SNAP-ON INCORPORATED GENERAL STANDARD ON EMPLOYEE SAFETY AND HEALTH

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1 SNAP-ON INCORPORATED GENERAL STANDARD ON EMPLOYEE SAFETY AND HEALTH Issued By: SEQ6401.DOC Approval: Page 1 of 66

2 1.0 SCOPE It is Snap-on Incorporated's policy to have in place a management system that drives all operating units to continual improvement in environmental quality and protection of employee health and safety through the application of best management practice. Best management practice is the minimization of impacts from operations and production by optimizing all of the following: Inputs Processes, Procedures, Practices Prevention and Beneficial Reuse of Waste Minimization of Air Emissions, Wastewater Discharges and Disposal of Waste From Processes and Packaging Safe and Healthy Work Environs This standard applies to all semiautonomous business units, manufacturing plants, distribution centers and repair or service centers worldwide. 2.0 PRACTICE 2.1 General Requirements Each employee actively involved in the operation and implementation of the Environmental, Hygiene and Safety Management System and employees exposed to hazardous conditions or substances must receive on an annual basis the training required to maintain their knowledge and skills at an acceptable competence level per SEQ Training programs must include the following as appropriate: (1) Each employee potentially exposed to hazardous materials shall be trained in the proper identification and quantification of exposures. (2) Each employee potentially exposed shall be familiar with the necessary protective equipment and how it is to be properly maintained. (3) Each employee potentially exposed to hazardous material shall be familiar with the Spill Prevention Control and Countermeasure Plan (SPCC) and their role in plan implementation. (4) Employees potentially exposed to unsafe conditions or agents, including ergonomics stressors, shall be given adequate and periodic training with regard to the recognition and elimination of safety hazards. (5) Employees involved in EH&S Management System operation and implementation will receive annual skill-enhancement training. Page 2 of 66

3 2.2 Management Leadership, Commitment and Employee Involvement The elements of management leadership, commitment and employee involvement are complementary and form the core of a viable occupational safety and health program. Management s commitment provides the motivating force and the resources for organizing and controlling activities within an organization. In an effective program, management regards worker safety and health as a fundamental value of the organization and applies its commitment to safety and health protection with as much vigor as to other organizational goals. Employee involvement provides the means by which workers develop and/or express their own commitment to safety and health protection for themselves and their fellow workers. In implementing Snap-on s safety and health program, there are various forms of commitment and support by management and employees. Some actions are described briefly as follows: A clearly stated worksite policy on safe and healthful work and working conditions, so that all employees with responsibility at a site (and personnel at other locations with responsibility for the site) fully understand the priority and importance of safety and health protection at Snap-on. Establish and communicate a clear goal for the safety and health program at each site and define objectives for meeting that goal, so that all members of the organization understand the results desired and the measures planned for achieving them. Convey visible top management involvement in implementing the program, so that all employees understand that senior management s commitment is serious. This is substantiated by the corporation s financial support for programs. Arrange for and encourage employee involvement in the structure and operation of the program and in decisions that affect their safety and health, so that they will commit their insight and energy to achieving the safety and health program s goal and objectives. This is best demonstrated by line employee involvement in programs. Assign and communicate responsibility for all aspects of the program, so that managers, supervisors and employees in all parts of the organization know what performance is expected of them. Provide adequate authority and financial resources to site management so that assigned responsibilities can be met. Hold managers, supervisors and employees accountable for meeting their responsibilities, so that essential tasks will be performed and minimal interruption by lost time, accidents and illnesses will occur. Review program operations at least bienially to evaluate their appropriateness in meeting goals and objectives, so that deficiencies can be identified and the program and/or the objectives can be revised when they do not meet the goal of effective safety and health protection. Page 3 of 66

4 2.3 Worksite Analysis/Risk Assessment A practical periodic analysis of the work environment involves a variety of worksite examinations in order to identify existing hazards and conditions and operations in which changes might occur to create new hazards. Unawareness of a hazard stemming from failure to examine the worksite is a sign that safety and health policies and/or practices are ineffective. Effective management actively analyzes the work and worksite to anticipate and prevent harmful occurrences. In order that all hazards and potential hazards are identified, the following measures are required: Conduct comprehensive baseline worksite surveys for safety and health and periodic comprehensive update surveys. See Worksheet A. Analyze planned and new facilities, processes, materials and equipment. Perform routine job hazard analyses on all jobs involved in lost time accidents. Conduct regular site safety and health inspections at least quarterly so that new or previously missed hazards and failures in hazard controls are identified. Safety and health inspections are to be conducted and documented through ELMERI (Mandatory Annex B) or country equivalent. Provide a reliable system for employees to notify local management about conditions that appear hazardous and to receive timely and appropriate responses and encourage employees to use the system without fear or reprisal. This utilizes employee insight and experience in safety and health protection and allows employee concerns to be addressed. Investigate accidents so that their causes and means for their prevention can be identified. Analyze injury and illness trends over time so that patterns with common causes can be identified and prevented. Each workstation shall have warning signs (pictorials) that continually remind employees of the hazards present at any particular workstation. (See Annex A to this standard.) Signage is available on the EH&S web site. Page 4 of 66

5 WORKSHEET A Location: Risk Assessment Worksheet Assessment Survey Department: Machine I.D. Date: M# I. Machine Guarding II. Personal Protective Equipment Machine guarding required YES NO (If yes, complete section III below) Personal protective equipment required? (If yes, complete section IV below) YES NO Section III. Identify types of guarding which are in place: Barrier guards Two hand tripping devices Electronic safety devices Safety restraints (i.e. Pull backs) Other Other Other Section IV. Identify PPE required for this job or machine center: Steel to safety shoes Hearing protection Safety glasses Additional PPE required? (SEE BELOW) ADDITIONAL PPE REQUIREMENTS MAY BE FOUND IN PERSONAL PROTECTIVE EQUIPMENT HAZARD ASSESSMENT AND RISK ANALYSIS Section V. Hazardous Conditions Indicate which critical factors were used to select PPE and warning signage which ensures a level of protection greater than the minimum required to protect employees from potential hazards Noise Chemicals Oil/Grease Vibration Abrasion Heat/Cold Applications Cut/Puncture Grip Dexterity/Touch Sensitivity Biohazards Material Handling Signature of Assessor: Date: Product Protection Overhead Hazards Flying Debris Falling Objects Welding/Cutting Electrical Shock Fall Atmosphere Contaminants Radiation Laser Page 5 of 66

