OSHA 3213 Poultry Processing

8/14/2019 OSHA 3213 Poultry Processing

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GuidelinesforPoultryProcessingOSHA 3213-09N2004

U.S. Department o f Labor

Ergonomicsfor thePrevention of

Musculoskeletal Disorde

www.osha.gov


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OSHAs role is to assure the safety and healthof Americas workers by setting and enforcingstandards; providing training, outreach andeducation; establishing partnerships; andencouraging continual improvement inworkplace safety and health.

U.S. Department of Labor


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Guidelines for Poultry Processing 1


Occupational Safety and Health Administration

OSHA 3213-09N

2004

Guidelines for Poultry Processing

Ergonomics for the Prevention

of M usculoskeletal DisordersU.S. Department of Labor


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2 Guidelines for Poultry Processing

Executive Summary 3

Introduction 4

Ergonomics Process 5

Providing Management Support 5

Involving Employees 5

Providing Training 5

Identifying Problems 7

Implementing Solutions 8

Addressing Reports of Injuries 8

Evaluating Ergonomics Efforts 9

Implementing Solutions 10

Workstations 11

Tools 16

Manual Materials Handling 18

Personal Protective Equipment 21

Additional Sources of Information 22

References 23

Contents


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These guidelines provide recommendationsfor poultry processing facilities to reduce thenumber and severity of work-related musculo-skeletal disorders (MSDs). In preparing these

recommendations, OSHA reviewed existingpractices and programs as well as availablescientific information on ergonomics, andreflected comments received from representa-tives of trade and professional associations,labor organizations, individual firms and otherinterested parties. These guidelines are designedspecifically for the poultry processing industry;however, other industries may find the recom-mendations and solutions presented useful.

More remains to be learned about therelationship between workplace activities and

the development of MSDs. However, OSHAbelieves that the experiences of many poultryprocessing facilities provide a basis for takingaction to better protect workers. As the under-standing of these injuries develops and informa-tion and technology improve, the recommenda-tions made in this document may be modified.

These guidelines are drawn in part fromOSHAsErgonomics Program ManagementGuidelines for Meatpacking Plants (meatpackingguidelines). Employers and employees in thepoultry processing industry have told OSHAthat many of the elements of the meatpackingguidelines have been successfully implemented ina number of poultry processing facilities. Thesestakeholders suggested that this document reflectthe meatpacking guidelines to avoid disruptingthe effective programs employers have already

Executive Summary

implemented. While the two guidelines aresimilar, they also differ in some respects. Thepoultry guidelines include more examples ofpractical ergonomic solutions than the meat-

packing guidelines do, use the terms musculo-skeletal disorder and MSD instead of cumu-lative trauma disorder and CTD, and areformatted to closely resemble OSHAs morerecent ergonomics guidelines.

The heart of these guidelines is the descrip-

tion of various solutions that have been imple-

mented by poultry processors. OSHA recom-

mends that poultry processors consider these

solutions in the context of a systematic process

that includes the elements described in the pages

that follow. Such a process will make it more

likely that the solutions implemented in a partic-ular workplace will be successful in reducing

injuries and will be cost effective.

OSHA recognizes that small employers inparticular may not have or need as comprehen-sive a process as would result from implementa-tion of every action described in this document.OSHA also realizes that many small employersmay need assistance in implementing an appro-priate ergonomics process and wants them toknow that the free OSHA consultation service isavailable to help them with ergonomics andother safety and health issues. The consultationservices are independent of OSHAs enforcementactivity. Information about the OSHA consulta-tion service can be found on OSHAs website atwww.osha.gov.

These guideli nes are advisory in nature and inform ational in content . They are not a new standard orregulation and do not create any new OSHA duties. Under the OSH Act, the extent of an employersobli gation to address ergonom ic hazards is governed by t he general duty clause. 29 U.S.C. 654(a)(1).An employers failure to implement the guidelines is not a violation, or evidence of a violation of thegeneral duty clause. Furtherm ore, the fact that OSHA has developed this docum ent is not evidence ofan employers obligations under the general duty clause; the fact that a measure is recommended inthis document but not adopted by an employer is not evidence of a violation of the general duty clause.In addition, the recommendations contained herein were developed with the idea that they could beadapted to the needs and resources of each individual place of employment. Thus, implementation ofthe guidelines may differ from site to site depending on the circumstances at each particular site.


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In the mid-1980s, the poultry processingindustry began to focus on the problem of work-related musculoskeletal disorders (MSDs). MSDsinclude injury to the nerves, tendons, muscles and

supporting structures of the hands, wrists, elbows,shoulders, neck and low back (1, 2). In 1986,members of the poultry processing industry devel-oped a guideline advocating training, the processof ergonomics and medical intervention as ameans to reduce the occurrence of MSDs andtheir associated costs (3).

In August 1993, OSHA published itsErgonom ics Program Management Guidelines for

Meatpacking Plants (meatpacking guidelines) (4).The meatpacking guidelines specifically recom-

mended that employers implement an ergonomicsprocess to identify and correct ergonomics-relatedproblems in their worksites. While the meatpack-ing guidelines were directed primarily to meat-packing plants, many poultry processing facilitiesinitiated ergonomics programs based upon therecommendations contained in the meatpackingguidelines.

The poultry processing industry has reducedoccupational injuries and illnesses by almost halfover the last 10 years (5). Despite these efforts,MSDs are still prevalent in the poultry processingindustry. According to the Bureau of LaborStatistics, of the 3,000 cases with days away fromwork that occurred in 2002, over 30% (976cases) involved MSDs (6, 7). Many poultry pro-cessing jobs involve physically demanding work.Some poultry workers make over 25,000 cuts perday processing chickens and turkeys.

These processing tasks involve factors, includ-ing repetition, force, awkward and static posturesand vibration, which have been identified asincreasing the risk of incurring injury. Many of

the operations in poultry processing occur with achilled product or in a cold environment. Coldtemperatures in combination with the risk factorsmay also increase the potential for MSDs todevelop (1). Excessive exposure to these riskfactors can lead to MSDs (2).

In these guidelines, we use the term MSD torefer to a variety of injuries and illnesses thatoccur from repeated use or overexertion,including:

Introduction

s Carpal tunnel syndrome;s Tendinitis;s Rotator cuff injuries (a shoulder problem);s Epicondylitis (an elbow problem);s Trigger finger; ands Muscle strains and low back injuries.

