (other than the day on which the injury or illness occurred). *Note: As set out in Chapter 2, 1., F. of the Recordkeeping Policies and Procedures Manual (OSHA CPL a case would not be recorded under section 1904. (4) if 1 the employee experiences minor musculoskeletal discomfort, and 2) a health care professional determined that the employee is fully able to perform all of his or her routine job functions, aid 3) the employer assigns a work restriction to that employee for the purpose of preventing a more serious condition ?om developing. 3. Impact of pre-existing injuries or illnesses on recordability: 29 CFR 1904.5 requires the employer to consider an injury or illness to be work-related if an event or exposure in the work environment either caused or contributed to the resulting condition or signi?cantly aggravated a pre-existing injury or illness. 4. Impact of temporary worker status on recordability: 29 CFR 1904.31 requires the host employer to record the injuries and illnesses of temporary help service employees if the host company supervises the employee on a day-to-day basis. OSHA welcomes any report of your efforts to reduce the above-mentioned condition. If you have any questions concerning this matter, please contact this of?ce. Sincerely, git/{magi .- Area Director ?x OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION US. DEPARTMENT OF LABOR Cleveland Area Of?ce Region 6393 Oak Tree Blvd, Suite 203 Independence, Ohio 44131-6964 Table A1: Examples unrecorded musculoskeletal injuries and illnesses for which there was some evidence of potentially meeting the criteria for an OSHA recordable case. Further evaluation by the employer is recommended. Date Department Contributing Activity Body Part(s) Affected Injury/Illness General recording criteria that appeared to have been triggered 3/2012. Packing hanging chicken hands/wrists(bi) carpal tunnel de Quervain tenosynovitis medical treatment beyond first aid (including surgery) 572012 unknown lifting chicken ?nger (R) tendonitis medical treatment beyond ?rst aid (including prescription for medication) 5/2012 unknown 5/2012 Debone unknown hand (R) sprain medical treatment beyond ?rst aid #cutting chicken arm/hand (L) 6/2012 Debone packing and clipping chicken leg quarters hands/wrists (bi) swelling, numbness, Jillgling work restriction/job transfer (employer imposed) tenosynovitis medical treatment beyond first aid (including prescription for medication); work restriction/job transfer (physician recommended); Note: evidence for work-related aggravation of potential pre- existing injury 6/2012 Vac Line pushing boxes shoulder dislocation medical treatment beyond first aid 7/2012 Evisceration live hang - hand tendonitis medical treatment beyond ?rst aid (including prescription for medication); work restriction/job transfer (physician recommended); N0_te: eligiencefor OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION US. DEPARTMENT OF LABOR Cleveland Area Of?ce Region 6393 Oak Tree Blvd, Suite 203 Independence, Ohio 44131-6964 work-related aggravation of potential pre- existing injury 7/2012 unknown 9/2012? unknown line work arm strain work restriction/job transfer (physician recommended) _g_rading wings shoulder strain/ Sprain work restriction/job? transfer (physician recommended) 10/2012 Debone cutting wings wrist sprain medical treatment beyond first aid (including prescription for medication); work restriction/job transfer (physician recommended) 11/2012 Debone cutting breasts wrists [bi] carpal tunnel medical treatment beyond first aid 1 including surgery) 3/2013 Debone lifting boxes of wings low back pain medical treatment beyond ?rst aid (including prescription for medication) 6/2013 Debone pulling chicken breasts wrist pain work restriction/j ob transfer (employer imposed) 8/2013 Live hang live hang hands/fingers pain, numbness medical treatment beyond ?rst aid (including immobilizing hand splint) 9/2013 Cut Up rehan gin chickens wrist pain, swelling work restriction/j ob transfer (employer imposed) 11/2013 Leg OEarter Packing lifting boxes of bagged chicken abdomen pain, pulled muscle work restriction/ ob transfer (employer imposed) 12/2013 Fast food unknown low back strain medical treatment beyond first aid (including prescription for medication); work restriction/job OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION US. DEPARTMENT OF LABOR Cleveland Area Of?ce Region 6393 Oak Tree Blvd, Suite 203 Independence, Ohio 44131-6964 recommended) 4/2014 8 piece pulling boxes shoulder strain; rotator medical treatment on the scale cuff tear beyond ?rst aid (including prescription for medication) 6/2014 8 piece lifting boxes low back strain work restriction/job Fast food transfer (employer . imposed) 6/2014 Debone loading shoulder sprain work restriction/job transfer (physician recommended 7/2014 Debone pulling wrist [bi] pain work restriction/job chicken transfer (employer breasts imposed) 7/2014 71106 hanging shoulder pain work restriction/job chicken arm transfer (employer imposed)