6 ANNEX A WORKPLACE SAFETY SIGNS (ANSI Z535.3 AND ANSI Z535.4) Hazard Condition/Factor 1. Noise Protection Required 2. Chemicals 3. Falls/Slips 4. Hand Hazard 5. Biohazard 6. Overhead Hazard 7. Respirator Protection 8. Welding/Cutting 9. Electrical Hazard 10. Radiation 11. Fire Extinguisher 12. Evacuation Path 13. Eye Protection 14. Confined Space 15. Material Handling/Lifting Page 6 of 66

7 ANNEX B WORKPLACE SAFETY AND ELMERI Proactive Monitoring of Safety Performance ELMERI is a reliable safety and health monitoring tool for the manufacturing industry. It is simple and quick to use in any plant of any size and in any industrial sector. The method is based on the observation of workstations and walkways. The observed aspects cover all the main safety and health issues, such as the use of personal protective devices, order and tidiness, machine safety, industrial hygiene and ergonomics. The ELMERI method produces a safety index, showing the present safety level of the plant. The safety index (a percentage) may vary from 0 to 100%. For instance an index of 60% means that 60 out of every 100 items observed are in keeping with the safety standards and good workplace practices. The ELMERI index gives positive feedback and motivates future safety actions. A scientific study carried out in metal product manufacturing companies showed that the ELMERI method predicts reliably the accident rate of the company. A high safety index as a monitoring result indicates a low accident rate, and vice versa. ELMERI is a valid proactive measure of safety performance. It shows the potential causes of future accidents. ELMERI provides quantitative information on the effectiveness of the OH&S management system. It helps to identify development needs, to set goals and to measure the results of safety actions. ELMERI is also a tool for the company s safety personnel and other safety and health experts, e.g., consultants, insurance companies and government safety inspectors. For them the method gives unbiased facts about the safety and health in the company, and the results can be compared with those of other companies in the same branch of industry. The ELMERI method was developed together with experienced researchers, safety inspectors and safety managers, and the workers safety delegates from a great variety of industrial branches. Page 7 of 66

8 ELMERI SAFETY OBSERVATION ELMERI in a Nutshell ELMERI is an easy-to-use and reliable method of evaluating the safety level of a workplace. The ELMERI method is based on reliable observation of all the notable safety and health aspects of the physical work environment, and of safety behavior. The observations are focused on the following seven main item groups: Safety behavior Order and tidiness Machine safety Industrial hygiene Ergonomics Walkways First aid and fire safety All items are observed at every workstation which has been selected for observation. The item is assessed to be either correct or not correct. The item is scored as correct if it meets the minimum safety standards and good workplace practices defined in the ELMERI observation rules, otherwise the item is scored as not correct. A no observation mark is given if the item cannot be scored during the inspection, or the observer is not sure how to score it. Special investigations, e.g., industrial hygiene measurements, may be needed in some cases before the assessment can be done. The ELMERI safety index can be calculated when all the selected workstations have been observed. The safety index is calculated as a percentage of the correct items of all observed items. ELMERI index = correct observations correct + not correct observations x 100 (%) Selecting the Workstations to be Observed The observation takes about 15 minutes at one workstation. All workstations can easily be covered in a small company and in a department of a larger company. In this case the resulting safety index is the most trustworthy. Page 8 of 66

9 ELMERI SAFETY OBSERVATION Reliable results can be obtained even if there are not enough resources to observe all the work areas. In such a case, a representative sample of workstations has to be selected for observation. The sample must cover all the relevant jobs in the workplace. For an exact and reliable result, 5-8 workstations have to be observed. Thus there will be about observations in all. Before selecting the workstations, the different types of jobs in the company should be determined. If possible, also workers without their own distinct workstation are to be observed, e.g., cleaners and forklift truck drivers. If many workers have the same type of job, a sufficient number of these workstations must be observed. For instance, if there are five welders, one welding workstation may be selected randomly for investigation. Randomization is necessary to avoid systematic bias in results. For instance, randomization can be based on the first letter of the worker s last name, but any other method of randomization can be used as well. If there are several departments in the company, a sufficient number of workstations should be selected from every department. This is necessary because considerable differences may exist between departments. The Area of a Workstation The area of each workstation, as well as the machines and equipment included, have to be decided before the observation. Basically, a workstation is limited area for one worker or one process phase (for instance, machine-tool work, welding, painting, packing). It is recommended that the observed area be small rather than large. It is work dividing a long machine line into suitable sections, and to investigate each section separately. The items connected with gangways and first aid and fire safety should also be determined. When workstations are next to each other, one must take care not to observe the same items twice. Assessing the Workstation Once the workstation is selected, scoring can begin. It is suggested to go through the observation form by starting at the top and taking each point in sequence. After observing all the items at one workstation, move on to the following one. It is best to write down the observed deficiencies immediately. Afterwards it is difficult to remember the reason for the not correct indications. Page 9 of 66

10 ELMERI OBSERVATION PROCEDURES 1. SAFETY BEHAVIOUR Number of Observations One observation is made for each worker at the workstation. If there is no worker at the workstation during the observation, a no observation mark is given. Criteria For a Correct Score 1.1.) Use of personal protective equipment (PPE) and risk taking. The worker uses all the PPE that are necessary in his job, and does not take any noticeable risk. The PPE that may be needed are, for instance: Head protectors Foot and leg protectors Hearing protectors Eye and face protectors Protective clothing Protective gloves PPE against falls from a height, harnesses Respiratory protective equipment. The risk taking may include, for instance: Using defective devices Removing safety devices or making them inoperable Servicing equipment in operation Operating at an improper speed Smoking in a nonsmoking area. Page 10 of 66

11 ELMERI OBSERVATION PROCEDURES 2. ORDER AND TIDINESS Number of Observations Altogether five observations are made, one for each of the items given below. If there is no worktable, shelf, surface of machine or waste container, a no observation mark is given. If one wants to emphasize order and tidiness, the observation can be done separately for every worktable, shelf, surface and waste container. Then there may be more than five observations. Criteria For a Correct Score 2.1.) Worktables The tables are in order and there are no unnecessary objects on them. 2.2.) Shelves The shelves are in order, solidly built, safe and not overloaded. The racks, etc., are observed for these points too. 2.3.) Surfaces of machines and lockers, etc. There are no unnecessary objects on the surfaces of machines, lockers or cupboards, etc. 2.4.) Waste container The waste container is not flowing over. 2.5.) Floors and platforms The floors and platforms are tidy, uncluttered and in good condition, considering walking, driving and material handling. Page 11 of 66