Employers should consider an MSD to bework-related if an event or exposure in the workenvironment either caused or contributed to theMSD, or significantly aggravated a pre-existingMSD as required by OSHAs recordkeeping rule(29 CFR 1904). For example, when an employeedevelops carpal tunnel syndrome, the employer

needs to look at the hand activity required for thejob and the amount of time spent doing theactivity. If an employee develops carpal tunnelsyndrome and his or her job requires frequenthand activity, or forceful exertions or sustainedawkward hand positions, then the problem maybe work-related. If the job requires very littlehand activity, then the disorder may not be work-related.

Activities outside of the workplace that involvesubstantial physical demands may also cause or

contribute to MSDs (1). In addition, develop-ment of MSDs may be related to genetic causes,gender, age and other factors (1). Finally, there isevidence that reports of MSDs may be linked tocertain psychosocial factors such as job dissatis-faction, monotonous work and limited jobcontrol (1, 2). These guidelines address onlyphysical factors in the workplace that are relatedto the development of MSDs.

These guidelines present recommendations forthe workplace and work practices with the goalof reducing work-related MSDs. Poultry pro-

cessors can usually meet this goal by changingwork methods, equipment, or workstations.Many changes can be made without significantlyincreasing costs and many ergonomic changesresult in increased efficiency by reducing the timeneeded to perform a task. Many poultryprocessing companies have already institutedprograms that reduce MSDs, reduce workerscompensation costs and improve efficiency (8, 9).


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Ergonomics Process

Many employers in the poultry processingindustry have implemented OSHAs recom-mendations contained in the 1993 meatpackingguidelines. OSHA does not intend for these

guidelines to disrupt the effective programsemployers have established based on thoserecommendations. However, these guidelinesare specifically tailored to poultry processingoperations and update and expand on the meat-packing guidelines while remaining consistentwith them. For example, the ImplementingSolutions section below describes some specificsolutions that poultry processing employers canconsider implementing in their facilities. Thesesolutions reflect the over 10 years of innovation

in poultry processing since the meatpackingguidelines were published. At the same time,these guidelines provide some additional infor-mation that is specifically tailored to the jobsand processes in the poultry processing industry.For example, in the Implementing Solutions sectionbelow, OSHA describes 22 specific solutions thatpoultry pro-cessing employers can considerimplementing in their facilities.

Providing M anagement Support

Strong management support is critical to theeffective implementation of the ergonomicsprocess. OSHA recommends that managementsupport be visible to all employees. In general,management can provide visible support by:

s Consistently communicating the importanceof employee safety and health;

s Assigning and communicating responsibilityfor the various aspects of the ergonomicsprocess to appropriate managers, supervisorsand other employees;

s Committing adequate resources to the ergo-nomics process;

s Integrating production processes and produc-tion improvements with safety and healthconcerns; and

s Ensuring that all managers and employees areaccountable for carrying out their responsi-bilities under the ergonomics process.

The red meat guidelines have been, and continue tobe, a reliable set of tools in [MSD] management. Tyson Foods (10).

The impact of our Ergonomics Program on ourworkforce has been huge. The program has provided

the platform to help us reduce our incident rate andlost time rate over the last three years. ConAgraFoods, Refrigerated Foods Group, Turkey BusinessUni t (11).

Involving Employees

An effective ergonomics process also includesactive employee involvement. Involving em-ployees provides additional problem-solvingcapabilities and hazard identification assistanceto the ergonomics process. Involving employeesin the ergonomics process also leads to greateracceptance when workplace modifications are

made. The following are some ways to involveemployees in the ergonomics process:

s Implement a procedure that encouragesprompt and accurate reporting of MSDs aswell as of their early indications.

s Develop a system to engage employees in thedesign of work, equipment and procedures,the reporting of workplace hazards, andtraining.

s Establish an employee complaint or sugges-tion procedure designed to allow employeesto raise ergonomic issues without fear ofreprisal.

s Request employee feedback on workplacemodifications.

s Form employee groups to identify problems,analyze tasks and recommend solutions.

Providing Training

Training is also an important element of theergonomics process. Training ensures that


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employees are informed about ergonomic con-cerns in the workplace and how to minimize therisk of injury. Training should be provided byindividuals who have experience in ergonomics

in the poultry processing industry. Trainingshould also be provided in a manner and lan-guage that all employees can understand.

OSHA recommends that all employees receivegeneral training on ergonomic issues. This train-ing can be integrated into initial safety and healthtraining. In general, this training should include:

s The procedures for reporting work-relatedinjuries and illnesses as required by OSHAsinjury and illness recording and reportingregulation (29 CFR 1904);

s The companys ergonomics process;s How to identify ergonomic risk factors;s The policies and procedures for avoiding

injury, including proper work practices anduse of equipment;

s How to recognize MSDs and their early indi-cations; and

s The advantages of addressing early indicationsof MSDs before serious injury has developed.

OSHA also recommends that poultryprocessing employees receive job-specifictraining on ergonomic issues. At a minimum,OSHA recommends that the following em-ployees receive such training: employees at riskof injury, supervisors, managers, engineers andmaintenance personnel, as well as health careproviders.

Employees at Risk of Injury

In addition to the general training, OSHArecommends that employees at risk of injuryreceive hands-on ergonomics training prior tobeing placed in a full-time production job. Manypoultry processing facilities already use dedi-cated process lines for the purpose of providinghands-on training to new or reassigned employ-ees. These training lines are an ideal setting toprovide ergonomics training to workers. At aminimum, OSHA recommends that these em-ployees be trained in the following areas:

s Care, use, and handling techniques for knives;s Use of any special tools and devices;s Use of safety equipment, including personal

protective equipment (PPE), as they relate toMSD prevention (such as the proper fit ofgloves); and

s Use of proper lifting techniques and liftingdevices.

Supervisors

In order to effectively manage the ergonomicsprocess and to ensure that all employees arefollowing safe work practices, supervisors shouldreceive the same training as the employees at

risk of injury. OSHA recommends that super-visors receive additional training on how torecognize hazardous work practices, how tocorrect such practices, how to ensure the ergo-nomics process is effectively implemented andhow to track ergonomic corrections. Super-visors should also be instructed on how todetermine if employees need additional train-ing in safe work practices, and how to monitorworkers on restricted duty.

Managers

Managers must be familiar with the ergo-nomics process and their responsibilities in thatprocess. OSHA also recommends that managersreceive sufficient training in the ergonomic issuesassociated with their areas of responsibility, sothat they can effectively implement the ergo-nomics process.