12 ELMERI OBSERVATION PROCEDURES 3. MACHINE SAFETY Number of Observations Four observations are made separately for each machine at the workstation. If there is no machine guard or permanent means of access and they are not needed, a no observation mark is given. Criteria For a Correct Score 3.1.) Design, construction and condition is correct when The machine is stable and solidly built There are no sharp edges, etc., likely to cause injury The machine is undamaged, the structure has no breaks and there are no unsubstantial, frail repair jobs, e.g., wire or adhesive tape There are appropriate well visible safety signs. 3.2.) Control devices and emergency stops Control devices, including, e.g., start-up devices, stop devices and adjusters are correct when they are Clearly visible, identifiable and properly marked Undamaged Positioned for safe and ergonomic operation Designed so that the movement of the control is consistent with its effect. The emergency stop control must also be Clearly identifiable and clearly visible Quickly accessible. 3.3.) Machine guards Moving machine parts must be designed to avoid hazards, or fixed with guards in such a way as to prevent risk of contact. The machine guards are correct when they Fulfill safety standards Are in place and undamaged Have not been bypassed or made inoperable. 3.4.) Permanent means of access The machinery must be fitted with permanent means to allow safe access to all areas used for daily production, adjustment and maintenance operations of the machine. Permanent means of access are correct when They are located where needed Their construction is safe and there is enough space A stairway, with a maximum slope of less than 45, leads to the platform There are no unnecessary objects on them No temporary stands are used as platforms. Page 12 of 66

13 ELMERI OBSERVATION PROCEDURES 4. INDUSTRIAL HYGIENE Number of Observations Five observations on industrial hygiene are made at each workstation. If an item cannot be evaluated by sensory methods or by experience, and there are no earlier results of hygienic measurements, a no observation mark is given. Further investigations may then be recommended. Criteria For a Correct Score 4.1.) Noise The noise is correct when The noise level is under 85 db(a) or protective measures have been implemented. There is no impulse noise (for instance hammering). 4.2.) Lighting The lighting is correct when The level of illumination is sufficient. There is no harmful glare. There is no excessive contrast between light and dark areas. 4.3.) Air quality The air is clean and healthy if there are no airborne contaminants/pollutants, such as dust, fibers, gases, vapors or microorganisms in the ambient air of the workstation, or if the concentrations are less then 25% of the TLV levels (Threshold Limit Value). The evaluation may be based on the available data from the industrial hygiene measurements. If there are no data available, hazardous operations may be identified visually. Some chemicals can be identified by their odor/smell. The dust on the surfaces and shelves reveals something about the dust concentration. Also the information on the work process and its emissions can be used. 4.4.) Thermal conditions Thermal conditions are correct when The air temperature is suitable for the activity. The humidity is suitable. The air velocity is suitable and there is no draft. 4.5.) Chemicals Chemical hazards are under control when The packings and containers are undamaged, and the names of the chemicals and the necessary safety labeling are marked on them. The handling is safe and clean and does not cause exposure. If there are no chemicals a no observation mark is given. Page 13 of 66

14 5. ERGONOMICS ELMERI OBSERVATION PROCEDURES Number of Observations Four observations are made at each workstation, one observation for each item given below. Criteria For a Correct Score 5.1.) Design of the workstation and work posture This aspect is correct when The workspace is sufficient for the worker to perform the work movements and to change postures The objects to be handled are situated so that the workers work posture is good The worker can adjust the dimensions of the workstation, for example, the seat and working height. Pay attention to the height of the worktable and the seat. Is their dimensioning correct or are they easily adjustable? 5.2.) Manual material handling Several factors affect the risk of injury from manual material handling, for instance the weight, size and shape, of the load the work task, lifting height, the timing, i.e., how often loads must be lifted, the work environment and individual capability. In two-hand lifting the situation is usually correct when The load is less than 70 lbs. and the lifting takes place near the body, standing upright, in optimal lifting conditions. These limits are valid if there is less than one hour of lifting during the working day, and the lifting is repeated no more than once every five minutes. If the work involves more lifting or the lifting is repeated more often, these limits should be lowered substantially. 5.3.) Repetitive work Repetitive work means here work tasks which cause a risk of repetitive-strain injuries. Repetitive work may be found for example in packing tasks and in serial production. Estimate whether the worker is able to adjust the workflow, e.g., is there a buffer stock in the workstation. This item is correct when no repetitive work is being done, or the length of the work cycle is more than 30 seconds. 5.4.) Physical variability This aspect is correct when the work includes a variable amount of physical activity, sitting, standing and moving. You may ask what the different main tasks that the work includes are. Page 14 of 66

15 6. WALKWAYS ELMERI OBSERVATION PROCEDURES Number of Observations Three observations are made for walkways just outside the workstation, one observation for each item given below. The walkways coming to the workstation are observed at a distance of 10 m, or to the next door if the door is nearer than 10 m. If the same walkways come to several workstations being observed, they are assessed only once and a no observation mark is used instead of duplication. The floors and walkways of the workstation are observed when scoring item 2.5. Floors and platforms. Criteria For a Correct Score 6.1.) Design and markings The walkway must be Wide and high enough Marked, and the pedestrian traffic separated from vehicle traffic when needed. Vehicle passages must be separated and marked clearly. The separation can be done by painting, safety islands (platforms), banisters or traffic signs. Pedestrian traffic must be separated from the vehicle traffic when needed. 6.2.) Order and condition The walkway must be in order and in good condition. There should be no unnecessary objects on the walkway. The surface of the walkway must not be broken or slippery. 6.3.) Visibility and lighting The visibility must be good in all directions. The illumination of the walkway must be sufficient and even. Page 15 of 66

16 ELMERI OBSERVATION PROCEDURES 7. FIRST AID AND FIRE SAFETY Number of Observations Four items are to be observed, one observation for each item given below. If the item, for example, a first aid kit, does not exist at the workstation observed, the nearest first aid kit shall be assessed. If the same first aid kit, etc., is the nearest one to several workstations, it is assessed only once and a no observation mark is used instead of duplication. Criteria For a Correct Score 7.1.) Electric distribution box The electric distribution box is marked, and there is free space of at least 3.0 ft. in front of it. 7.2.) First aid kit All the necessary first aid supplies must be available. The supplies that are needed depend on the hazards at the workplace. 7.3.) Fire extinguisher Suitable fire extinguishers must be available. There should be free space in front of them to allow easy access and use. 7.4.) Emergency exits An emergency exit must be available and free of obstructions. The exit must be clearly marked. The markings must be seen from the workstation, also in case of power failure. Page 16 of 66

17 E M R L E I Finnish Institute of Occupational Health Topeliuksenkatu 41 a A FIN Helsinki Finland Tel elmeri@occuphealth.fi Page 17 of 66

18 ELMERI Observation Form Company: Date: Observer: Workstation: Items Correct Total Not correct Total Not observed 1. SAFETY BEHAVIOR 1.1. Use of PPE and risk taking 2. ORDER AND TIDINESS 2.1. Worktables 2.2. Shelves 2.3. Surfaces of machines, etc Waste container 2.5. Floors and platforms 3. MACHINE SAFETY 3.1. Design, construction and condition 3.2. Control devices and emergency stops 3.3. Machine guards 3.4. Permanent means of access 4. INDUSTRIAL HYGIENE 4.1. Noise 4.2. Lighting 4.3. Air quality 4.4. Thermal conditions 4.5. Chemicals 5. ERGONOMICS 5.1. Design of workstation and work posture 5.2. Manual material handling 5.3. Repetitive work 5.4. Physical variability 6. WALKWAYS 6.1. Design and markings 6.2. Order and condition 6.3. Visibility and lighting 7. FIRST AID AND FIRE SAFETY 7.1. Electric distribution box 7.2. First aid kit 7.3. Fire extinguisher 7.4. Emergency exits Total Total correct ELMERI index = correct + not correct x 100 = x 100 = % Finnish Institute of Occupational Health 2000 Total Occupational Safety Inspectorate Page 18 of 66

19 ELMERI Observation Rules Items Criteria for a correct score 1. SAFETY BEHAVIOR: One observation for each worker 1.1. Use of personal protective * The worker uses all the necessary PPE, and does not take any equipment (PPE) and risk taking noticeable risk (e.g., by removing safety devices, servicing equipment in operation, operating at an improper speed, smoking in a nonsmoking area) 2. ORDER AND TIDINESS: Five observations for each workstation 2.1. Worktables * In order, no unnecessary objects 2.2. Shelves * In order, solidly built, safe, no overloading 2.3. Surfaces of machines, etc. * No unnecessary objects 2.4. Waste container * Container not flowing over 2.5. Floors and platforms * Tidy, uncluttered, in good condition, no oil/water etc. 3. MACHINE SAFETY: Four observations for each machine at the workstation 3.1. Design, construction and condition 3.2. Control devices and emergency stops 3.3. Machine guards 3.4. Permanent means of access * Stable, solid, undamaged, safety signs * Position, marking, condition, as recommended * Fulfill safety standards, undamaged, operable * Safe access to all areas used for daily production, adjustment and maintenance operations, no unnecessary objects 4. INDUSTRIAL HYGIENE: Five observations for each workstation 4.1. Noise 4.2. Lighting 4.3. Air quality 4.4. Thermal conditions 4.5. Chemicals 5. ERGONOMICS: Four observations for each workstation 5.1. Design of workstation and work posture * Noise less than limits, e.g., production space 85 db(a), no impulse noise * Lighting is sufficient, no glare * Air is clean and healthy, concentrations of airborne contaminants/pollutants are less than 25% of the TLV levels * Temperature, humidity and air velocity suitable * Packing and containers undamaged, names and safety labeling, handling of the chemicals safe and clean * Sufficient workspace, tools and materials properly located, adjustability of work height and seat, possibility to change work posture 5.2. Manual material handling * No heavy manual lifting, pushing or pulling tasks 5.3. Repetitive work * No repetitive work tasks; work cycle longer than 30 sec Physical variability * Varying physical activities, sitting, standing and moving 6. WALKWAYS: Three observations for walkways coming to the workstation (distance 10 m) 6.1. Design and markings * Walkway wide enough, marked, and pedestrian and vehicle traffic separated when needed 6.2. Order and condition *No unnecessary things on the walkway, the surface not broken or slippery 6.3. Visibility and lighting * Good visibility and sufficient lighting 7. FIRST AID AND FIRE SAFETY: Four items nearest the workstation under observation 7.1. Electric distribution box 7.2. First aid kit 7.3. Fire extinguisher 7.4 Emergency exits Finnish Institute of Occupational Health 2000 * Marked, free space of 0.8 m in front of it * All the necessary first aid supplies are available *Available, easy to access and use * Available, free, markings also in case of power failure Occupational Safety Inspectorate Page 19 of 66

20 ELMERI INDEX COMPANY: SUMMARY OF OBSERVATIONS Finnish Institute of Occupational Health, Occupational Safety Inspectorate Page 20 of 66

21 2.4 Ergonomic Intervention Implementation Each facility with a documented MSD problem job is required to develop and implement a site-specific ergonomics intervention program. An MSD problem job is one identified in Table W-1. At a minimum, the plan shall include: Workplace assessments will be normally performed by the SEQ Group to identify problem jobs using Table W-1. TABLE W-1 Basic Screening Tool Page 21 of 66

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24 Each facility will form an ergonomic task force/team to address the SEQ Group recommendations. The Facility Manager is the final authority on task force assignments. However, a recommended task force/team structure includes: i. Manufacturing/Industrial Engineering ii. iii. iv. Industrial Hygiene Coordinator Union Safety Committee Member or Representative from Hourly Workforce Maintenance Supervisor or Lead Person v. Industrial Nurse (if one on staff) vi. Production Supervisor The ergonomic intervention task force/team structure recommendation is based upon the premise that participatory methods are the best ways to solve problems since knowledge, information, skills and intelligence are distributed among all levels and disciplines within the plant. Line people and line supervisors have relevant skills and information, and their input is required for optimum problem solving and efficient performance. The ergonomic team shall meet at a minimum on a quarterly basis and shall coordinate the plant ergonomic intervention program. Duties of the task force include, but may not be limited to, the following. i. Track injury statistics. ii. iii. iv. Investigate workplace injuries and recommend problem resolution. Follow through on Ergonomic Assessment Recommendation of the SEQ Group. Review all proposed workstations and work procedures for consistency to ergonomic principles during the planning stages of the CEC process. Quarterly ergonomic team meetings may coincide with regularly scheduled meetings at the discretion of the Facility Manager. Medical/Rehabilitation Management As part of the plan, each plant will have in place a medical case management program which will incorporate at least the following key attributes: i. Document all work related injuries and illnesses. a. OSHA recordkeeping requirement or national equivalent. Page 24 of 66