Engineers and Maintenance Personnel

OSHA recommends that these personnel betrained in how to prevent and correct ergonomicproblems through job and workstation designand proper maintenance. OSHA recommendsthat plant engineers and maintenance personnelbe trained in the ergonomic issues associatedwith the tools used in their job tasks.

Health Care Providers

Many poultry processors employ health careproviders to deliver occupational health services.OSHA recommends that these health care


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providers receive training in the prevention,early recognition, evaluation, treatment, andrehabilitation of MSDs. OSHA also recom-mends that these health care providers be

familiar with the various jobs in the poultryprocessing facility so that they are aware of thetypes of ergonomic problems employees mayface when performing certain job tasks.

Identifying Problems

OSHA recommends that poultry processingfacilities establish a three-step process to sys-tematically identify ergonomic problems. Thisprocess should account not only for currentworkplace conditions, but also for planned

changes to existing and new facilities, processes,materials, and equipment. The three-stepprocess for identifying ergonomic problems inpoultry processing facilities includes:

s Gathering information from availablesources;

s Conducting initial workplace surveys todetermine which jobs need a closer analysis;and

s Performing ergonomic job hazard analysesof those workstations with identified riskfactors.

Gathering Information from Available Sources

The first step in identifying ergonomicproblems should be a review and analysis ofavailable information. Information aboutproblems or potential problems can be obtainedfrom a variety of sources, including the OSHA300 and 301 reports, first aid logs, reports ofworkers compensation claims, accident andnear-miss investigation reports and insurance

company reports. Employers can also gainuseful information from employee interviewsand surveys, as well as from reviews andobservations of workplace conditions.

Conducting an Initial Workplace Survey

The second step is to conduct an initial work-place survey. An initial workplace survey istypically performed with an ergonomics check-

list to look for relevant workplace risk factors.According to poultry processing employers (8),the most important risk factors in poultry pro-cessing facilities are:

s Repetition performing the same motion orseries of motions continually or frequently.

s Force the amount of physical effort requiredto perform a task (such as heavy lifting) or tomaintain control of equipment or tools.

s Awkward and static postures assumingpositions that place stress on the body, suchas reaching above shoulder height, kneeling,squatting, leaning over a worktable, twistingthe torso while lifting, as well as holding or

using tools (e.g., knives or scissors) in a non-neutral or fixed position.

s Vibration utilizing hand-held power toolsthat can increase the stress on the hands andarms.

Cold temperatures in combination with theabove risk factors may also increase the poten-tial for MSDs to develop (1). Many of theoperations in poultry processing occur with achilled product or in a cold environment.

Not all of these risk factors will be present in

every job, nor is the existence of one or all ofthese factors necessarily sufficient to cause in-jury. Employers, however, should examine thesefactors when screening and analyzing jobs,operations, or workstations to determine whichrisk factor(s) is present. Jobs and tasks thathave multiple risk factors have a higher proba-bility of causing MSDs (2).

Performing Ergonomic Job Hazard Analyses

The third step is to conduct a job hazard

analysis of those jobs identified above aspotentially hazardous. In many cases, jobassessments can be accomplished by observationand discussing with employees the tasks they areperforming. Discussing tasks with employeeshelps to ensure that a complete picture of theprocess is obtained. An adequate analysisshould identify all risk factors present in eachstudied task (12).


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Implementing Solutions

Examples of potential solutions for variousconcerns are included in the ImplementingSolutions section of these guidelines. Poultryprocessors may need to modify workstations,purchase equipment, and change work practicesto achieve their ergonomic goals. Simple, low-cost solutions are often available to solve prob-lems. For example, carts or cut outs can be usedto reduce exposure to risk factors. Employersshould consider ergonomic issues when design-ing new plants or redesigning existing plants. Atthat time, major changes are easier to implement,and ergonomic design elements can be incorporat-ed at little or no additional cost.

Addressing Reports of Injuries

Even in poultry processing facilities witheffective safety and health programs, injuriesand illnesses may occur. Early reporting, diag-nosis, and intervention can limit injury severity,improve the effectiveness of treatment, minimizethe likelihood of disability or permanent damage,and reduce workers compensation claims (3, 9,12). Many employers have found that earlyreporting, combined with appropriate medical

treatment and/or work restrictions, can helpemployees recover fully without more seriousand costly consequences (3, 9, 10, 12). OSHAsinjury and illness recording and reporting regu-lation (29 CFR 1904) requires employers tokeep records of work-related injuries and ill-nesses. Employees may not be discriminatedagainst for reporting a work-related injury orillness (29 U.S.C. 660(c)).

OSHA recommends that employers implementa process that addresses the following areas:

sInjury and illness recordkeeping. Complete,descriptive, and accurate injury and illnessrecords can be used to identify problem areasand evaluate progress.

sEarly recognition and reporting. Early re-porting of potential MSD problems providesan opportunity to assess possible problemsand take action before injuries and illnessesoccur (3, 10, 12, 13).

s Systematic evaluation and referral. Someemployers have found that a defined processor protocol for evaluating employee reports,providing conservative treatment and work

restrictions, and referring employees formedical attention provides an effective andconsistent approach for minimizing theseverity of MSDs (3, 8, 10, 12).

s Conservative treatment. If provided early inthe development of an MSD, conservativetreatment may eliminate the need for moreinvasive medical procedures. Conservativetreatment may include rest, hot or coldtherapy, nonsteroidal anti-inflammatoryagents, exercise, or night splints, depending

on the nature and severity of the problem (3,10, 13).

s Conservative return to work (restricted duty).Restricted work or light duty are among themost helpful treatments for MSDs. Theseassignments, if properly selected, allow theworker to continue to perform productivework for the employer while continuing toensure recovery. Some MSDs require weeks(or months, in rare cases) of restricted workto allow for complete recovery (3, 10, 12).

s Systematic m onitoring. Systematic follow-upof employee reports provides an opportunityto reinforce good work practices, modifyconservative treatment plans, adjust workrestrictions, or refer the employee for medicalattention (3, 12).

sMedical resources. Employing health careprofessionals, or establishing permanentrelationships with outside health care pro-fessionals, allows the employer to quickly

and effectively respond to employee reports,

Effective medical management, especially earlyintervention, can virtually remove severity in w ork-related [MSDs]. Tyson Foods (10).


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evaluate employees, make referral recommen-dations, provide treatment and monitor therecovery of injured employees (3, 10, 12).