25 b. Maintain a case management log tracking the employees' treatment and rehabilitation progression including weekly follow-ups with the employees health care provider and the employee (i.e., date, name, department, injury class, action, unit and number of days lost). ii. iii. Provide quality medical care as expeditiously as possible. The plant shall encourage our employees to seek care from local practitioners. However, in certain instances, the plant may be required to exercise its right to choose the treating physician and, if required, to select an alternate source in the interest of progressing the rehabilitation process. The plant shall provide wherever possible light or restricted duty assignments for employees undergoing rehabilitation. Every attempt shall be made to provide assignments within the employee's regularly assigned department. However, if this is not feasible, light duty assignments in other departments may occur. Administrative Controls If after all economically feasible engineering changes to tools, equipment, workstations and procedures have not resulted in an acceptable ergonomic risk level for employees, the plant may exercise administrative controls. Administrative controls may mean excluding certain hyper susceptible persons or limiting their time of exposure to particular jobs or activities. Employee Training and Education Training in basic ergonomics is essential if the Corporation is to meet its long-term goals on ergonomic intervention. The ergonomic team shall coordinate a plant-wide training program per SEQ Task force/team members shall have initially a minimum of eight hours training in safety and ergonomics, which will target topics identified by injury surveillance activities. Additional or refresher training shall be conducted as needed. Intervention Hierarchy The plant, in carrying out its ergonomic intervention program, shall apply the following priorities: 1. Eliminate the hazard and/or risk by engineering control. 2. Apply appropriate safeguarding, including administrative controls. 3. Train and instruct in ergonomics. 4. Finally, provide personal protection equipment as a last resort. The SEQ Group and facility taskforce will use the following checklist to document ergonomic stressors. Page 25 of 66

26 Checking and Monitoring. 1. The SEQ Group will validate each facility s ergonomic program through periodic ergonomic program assessment visits and the ISO auditing program. 2. At the facility level, each workplace musculoskeletal disorder injury, including lost time, will be considered a triggering event requiring the evaluation process described on worksheet B. PROCEDURE/PRACTICE WORKSHEET B ERGONOMICS INTERVENTION PLANS (Mandatory) WORKPLACE ASSESSMENT TO IDENTIFY PROBLEM JOBS 1. The SEQ Group and the ergonomic taskforce will use the following protocol in addressing its duties with regard to identifying problem jobs. a. Complete the Job Analysis Checklist for all MSD problem jobs in the facility. b. Jobs that require lifting should be evaluated using the criteria covered in the revised NIOSH Lifting Equation. In cases where the lifting index (weight lifted/recommended weight limit) exceed 3.0 (LI >3.0) the job should be considered of high risk and further assessment to reduce and/or control exposure shall be initiated. 2. Based upon the hazard ranking developed under 1(a) and 1(b) the ergonomics taskforce should set the action agenda for a particular location. Page 26 of 66

27 Date: Facility Name: Workplace Identification Employee Name: Department No: Workcenter Description: Reports To Whom And Job Title: Products/parts Worked On: Shift: Clock No: Machine No: Job Summary: Machinery and Tools/Equipment Used A. Machinery (If available, name, model & serial no.): B. Tools/Equipment Power operated: Manual operated: Job Functions Job Task(s) Task 1: Task 2: Task 3: Task 4: Task 5: Task 6: Task 7: Preparatory/Set-up: Clean-up: % of Time Spent Is This a Cycled Job? Y or N Y or N Y or N Y or N Y or N Y or N Y or N Y or N Y or N Noted Ergonomic Stressors Within Each Job Step (Height, reaches, clearances, posture, motion, force) General Workplace Stressors Page 27 of 66

28 Workplace Characteristics A. Extended reaches, beyond normal arm reach Yes No B. Inadequate clearance for handling or maintenance tasks Yes No C. Inaccessible workplaces for using handling equipment Yes No D. Poor chairs: difficult to adjust, inadequate back support, no footrests Yes No E. Dials and displays that are difficult to read or reach Yes No F. Inefficient work motions because of workplace layout Yes No G. Awkward postures Yes No H. Inadequate space for temporary storage at the workplace Yes No I. No adjustibility built into workplace Yes No Comments: Perceptual Load A. Difficult-to-hear auditory signals Yes No B. Small and difficult-to-see defects Yes No C. Multiple types of defects to detect Yes No D. Fine color differences to be discriminated Yes No E. Need to judge distance rather critically, such as using the high stacking capability on a forklift truck Yes No F. Need to detect defects or information under low light levels Yes No G. Need to discriminate parts by touch Yes No Comments: Mental Load A. Highly complex operations Yes No B. Need to keep track of multiple factors simultaneously Yes No C. Demands for performance in a designated time frame, such as externally paced machine operations Yes No D. Long training times needed Yes No E. Highly repetitive, monotonous unvarying activity Yes No F. Critical tasks that involve high accountability where errors are not tolerated Yes No 5922MF.HB Page 28 of 66

29 Mental Load (Continued) G. Heavy memory (short-term) load, such as working with 9-digit codes Comments: Yes No Environment A. Noise that interferes with conversation or doing the job Yes No B. Noise that is annoying and distracting Yes No C. Vibration that is annoying Yes No D. Temperature/humidity that is frequently uncomfortable or distracting and interferes with the job Yes No E. Poor air circulation Yes No F. Inadequate lighting for the job Yes No G. Glare that interferes with reading or inspecting at the workplace H. Wet locations that may produce electric shock hazards, such as when working with power tools Yes No Yes No I. Floors that are uneven, with drains or pit marks Yes No J. Slippery floors Yes No K. Poor housekeeping, such as crowded aisles or waste on floor Yes No L. Hot surfaces that may increase burn hazards Yes No M. Conditions that require protective clothing in addition to safety glasses Comments: Yes No Displays, Controls and Dials A. Displays that are difficult to read from the operator s usual workplace locations: at the wrong angle, too high or low, too small B. Displays and controls that do not follow population stereo- Yes No types or are not compatible Yes No C. Labeling on control and display panels that is unclear Yes No D. Displays that are not adequately lit Yes No E. Controls that are difficult to distinguish or are not laid out consistently from one work station to another Yes No 5922MF.HB Page 29 of 66

30 Displays, Controls and Dials (Continued) F. Excessive number of controls needed to perform the job Yes No G. Immoderate amount of information to be handled in a short time Comments: Yes No Physical Demands A. Frequent heavy lifting (>18 kg, or 40 lb, 2 hr/day) Yes No B. Occasional very heavy lifting or force exertion (>23 kg, or 50 lb, 225 N, or 50 lbf) Yes No C. Constant handling of materials, little variety Yes No D. Handling difficult-to-grasp items Yes No E. Awkward lifts or carries that are near floor, above the shoulders, or far in front of the body F. Exertion of forces in awkward positions: to the side, overhead, at extended reaches Yes No Yes No G. Constant standing Yes No H. Frequent daily stair or ladder climbing Yes No I. High-precision movements Yes No J. Sudden movements during manual handling Yes No K. Static muscle loading Yes No L. High pressure on the hands from thin edges, such as pail handles or sheet metal edges M. Machine pacing of the handling, such as on and off of conveyors Yes No Yes No N. Use of hand tools that are difficult to grasp Yes No O. Short-duration heavy effort Yes No P. Moderate to heavy effort sustained throughout the shift Yes No Q. Handling oversized objects, including two-person lifting Yes No R. Lack of handling aids, such as drum carts, air hoists, scissors tables Yes No S. Unavailability of help for heavy lifting or exerting forces Yes No Comments: 5922MF.HB Page 30 of 66

31 Other Comments/Observations 5922MF.HB Page 31 of 66

32 LIFTING CRITERIA EQUATION LC x (HM x VM x DM x AM x CM x FM) = RWL LC = LOAD CONSTANT 23 KG (51 LBS.) SIX MULTIPLIERS TO ADJUST FOR NON-IDEAL CONDITIONS. LC = 23 KG (51 LBS.) 1. STANDARD LIFTING LOCATION (A THREE DIMENSIONAL REFERENCE POINT FOR EVALUATING WORKER'S LIFTING POSTURE). OPTIMAL VERTICAL TO START LIFT: 75 CM (30 IN.) OPTIMAL HORIZONTAL: 25 CM LIFTING IN THE MID-SAGITTAL PLANE WITH LOAD CAPACITY SPLIT BETWEEN TWO UPPER EXTREMITIES. 2. LC - BASIS CONSIDERATIONS BIOMECHANICAL - MAXIMUM DISC COMPRESSION: 4.3 KN (770 LBS.) MAXIMUM ENERGY EXPENDITURE: KCAL/MIN. * ENERGY EXPENDITURE (KG/MIN.) LIMIT FOR A SPECIFIC TASK DEPENDS ON THE VERTICAL HIGH AND THE DURATION OF CONTINUOUS LIFTING. DURATION LIFT LOCATION < 1 HR. 1-2 HR. 2-8 HR. V < 75 CM (30 IN.) V > 75 CM (30 IN.) PSYCHOPHYSICAL - MAXIMUM ACCEPTABLE WEIGHT: ACCEPTABLE TO 75% OF FEMALE WORKERS AND 99% OF MALES. Page 32 of 66

33 (HM) = (25 CM) or (10 IN.) (H CM) (H IN.) HORIZONTAL MULTIPLIER: BIOMECHANICAL AND PSYCHOPHYSICAL STUDIES INDICATE THAT WITH INCREASING HORIZONTAL DISTANCE OF THE LOAD FROM THE SPINE, THE PREDICTED DISC COMPRESSION FORCE INCREASES AND THE MAXIMUM ACCEPTABLE WEIGHT LIMIT DECREASES (SNOOK 1978, CHAFFIN AND ANDERSSON 1984, GARG 1986). THE AXIAL COMPRESSION STRESS APPLIED TO THE SPINE DURING LIFTING IS GENERALLY PROPORTIONAL TO THE HORIZONTAL DISTANCE OF THE LOAD FROM THE SPINE. FOR EXAMPLE, BOTH THE LOAD AND THE FLEXION MOMENT (THE PRODUCT OF THE LOAD AND THE HORIZONTAL DISTANCE FROM THE SPINAL AXIS) ARE IMPORTANT IN DETERMINING THE AXIAL COMPRESSION STRESSES ON THE LUMBAR SPINE (SCHULTZ et.al. 1982, CHAFFIN AND ANDERSSON 1984). FURTHERMORE, PSYCHOPHYSICAL DATA CONSISTENTLY INDICATE THAT AS THE LOAD IS MOVED HORIZONTALLY FROM THE SPINE, THE AMOUNT OF WEIGHT A PERSON IS WILLING TO LIFT DECREASES PROPORTIONATELY (SNOOK 1978, AYOUB et.al. 1978, GARG AND BADGER 1986, SNOOK AND CIRIELLO 1991). (VM) = V - 75 or (VM) = V-30 IF V < 30 IN.: (VM) IF V > 30 IN.: (VM) VERTICAL MULTIPLIER: BIOMECHANICAL STUDIES SUGGEST AN INCREASED LUMBAR STRESS FOR LIFTING LOADS NEAR THE FLOOR (CHAFFIN 1969, BEAN et.al. 1988). EPIDEMIOLOGIC STUDIES INDICATE THAT LIFTING FROM NEAR THE FLOOR IS ASSOCIATED WITH A LARGE PERCENTAGE OF LOW BACK INJURIES ATTRIBUTABLE TO LIFTING (SNOOK 1978, PUNNETT et.al. 1991). PHYSIOLOGICAL STUDIES INDICATE THAT LIFTING FROM NEAR THE FLOOR REQUIRES A SIGNIFICANTLY GREATER ENERGY EXPENDITURE THAN LIFTING FROM GREATER HEIGHTS (FREDRICK 1959, GARG et.al. 1978). ALTHOUGH NO DIRECT EMPIRICAL DATA EXISTS TO PROVIDE A SPECIFIC ADJUSTMENT VALUE FOR LIFTING NEAR THE FLOOR, THE 1991 COMMITTEE RECOMMENDED THAT THE VERTICAL FACTOR PROVIDE AT LEAST A 22.5% DECREASE IN THE ALLOWABLE WEIGHT FOR LIFTS ORIGINATING NEAR THE FLOOR. THE RATIONALE FOR REDUCTION OF LOADS TO BE LIFTED ABOVE 75 CM FROM THE FLOOR IS BASED ON EMPIRICAL DATA FROM PSYCHOPHYSICAL STUDIES INDICATING THAT A WORKER'S MAXIMUM ACCEPTABLE WEIGHT OF LIFT DECREASES AS THE VERTICAL HEIGHT OF LIFT (V) INCREASES ABOVE 75 CM (SNOOK 1978, AYOUB et.al. 1978, SNOOK AND CIRIELLO 1991). THE 1991 COMMITTEE CHOSE A DISCOUNT VALUE OF 22.5% TO DECREASE THE ALLOWABLE WEIGHT FOR LIFTS AT SHOULDER LEVEL (150 CM, OR 60 IN.) AND FOR LIFTS AT FLOOR LEVEL, RESULTING IN THE VERTICAL MULTIPLIER. Page 33 of 66