Of these, early reporting of signs and symptomsof MSDs and conservative return to workprograms are particularly important. OSHArecommends employers encourage employees toreport early indications of MSDs before moreserious MSDs develop.

Some poultry processing facilities employ ahealth care professional with training in theprevention and treatment of MSDs to receiveand address reports of injuries. Some of thesefacilities report that they fully integrate thehealth care professional into their ergonomics

efforts. OSHA recommends that these healthcare providers, at a minimum, conduct periodic,systematic workplace walkthroughs to remainknowledgeable about operations and workpractices at the workplace, to identify potentiallight duty jobs and to maintain close contactwith the employees.

Evaluating Ergonomics Efforts

Procedures and mechanisms to evaluate theimplementation of the ergonomics process andto monitor progress are also important. Evalua-tion and follow-up are central to continuousimprovement and long-term success. OSHArecommends that the ergonomics process beregularly evaluated to determine whether it ismeeting its goals and objectives. Such evalua-tions should include input from managers, su-pervisors, and employees who review the goalsand objectives identified, suggest changes in theprogram, and evaluate the effectiveness of imple-mented solutions. Evaluation techniques caninclude methods such as:

s Trend analysis of injury and illness rates andworkers compensation reports;

s Employee surveys and interviews; ands Surveys of job/worksite changes.Any deficiencies identified through the evalua-tion should be addressed.


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The ergonomic solutions for poultry process-ing include engineering changes to workstationsand equipment, work practices, personal protec-

tive equipment (PPE), and administrative actions.The recommended solutions presented in thefollowing pages are not intended to be an exhaust-ive list, nor does OSHA expect that all of themwill be used in any given facility. Poultry pro-cessing facilities are encouraged to develop inno-vative ergonomic solutions that are appropriateto their facilities. As with the meatpackingguidelines, OSHA recommends that employersuse engineering techniques, where feasible, asthe preferred method of dealing with ergonomicproblems in poultry processing facilities. How-ever, OSHA recognizes that a variety of solutionsmay be needed in any given facility.

OSHA recommends that employers trainemployees to use proper work practices. Properwork practices include proper use and mainten-ance of pneumatic and power tools, good cuttingtechniques, proper lifting techniques and goodknife care. Using and maintaining effective PPEis also important. For example, good fittingthermal gloves can help with cold conditions whilemaintaining the ability to grasp items easily.

Many poultry processors have found thatadministrative solutions can be used to reducethe duration, frequency, and degree of exposureto risk factors. Some examples of administrativesolutions used effectively by poultry processorsfollow:

sJob rotation may alleviate physical fatigueand stress of a particular set of muscles andtendons. To set up a job rotation system,employers typically classify the nature andextent of exertions of each task, and then

create a schedule that rotates between highand low repetitions within the line and/orbetween bending and stretching movements inthe same work area or whole plant as appro-priate to reduce exposure. Also consider thebody parts used and rotate so that body partsused repetitively or in awkward postures caneither rest completely or work at slower ratesand in better postures. Use a rotation sched-ule to address tasks considered to be high risk

Implementing Solutions

(e.g., using vibrating hand tools or deboningactivities) or to minimize exposure to cold.

s Staffing floaters provide periodic breaksbetween scheduled breaks.

s New employees, reassigned employees,employees returning from an extended timeoff for vacation or some other purpose inpoultry processing facilities often will need aconditioning, or break-in period to get themaccustomed to an activity and strengthenthem for the physically demanding work theywill be performing. To accommodate this,OSHA recommends that new and reassignedemployees be gradually integrated into a full

workload. OSHA also recommends that em-ployees be assigned to an experienced trainerfor job training and evaluation during theconditioning period.

s Allowing pauses relieves fatigued muscles andallows employees to rest affected muscle groupsduring that time period.

s Cross-train employees so that sufficientsupport is available for peak production, tocover breaks, to institute job enlargement

programs and to provide additional rotationalternatives.

s Performing routine and preventive mainten-ance on equipment assures that the equipmentis working properly.

When combined with exposure to other riskfactors, cold can increase the risk of developingan MSD. Employers typically limit cold expos-ure by providing a warm, dry area and allowingfrequent, short breaks to allow workers to warmup. It is also important to use appropriate cloth-

ing and personal protective equipment whenworking in cold environments.

The solutions on the following pages are notintended to be an exhaustive list, and are onlyexamples of ergonomic solutions. Individualpoultry processing facilities should try to usethese ideas as a starting point as they look forother innovative methods that will meet theirfacilitys needs.


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WORKSTATIONS - Cut Outs

DESCRIPTION:Removal of a section of w ork surface to allow the employee to get closer to

items located at the w orkstation.

WHEN TO USE:Where excessive leaning or reaching is required to access material at aworkstation.

POINTS TO REMEMBER:q Placing i tems closer to the employee minim izes excessive reaching and bending.

Maximum reach should not exceed arms length with the torso upright.q Placing the employee closer to the work through recessed designs at the knee

and foot also reduces reaching and bending.q Providing cutouts can increase the amount of useable space for placement of

poultry parts, tools, supplies and other items.q Ensure that wor kstation edges are rounded to avoid d iscomfort from direct

contact.

WORKSTATIONS - Baggers and Other Packaging Systems

DESCRIPTION:Mechanisms and fixtures used to pl ace whole bir ds or poultr y products intopackaging, and packages into shipping containers.

WHEN TO USE:When packaging, fini shed product.

POINTS TO REMEMBER:q Auto baggers allow whole b irds or parts to slide sideways or vertically into bags.

These systems may automatically count or weigh parts for inventory needs.q Semi-autom ated systems may requir e manual placement of the bag w hile

products drop or slide into the bag, and may use a fan to autom atically open

bags in preparation for l oading.q Filled bags m ay be automatically crim ped or fastened closed.q Many systems are designed to allow employees to alternate hands.q A hoist system i s recomm ended to reload plastic film .q If a hand scoop is used, it should have a bent handle to keep the wrist in a

neutral posture. The handle should be rubber or roughened plastic for easiergrip.

q Packaged meats may be dropped directly into packing boxes and then sentto autopackers for sealing, labeling and palletizing.

WORKSTATIONS - Tilters and Dumpers

DESCRIPTION:Mechanical device that tilts or inverts a container in order to release itscontents.

WHEN TO USE:For unloading the contents of a container into a machine, new container,waste receptacle, or onto a workstation.