34 (DM) = (4.5 CM) ( D CM) or (DM) = (1.8 IN.) ( D IN.) DISTANCE MULTIPLIER: THE RESULTS OF PSYCHOPHYSICAL STUDIES SUGGEST AN APPROXIMATE 15% DECREASE IN MAXIMUM ACCEPTABLE WEIGHT OF LIFT WHEN THE TOTAL DISTANCE MOVED IS NEAR THE MAXIMUM (e.g., LIFTS ORIGINATING NEAR THE FLOOR AND ENDING ABOVE THE SHOULDER (GARG et.al. 1978, SNOOK 1978, SNOOK AND CIRIELLO 1991). ALSO, RESULTS OF PHYSIOLOGICAL STUDIES INDICATE A SIGNIFICANT INCREASE IN PHYSIOLOGICAL DEMAND AS THE VERTICAL DISTANCE OF THE LIFT INCREASES (AQUILANO 1968, KHALIL et.al. 1985). FINALLY, FOR LIFTS IN WHICH THE TOTAL DISTANCE MOVED IS < 25 CM (< 10 IN.), THE PHYSIOLOGICAL DEMAND IS NOT SIGNIFICANTLY INCREASED, AND THEREFORE THE MULTIPLIER SHOULD BE HELD CONSTANT. AS A RESULT, THE DISTANCE MULTIPLIER (DM) WAS ESTABLISHED BY THE 1991 COMMITTEE. (AM) = (1 - ( A)) ASYMMETRIC MULTIPLIER: TO DATE, ONLY A FEW STUDIES PROVIDE DATA ON THE RELATIONSHIP BETWEEN ASYMMETRIC LIFTING (i.e., LIFTING LOADS AWAY FROM THE SAGITTAL PLANE) TO MAXIMUM ACCEPTABLE LIFTING CAPACITIES. OF THE LIMITED NUMBER OF PSYCHOPHYSICAL STUDIES AVAILABLE, ALL HAVE REPORTED A DECREASE IN MAXIMUM ACCEPTABLE WEIGHT (8% TO 22%) AND A DECREASE IN ISOMETRIC LIFTING STRENGTH (39%) FOR ASYMMETRIC LIFTING TASKS OF 90 DEGREES COMPARED WITH SYMMETRIC LIFTING TASKS (GARG AND BADGER 1986, MITAL AND FARD 1986, GARG AND BANAAG 1988). THE RESULTS FROM BIOMECHANICAL STUDIES ALSO SUPPORT A SIGNIFICANT DECREASE IN THE ALLOWABLE WEIGHT FOR ASYMMETRIC LIFTING JOBS (BEAN et.al. 1988). THEREFORE, THE 1991 COMMITTEE RECOMMENDED THAT THE ASYMMETRIC MULTIPLIER BE ESTABLISHED SO THAT THE ALLOWABLE WEIGHT OF LIFT BE REDUCED BY ABOUT 30% FOR LIFTS INVOLVING ASYMMETRIC TWISTS OF 90 DEGREES. THE ASYMMETRIC MULTIPLIER (AM) WAS ESTABLISHED BY THE 1991 COMMITTEE WHERE A = THE ANGLE BETWEEN THE SAGITTAL PLANE AND THE PLANE OF ASYMMETRY. (THE ASYMMETRY PLANE IS DEFINED AS THE VERTICAL PLANE THAT INTERSECTS THE MIDPOINT BETWEEN THE ANKLES AND THE MIDPOINT BETWEEN THE KNUCKLES AT THE ASYMMETRIC LOCATION.) (CM) = 1.0, 0.95 or 0.90 COUPLING MULTIPLIER: LOADS EQUIPPED WITH APPROPRIATE COUPLINGS OR HANDLES FACILITATE LIFTING AND REDUCE THE POSSIBILITY OF DROPPING THE LOAD. PSYCHOPHYSICAL STUDIES THAT INVESTIGATED THE EFFECTS OF HANDLES ON MAXIMUM ACCEPTABLE WEIGHT OF LIFT SUGGESTED THAT LIFTING CAPACITY WAS DECREASED IN LIFTING TASKS INVOLVING CONTAINERS WITHOUT GOOD HANDLES (GARG AND SAXENA 1980, Page 34 of 66

35 SMITH AND JIANG 1984, DRURY et.al. 1989). ALTHOUGH THESE STUDIES DID NOT AGREE PRECISELY ON THE DEGREE OF REDUCTION IN LIFTING CAPACITY, MOST CONCLUDED THAT THE REDUCTION SHOULD BE IN THE RANGE OF ABOUT 7% TO 11% FOR CONTAINERS WITHOUT HANDLES. THE COUPLING MULTIPLIERS ARE DISPLAYED BELOW. CONSIDERING THE QUALITY OF THE DATA AND THE DIFFICULTY IN JUDGING THE QUALITY OF THE COUPLING, THE CONSENSUS OF THE 1991 COMMITTEE WAS THAT THE PENALTY FOR A POOR COUPLING SHOULD NOT EXCEED 10%. HENCE, THE CONTAINER COUPLING MULTIPLIER (CM) WAS DEFINED. V < 75 CM (30 IN.) V > 75 CM (30 IN.) COUPLINGS COUPLING MULTIPLIERS GOOD FAIR POOR Page 35 of 66

36 FREQUENCY MULTIPLIER: FOR THE 1991 LIFTING EQUATION, THE APPROPRIATE FREQUENCY MULTIPLIER IS OBTAINED FROM A TABLE RATHER THAN FROM A MATHEMATICAL EXPRESSION: FREQUENCY MULTIPLIER (FM) WORK DURATION FREQUENCY < 1 H < 2 H < 8 H LIFTS/MIN. V < 75 V > 75 V < 75 V > 75 V < 75 V > > Note: values of V are in cm; 75 cm - 30 in. LIFTING INDEX = WEIGHT RWL THE LIFTING INDEX (LI) PROVIDES A SIMPLE METHOD FOR COMPARING THE LIFTING DEMANDS ASSOCIATED WITH DIFFERENT LIFTING TASKS IN WHICH THE LOAD WEIGHTS VARY AND THE RECOMMENDED WEIGHT LIMITS (RWL) VARY. IN THEORY, THE MAGNITUDE OF THE LI MAY BE USED AS A GAUGE TO ESTIMATE THE PERCENTAGE OF THE WORK FORCE THAT IS LIKELY TO BE AT RISK FOR DEVELOPING LIFTING RELATED LOW BACK PAIN. THE SHAPE OF THE RISK FUNCTION, HOWEVER, IS NOT KNOWN. THUS IT IS NOT POSSIBLE TO QUANTIFY THE PRECISE DEGREE OF RISK ASSOCIATED WITH INCREMENTS IN THE LIFTING INDEX. IN A SIMILAR MANNER, THERE IS UNCERTAINTY ABOUT WHETHER A LIFTING INDEX OF ONE IS A RELIABLE BOUNDARY FOR DIFFERENTIATING BETWEEN AN INCREASE IN RISK AND NO INCREASE IN RISK FOR SOME FRACTION OF THE WORKING POPULATION. THE PREVIOUS DISCUSSION OF THE CRITERIA UNDERLYING THE LIFTING EQUATION AND OF THE EQUATION MULTIPLIERS HIGHLIGHT THE ASSUMPTIONS AND UNCERTAINTIES IN THE SCIENTIFIC STUDIES AND THE THEORETICAL MODELS WHICH HAVE RELATED LIFTING TO LOW BACK INJURIES. HOWEVER, THESE UNCERTAINTIES DO NOT ALL POINT IN THE SAME DIRECTION. SOME SUPPORT THE BELIEF THAT A LIFTING INDEX OF ONE WILL PLACE A SUBSTANTIAL FRACTION OF THE WORK FORCE AT AN Page 36 of 66

37 INCREASED RISK OF LOW BACK PAIN. OTHERS SUPPORT THE BELIEF THAT MOST OF THE WORK FORCE CAN WORK SAFELY ABOVE A LIFTING INDEX OF ONE. THREE OF THE MOST IMPORTANT LIMITATIONS OF THE EQUATION ARE THE FOLLOWING: (1) A SIGNIFICANT PART OF THE EQUATION IS BASED ON PSYCHOPHYSICAL LABORATORY STUDIES. SINCE THESE DATA ARE OBTAINED FROM WORKERS' JUDGEMENT OF PERCEIVED LIFTING STRESS, PSYCHOPHYSICAL DATA MAY REVEAL MORE ABOUT A WORKER'S TOLERANCE TO STRESS THAN OF IMPENDING LOW BACK PAIN. (2) THE PHYSIOLOGICAL CRITERION IS BASED ON RESTRICTING ENERGY EXPENDITURES TO AVOID WHOLE BODY FATIGUE. THE CRITERION, HOWEVER, DOES NOT ADDRESS THE POTENTIAL RISK ASSOCIATED WITH THE CUMULATIVE EFFECTS OF REPETITIVE LIFTING, WHICH MAY BE INDEPENDENT OF THE LEVEL OF WHOLE BODY FATIGUE. (3) IF THE THREE CRITERIA FOR THE EQUATION WERE CONSIDERED INDIVIDUALLY, THEY WOULD PROBABLY NOT BE PROTECTIVE OF ALL WORKERS. A MAIN TENET OF OUR APPROACH, HOWEVER, IS THAT THE MULTIPLICATIVE NATURE OF THE EQUATION HAS PROVIDED A FINAL EQUATION THAT IS MORE LIKELY TO PROTECT HEALTHY WORKERS THAN EACH INDIVIDUAL CRITERION. SPECIFICALLY, WHEN SEVERAL FACTORS DEVIATE FROM THE IDEAL (i.e., STANDARD LIFT LOCATION), THE DECLINE IN THE PREDICTED VALUE OBTAINED FROM A MULTIPLICATIVE MODEL FOR MOST LIFTS DEPENDS ON THE PRODUCT OF SEVERAL FACTORS; THIS SUBSTANTIALLY REDUCES THE RWL. BASED ON INDIVIDUAL PARAMETERS, THE MULTIPLICATIVE MODEL DEFINES DISCRETE REGIONS WHERE NO LIFTING IS ALLOWED NO MATTER HOW IDEAL THE OTHER PARAMETERS ARE. FOR EXAMPLE, IF THE HORIZONTAL FACTOR EXCEEDS 25 INCHES, THE MULTIPLIER IS ZERO, RESULTING IN A COMPUTED RWL VALUE OF ZERO. THIS MEANS THAT NO WEIGHT SHOULD BE LIFTED FOR THIS TASK CONDITION. DESPITE THE LIMITATIONS OF THE RESEARCH STUDIES AND INHERENT UNCERTAINTIES IN RELYING ON EXPERT JUDGEMENT, IT IS LIKELY THAT LIFTING TASKS WITH A LIFTING INDEX > 1 POSE AN INCREASED RISK FOR LIFTING RELATED LOW BACK PAIN FOR SOME FRACTION OF THE WORK FORCE. THEREFORE, THE LIFTING INDEX MAY BE USED TO IDENTIFY POTENTIALLY HAZARDOUS LIFTING JOBS OR TO COMPARE THE RELATIVE SEVERITY OF TWO JOBS FOR THE PURPOSE OF EVALUATING AND REDESIGNING THEM. Page 37 of 66

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