POINTS TO REMEMBER:q May elim inate the need for shoveling, especially for i ce.q The position of the tilter o r dum per can be adjusted to mi nim ize bending and

reaching.q Use wheeled carts to tr ansfer containers to t he tilter o r dum per.


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WORKSTATIONS Chutes

DESCRIPTION:Tunnel-type mechanism attached to a hole in the workstation surface into

whi ch poultr y parts or other items can be dropped and transported.

WHEN TO USE:For transport of separated poultry parts or other items. Items may dropdirectly into a container or into a vacuum system for transport.

POINTS TO REMEMBER:q Chute openings should be appropriate to the size of the part handled, so it

does not in terfere with the processing t ask, and does not require extendedreach.

q Delivering and placing parts closer to the employee minimizes excessivereaching and bending. M aximum reach should not exceed arms lengthwith the torso upright.

WORKSTATIONS Diverters

DESCRIPTION:Mechanical device that directs material on a conveyor or slide.

WHEN TO USE:Where excessive leaning or reaching is required to access material on aconveyor or slide.

POINTS TO REMEMBER:q Delivering and placing parts closer to the employee minim izes reaching and

bending. Maxim um r each should no t exceed arms length w ith the tor soupright.

q Can be adjusted to split pou ltry parts delivery ont o either side of a conveyor,slide, or work area so that employees can w ork on bo th sides of the line.

WORKSTATIONS Scales

DESCRIPTION:Embedded scales that incorporate weighing into the production process toeliminate unnecessary handling of poultry, poult ry parts, processed m eats,and waste.

WHEN TO USE:

When operations require that m aterials be weighed.

POINTS TO REMEMBER:q A scale can be recessed into the floor so that carts can be rolled onto it for

weighing without pushing carts uphill.q Locate scales within easy reach, in the wor k area rather than at another

wo rk area behind the empl oyee. Recess the scale to the same height as thecountertop so that poultr y can be placed on and removed from the scalewithout lifting.

q For boxed goods, a scale incorporated into the packing station candetermine weight duri ng initial loading and elimi nate reweighing later.

q Scales can also be incorpor ated into conveyor and shackle systems.


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WORKSTATIONS Shackles

DESCRIPTION:Mechanical devices used to position and stabilize poultry parts for processing

and transporting to other w ork areas.

WHEN TO USE:In all hanging processes.

POINTS TO REMEMBER:q Autom atic rehangers can reduce manual handling associated with hanging

birds.q Provide a rack or other support surface to hold the weight of the bir d so

that the legs can be easily p laced into t he shackles.q Ensure that shackle length can adequately ho ld the bird to m inim ize the

need for rehanging.q Consider a rail or gui de bar behind the birds to mini mize bird m ovement

and reaching by employees.q Orient shackles so employees have direct access with minimal forward

reach and no trunk tw isting, while holdi ng and lifting the bird .q Design the conveyor system to move the legs toward the shackle for easyplacement int o the shackle while supporting the w eight of the bir d.Preferably, the bird and shackles are automatically aligned.

q Provide adequate spacing between shackles to prevent birds from tangling.Adequate spacing of shackles may reduce rework and the need to separatebirds.

WORKSTATIONS - Jigs, Fixtures, Mandrills, and OtherDevices for Positioning Product

DESCRIPTION:Mechanical devices used to position and stabilize poultry parts forprocessing.

WHEN TO USE:In cutting and deboning operations where proper positioning of t he productwill min imize excessive use of force or awkward postures.

POINTS TO REMEMBER:q Design a clamping device to hold the bird s breast securely w hen cutting or

deboning, ensuring that the device does not dam age the product. Once thebird has been stabilized, the employee is able to use a 2-handed method topull meat off the bone. The device may be of m echanical or vacuum design.

q Clamps reduce gripping with the non-cutting hand. Height adjustability

with in the clamp allow s the employee to work without awkward armpostures. Devices should be adjustable to at least 2 different angles toallow an in -line knife to be used w ithout aw kward arm postures.

q For tendon removal, the tip o f the tendon can be placed into a vise thatuses a mechanical arm to pul l and separate it from the meat, leaving t hemeat in good condition. The vise reduces holding and pinching withthe hand.


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WORKSTATIONS - Seats, Stools, and Backrests

DESCRIPTION:Support devices for employees at fix ed wor kstations.

WHEN TO USE:At all stationary sitting and standing positions.

POINTS TO REMEMBER:q Selecting the most approp riate support device promotes neutral body

postures and reduces fatigue during seated, sit/stand and standing tasks.q The use of these devices should not r esult i n extended forw ard reaching,

bending, or trunk twisting.

Recommendations for Chairs:q Chairs with backrests may be provided for tasks that require visual or tactile

inspection as well as other disassembly o r processing tasks. The chairshould be adjustable to accomm odate both the task being perform ed andthe size of the employee.

q

Tall chairs should i nclude a mechanism for mounting and dismoun ting suchas a footring . Prolonged use of a footring m ay obstruct bloodflow to the leg,therefore a footrest should be provided for long duration use.

q Footrest surface area should be deep enough t o support the whole foot andlarge enough to allow some sideward and forward movem ent for positionchanges. Position the footrest to prevent an excessively bent or straightknee postur e. A slight open angle of the knee is preferred. Height adjust-ability of the footrest is preferred. Select an adjustment m echanism thatdoes not result in posture, force, or sanitation problems. Teach employeeswhen and how to make proper adjustments.

q Where height adjustability i s not pr ovided, select at least 2 fixed heightfoo trests to accommodate the smallest height person . Recess the upperfootrest slightly so it does not become an obstacle for the lower footr est.

q Seat pan depth should support the thigh but should not touch the back of theknee.

q Seat angle should support the thigh evenly.q The backrest should be height adjustable and l arge enough to support the

upper and low er back. The shape of the backrest shoul d prov ide suppor t forthe inward curve of the low back.

q Armr ests may int erfere with task requirements. Where used, armrestsshould be adjustable for height and w idth.

Recomm endations for Sit/Stand Stool s:q A high stool or angled seat provides a surface on which the empl oyee can

lean, shift weight, and change trunk angle.q With an angled seat, only leaning can occur. Wi th a flat seat, the emp loyee

may plant one foot on the floor and rest the other thigh on the seat forsupport.

q The base should be fixed so t hat it does not move unin tentionally.

Recomm endations for Backrests or Leaning Devices:q Another type of leaning device is an independent back support wi thout a

seat that is stationary, stable, and height adjustable. It shoul d provideadequate support for both the upper and lower back. Provide clearance forrequired cleaning and sanitation. Many o f the r ecomm endations above alsoapply to backrests or leaning devices.

q Position the device to prevent forward trunk bending.q Ensure clearance behind devices so as not to obstruct passage of other

employees walking past the w orkstation.


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WORKSTATIONS Rework

DESCRIPTION:Designated workstation or work area designed for evisceration and cutting.

WHEN TO USE:For damaged bi rds that require extra handling to remove unw anted parts.

POINTS TO REMEMBER:q Transporting these poultry parts away from the norm al processing line

allows the empl oyee adequate time to closely examine and rem oveunwanted parts without interrupting the line.

q Use pneumatic or m echanical cutting devices where appropri ate to m inim izehand forces.

q The use of fixtures and/or a slightly forw ard slanted table may be appro-priate to position poultry parts so that w ork can be completed using neutralbody postures.

q May be used as an alternative w ork area or part of rotation plan since workis self-paced and slower than conventional assembly lines.

WORKSTATIONS - Workheight and Angle Adjustments

DESCRIPTION:Properly adjusted work surfaces.

WHEN TO USE:At all w orkstations.

POINTS TO REMEMBER:q Proper w orkstation height m inimizes excessive forward trunk bending and lifting

of the arms w hen cleaning, preparing, and packing whole birds and pou ltry parts.q Proper hand height improves comfort and productivity.

Table height recommendations:q For close visual inspection, position table so that hands are slightly hi gher

than elbow height and below shoulder level.q For light assembly (e.g., placing parts in boxes) position table height so that

hands are slightly below elbow height. (Note: Table height may need to belowered further to accomm odate the height of a packing box.)

q For w ork requiring heavy force (e.g., some cutting or deboning), the tableshould be below elbow height, unless close visual inspection i s required.

q Powered adjustable height work surfaces that are positioned for use byindividual employees can be spring-loaded or electrically powered by a motor.

q Tables designed for taller employees should have standing pl atforms orheight adj ustable features to accommodate shorter employees. Teachemployees how and when to adjust height. Provide adjustment controls thatcan be operated wi thout causing a posture, force, or sanitation probl em.

Floor design recommendations:q Provide standing p latforms to prevent reaching above shoulder height.q Provide adequate clearance so emp loyees can take a step sideways along the

conveyor when necessary and so the whole foot is supported w hen placedslightly forw ard or behind the body.

q A railing on the back edge of the platform that is open on bo th ends may beadded to reduce fall hazards. Provide a platform depth that allow s unob-structed passage behind employees when they are at their wor kstations.

q Provide non-slip floor ing in areas that become w et or soiled wit h animal fat.q Use perforated rather than slatted flooring where possible. Where slats are

used, they should be fl at and wi de to m inim ize pressure points on the feet.q Non-slip anti-fatigue mats that can be easily removed for cleaning may be

added to solid floo r for comfort.


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TOOLS - Handle and Design

DESCRIPTION:

Designs that mini mize exposure to risk factors when using hand tools.

WHEN TO USE:For all hand tool applications.

POINTS TO REMEMBER:q Handles should be perpendicular to the l ine of action, of adequate diameter

to allow a power gri p, extend at least the length of the palm, and have a non-slip surface.

q Angled and pistol gri p handles are advised for cuts made wit h a downw ardstroke. These knives may not be w idely used, however they keep the w rist inneutral while allow ing for sufficient downw ard force to make a smoot h cut.

q Inline handles are best for horizontal cuts (e.g., when parts are resting flat ona tabletop).

Temperature and vibration:q Handles should help prevent transmission of cold from the tool to t he hand

and should work well w hen wet or covered with slippery material.q Dead blow hammers partially filled w ith shot reduce repercussion into the hand.

Handle dimensions:q Tools should com fortably fit the employees hand (not too wide or too

narrow).q Length should be slightly longer than the palm with or w ithout gloves.

Handle op tions:q Heavy tools should have 2 handles or be suspended or counterbalanced.q A wraparound handle allow s the tool to stay on the hand with m inim al effort.q A handle guard may be added to certain tool s to prevent the hand from

slipping forw ard onto the blade.

Reducing force:q Keep finger pinch to a min imum , especially for repetitive work.q Textured handles improve grip, reduce hand for ce and should be w ashable in

warm water to remove grease build-up.q Avoid concentrated pressure on small parts of the fingers (e.g., forceful

opening of scissors) or on the palm of the hand.

TOOLS - Spray Nozzles

DESCRIPTION:Designs that m inim ize hand f orce.

WHEN TO USE:

For all sanitation operations using spray nozzles for long tim e periods.

POINTS TO REMEMBER:q Avoid single finger activation, especially using the index finger.q Investigate options for hand actuators that are compatible w ith t he shape,

widt h, and size of the hand.q Provide swivel handles for hoses such as those used for water.q Provide pistol grip handles for spraying h igh-pressure hoses.q Use the entire finger rather than just the fingertip to activate the trigger,

minimizing tendon irritation.q Consider systems that can be activated by either the hand or foot so the

employee can switch at w ill w hen fatigue occurs.


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TOOLS Selection

DESCRIPTION:

Powered and m anual tools for cutting, deboning and ot her operations.

WHEN TO USE:For nearly all t asks in pou ltry processing, including evisceration, venting,deboning, fi lleting, peeling gizzards, and separation o f in ternal organs.

POINTS TO REMEMBER:q Hand too ls should be selected so that handle angle allows the w rist to w ork in

a neutral posture.q The addition of a universal joint between handle and blade may improve wr ist

posture.q Spring-loaded handles elim inate thumb f orce required to open blades for

sequential cuts.q Spring force should be designed to min imi ze hand fatigue.q A circular or electric saw is effective for cutting whole birds and breasts in half.q Powered (pneumatic) or spring-loaded shears and pneum atic wheels with

blades or m anual knives are preferred for cutting smaller parts (e.g., trimm ingand eviscerating).

q Shears are preferred for heart and l iver rem oval.q Knives are preferred for deboning and fil leting.q A specialized tool has been developed for cleaning gizzards (a powered hand-

held device with a small bladed wheel).q An inli ne thigh popper reduces required hand forces when compared to the

traditional m anual technique.

TOOLS - Use and Care of Knives, Saws, and Scissors

DESCRIPTION:Procedures for maintaining knives, saws, and scissors in optim al functioning

condition.

WHEN TO USE:For all kni fe, saw, and scissors use.

POINTS TO REMEMBER:q The sharper the edge, the low er the force (and possibly repetitions) required

to complete the task. Sharpening blades is a highly skilled task that requiresspecialized training and is usually com pleted away from the production area.Options for maintaining a sharp edge include having several knives assignedto an em ployee, trading out knives quickly and easily, and keeping the bladefree of metal fragments or burrs.

q Keeping the b lade free of m etal fragments or burrs requires constantattention. Employees may be taught to manually steel or use a mousetrapfor deburring or remov ing m etal fragments. These fragments make it harderto cut product and may even cause damage. Both methods of deburringrequire running the full length of the blade edge along a honing stone orother file-type m echanism. Manual steeling is a tw o-handed operationrequiring the empl oyee to hold the honing m echanism in one hand and knifein the other, both unsupported. A customized tool can be developed that hasone straight handle and tw o in-line steels positioned to ensure that the knifecontacts both steels evenly. The mousetrap (wit h attached hon ingmechanism) is fi xed to a stationary surface (such as a table or rail ) orportabl e surface (such as a scabbord) and requ ires only a one-handedoperation.

q Deburr or change knives if product damage becomes apparent, an increasein m uscle force is required, or if t he blade contacts bone, glove, or other hardobjects.


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MANUAL MATERIALS HANDLING - Hoppers and Augers

DESCRIPTION:Container used to hold and dispense contents into a machine, a new container,

or ont o a w orkstation t hrough an open gate or using a screw-type mechanism.

WHEN TO USE:When storage of product or other items is required at a workstation.

POINTS TO REMEMBER:q Hoppers are generally preferred for dispensing larger objects such as poultry

parts, whereas augers are generally preferred for smaller product such as ice,spices, and tenderizers in predetermined quantity to m atch recipe or packagingunits.

q Hoppers are loaded from the top of the uni t and have a gate to drop contentsin bulk or pre-measured quantities, whereas augers have screw-type mecha-nisms that lift smaller particles from a transport container and di spense inpre-measured quantities.

q Operation can be automatic or employee initiated with activation controlslocated to avoid reaching and bending.

q May replace the need for shoveling, especially fo r ice.q To load hoppers and avoid additi onal li fting, consider devices such as mechanical

lifters, dumpers, augers, and conveyors.

MANUAL MATERIALS HANDLING - Carts and Hand Trucks

DESCRIPTION:Wheeled devices designed to transport materials.

WHEN TO USE:For transporting containers of whole birds, bird parts, processed meats, wasteproducts, or suppli es between wor k areas.

POINTS TO REMEMBER:q

A small lip around the edges is helpful to prevent items from slipping off.q Ensure that the top stack height does not obstruct vision.q Optimal shelf height range should be between knuckle (with arms at side) and

shoulder height.q Pushing is preferred to pulling.q Balance loads and keep loads within manufacturer s weight restrictions.q Handles that are vertical, with some horizontal adjustability, will allow all

employees to push with hands at elbow height and shoulder width apart.A swing-out design may be useful to improve access.

q Manually pushed carts and hand trucks should have full bearing wheels made ofa material designed fo r the floor surface in the facility as well as brakes that areeasy to operate. Brakes prevent unin tentional movement of the cart or handtruck when left unattended or when loading. Larger wheels are generally easierto push. Rear swivel and front fixed wheel design improves ease of pushing,especially if the cart is long . In some designs, a third set of non-swi vel wheels isplaced centrally to add stability and improve ease of turning.

q Carts may be designed for general use or for specialized applications. Specialtycarts that have contours or clamps to hold specific supplies (e.g., rolls of plastic)may be designed to aid in supply transfer directly to the m achine or work surfacethat uses that product.

q Large bucket-type containers on carts should have an angled f ront to allowtipping for removal of contents (e.g., utility tilt trucks).

q Lift tables and height adjustable pallet stands that rotate allow parts and suppliesto be positioned at proper working heights. They may be used in conjunctionwith staging for vacuum systems and a variety of other workstations. Thesedevices improve working posture by reducing unnecessary bending andreaching.

q Pallet jacks may be manual or motor ized. The motorized version is preferred forfrequent or long-distance travel.


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MANUAL MATERIALS HANDLING - Racks and Shelves

DESCRIPTION:Rack and shelf design to opti mi ze manual access.

WHEN TO USE:Shelf systems can be configured to minimize excessive lifting, carrying, andawkward postures associated with storage of any item used or produced at aworkstation.

POINTS TO REMEMBER:q For items that w ill be m anually lifted, shelf height should be from approximately

knuckle (with arms at side) to shoulder height. Store heavy and frequently useditems in thi s range. Storage of lightw eight and infrequently used items aboveand below this range is acceptable. Labels on shelves may help to quickly andeasily identify materials to be lifted or carried.

q Bulk packages of suppl ies that are transported by mechanical devices can bestacked and stored as needed. However, once packages are opened andremoved manually, placement on shelves should follow the recommendationslisted above.

q Avoid closely spaced shelves as they lim it vi sual and hand access.

MANUAL MATERIALS HANDLING - Vacuum Systems

DESCRIPTION:Vacuum systems for lifting and transport of materials.

WHEN TO USE:Vacuum systems can be used for lifting and transporting poultry parts, boxes ofproduct, spice bags, ice, and other materials. Appl ications of vacuum systemsinclude:q Lifting of individual boxes and placement onto racks or pallets for storage or

transport.q Vacuum systems connected to chutes or transport tubes can transport individual

poultry parts or collect poultry parts in a container.

POINTS TO REMEMBER:q Vacuum entry points can be placed at individual work areas to gather product for

transport to chillers or other holding areas for further processing or packaging.q Vacuum systems can be designed specifically to handle internal transport of

hearts, livers, gizzards, and necks from harvesting area to giblet handling area.


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MANUAL MATERIALS HANDLING - Roller Tables

DESCRIPTION:Tabletop or w ork surface embedded wit h roll ers or ball bearings to r educefriction and force when sliding items.

WHEN TO USE:Recomm ended for transporting box es, bins, and ot her containers overrelatively short distances.

POINTS TO REMEMBER:q Rollers are preferred for tr ansport in a li near direction w hereas ball bearings

are preferred w hen change of direction is required.q Pushing or sliding containers eliminates lifting and carrying t hat can be

strenuous to the hands, arms, and back.q Appropr iate for product in containers, but not loose parts due to sanitation

issues.

DESCRIPTION:Mechanical systems such as belt-driven sheets of textured fabric or suspendedshackles/hooks that continually move product.

WHEN TO USE:For pr ocessing and cutting tasks, placing bags and smaller packages in boxes,and loading or unl oading trucks. Elim inates lifting and carrying when trans-porting whol e birds and parts through and between processing areas.

POINTS TO REMEMBER:q Ensure that required f orward reach does not extend beyond arm s length in

front of the body.q Overhead conveyors should be designed so that the employee can grasp

birds w ithout reaching higher t han mi d-chest level. This can be accomplishedby low ering the line or p roviding access for employees at their work area.

q Belt conveyors should be installed so that emp loyees can grasp birds or birdparts while keeping their elbow s close to the tor so. The conveyor speedshould allow sufficient tim e for the task being perform ed.

q Conveyors can be designed to reorient birds or bird parts.

MANUAL MATERIALS HANDLING - Belt and Overhead Conveyors


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PERSONAL PROTECTIVE EQUIPMENT - SelectionConsiderations

DESCRIPTION:Clothing and other work accessories designed to create a barrier against

workplace hazards that take ergonomic considerations into account.

WHEN TO USE:When selecting personal pr otective equipment fo r processing operations.

POINTS TO REMEMBER:q Protective clothing should be selected for the specific task performed.q Employees should be provided wi th a variety of options for rubber gloves

wor n under mesh gloves for optim al fit, dexterity, and flexibili ty.q Mesh gloves can include small barbs on the palm surface to r educe finger

force when pinching and pulling meat away from bone. A mesh or cutresistant glove and for earm sleeve should be w orn on the hand that does nothold the knife to protect against accidental cuts.

q Gloves should min imi ze the loss of tactile sensitivity.q Gloves should provide i ncreased friction betw een the hand and t he material

being handled.q Use non-slip and w aterproof footw ear with w ell-cushioned insteps and

insoles.


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OSHAs Training Institute in Arlington Heights,Illinois, offers courses on various safety and healthtopics, including ergonomics. Courses are also

offered through Training Institute EducationCenters located throughout the country. For aschedule of courses, contact the OSHA TrainingInstitute, 2020 South Arlington Heights Road,Arlington Heights, IL 60005, (847) 297-4810, orvisit OSHAs training resources webpage atwww.osha.gov/fso/ote/training/training_resources.html.

There are many states and territories thatoperate their own occupational safety and healthprograms under a plan approved by OSHA (23cover both private sector, state and local govern-ment employees, and three only cover public em-ployees). Information is available on OSHAswebsite at www.osha.gov/fso/osp/index.html onhow to contact a state plan directly for information

about specific state initiatives and complianceassistance applicable to the poultry processingindustry.

A free consultation service is available to pro-vide occupational safety and health assistance tosmall businesses. OSHA Consultation is fundedprimarily by federal OSHA, but delivered by the50 state governments, the District of Columbia,Guam, Puerto Rico and the Virgin Islands. Thestates offer the expertise of highly qualifiedoccupational safety and health professionals toemployers who request help to establish andmaintain a safe and healthful workplace. Devel-oped for small and medium-sized employers inhazardous industries or with hazardous opera-tions, the service is provided at no cost to theemployer and is confidential. Informationon OSHA Consultation can be found atwww.osha.gov/dcsp/smallbusiness/consult.html.

Additional Sources of Information


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References

(1) National Research Council and Instituteof Medicine. 2001. Musculoskeletal Disordersand the Workplace Low Back and Upper

Extremities. National Academy of Sciences.

Washington, DC: National Academies Press.

(2) Musculoskeletal Disorders and WorkplaceFactors: A Critical Review of Epidemiologic

Evidence for Work-Related Musculoskeletal

Disorders of the N eck , Upper Ex tremity, and

Low Back. Cincinnati, OH: U.S. Departmentof Health and Human Services, Public HealthService, Centers for Disease Control andPrevention, National Institute for OccupationalSafety and Health, DHHS. 1997. (NIOSH

Publication No. 97-141.)

(3) Poultry Industry Task Force. 1986. TheMedical Ergonomics Training Program: A Guidefor the Poultry Industry. (OSHA DocketGE2003-2, Exhibit 4-2.)

(4) U.S. Department of Labor, OccupationalSafety and Health Administration. 1993(Reprinted). Ergonomics Program ManagementGuidelines for Meatpacking Plants.

(5) Bureau of Labor Statistics. 2002. http://data.bls.gov/cgi-bin/dsrv?sh. Occupationalinjuries and illnesses: industry data (1989-2001).Series ID SHU30201531 and SHU30201532,Poultry slaughtering and processing. (OSHADocket GE2003-2, Exhibit 4-8.)

(6) Bureau of Labor Statistics. http://www.bls.gov/iif/oshsum.htm#01SummaryTables. Table 2.Numbers of nonfatal occupational injuries andillnesses by industry and case types, 2002. (OSHA

Docket GE2003-2, Exhibit 4-10.)

(7) Bureau of Labor Statistics. Special reportprepared by BLS for OSHA. Table 1. Number,median days, and incidence rate of nonfataloccupational injuries and illnesses with days

away from work involving musculoskeletaldisorders by selected industries, 2002. (OSHADocket GE2003-2, Exhibit 4-9.)

(8) Reports of OSHA site visits to poultryprocessing facilities. (OSHA Docket GE2003-2,Exhibit 4-5.)

(9) Jones, Ronald J. Corporate ErgonomicsProgram of a Large Poultry Processor. AIHAJournal (58). February 1997.

(10) Document submitted to OSHA by TysonFoods. (OSHA Docket GE2003-2, Exhibit 4-6.)

(11) Document submitted to OSHA by ConAgraTurkey Company (Butterball). (OSHA DocketGE2003-2, Exhibit 4-7.)

(12)Elements of Ergonomics Programs: APrimer Based on Evaluations of Musculoskeletal

Disorders. Cincinnati, OH: U.S. Department ofHealth and Human Services, Public HealthService, Centers for Disease Control andPrevention, National Institute for OccupationalSafety and Health, DHHS. 1997. (NIOSHPublication No. 97-117).

(13) Kaplan, S.J., Glickel, S.Z., Eaton, R.G.Predictive Factors in the Non-SurgicalTreatment of Carpal Tunnel Syndrome. TheJournal of H and Surgery. February 1990. Vol.15-B, No. 1.


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www.osha.gov


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Documents

OSHA 3213 Poultry Processing