Prevention Of Musculoskeletal Injuries In Poultry Processing

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Prevention of MusculoskeletalInjuries in Poultry ProcessingOSHA 3213-12R 2013

Occupational Safety and Health Act of 1970“To assure safe and healthful working conditions forworking men and women; by authorizing enforcementof the standards developed under the Act; by assistingand encouraging the States in their efforts to assuresafe and healthful working conditions; by providing forresearch, information, education, and training in the fieldof occupational safety and health.”Material contained in this publication is in the publicdomain and may be reproduced, fully or partially, withoutpermission. Source credit is requested but not required.This information will be made available to sensoryimpaired individuals upon request.Voice phone: (202) 693-1999;teletypewriter (TTY) number: 1-877-889-5627.This publication provides a general overview of a particularstandards-related topic. This publication does not alter ordetermine compliance responsibilities which are set forthin OSHA standards, and the Occupational Safety and HealthAct. Moreover, because interpretations and enforcementpolicy may change over time, for additional guidance onOSHA compliance requirements, the reader should consultcurrent administrative interpretations and decisions by theOccupational Safety and Health Review Commission andthe courts.This guidance document is not a standard or regulation, and it creates no new legal obligations. It containsrecommendations as well as descriptions of mandatory safety and health standards. The recommendationsare advisory in nature, informational in content, and are intended to assist employers in providing a safeand healthful workplace. The Occupational Safety and Health Act requires employers to comply withsafety and health standards and regulations promulgated by OSHA or by a state with an OSHA-approvedstate plan. In addition, the Act’s General Duty Clause, Section 5(a)(1), requires employers to provide theiremployees with a workplace free from recognized hazards likely to cause death or serious physical harm.Cover photo courtesy of National Chicken Council

Prevention of MusculoskeletalInjuries in Poultry ProcessingOccupational Safety and Health AdministrationU.S. Department of LaborOSHA 3213-12R 2013

TABLE OF CONTENTSForeword. 1Introduction. 2A Process for Protecting Workers . 3Provide Management Support. 3Involve Workers. 3Provide Training. 4Identify Problems . 5Encourage and Utilize Early Reports of Injuries. 6Implement Solutions . 7Evaluate Progress. 8Engineering Solutions. 9Additional Sources of Information. 26References. 26Workers’ Rights. 28OSHA Assistance, Services and Programs. 28Establishing an Injury and Illness Prevention Program. 28Compliance Assistance Specialists. 28Free On-site Safety and Health Consultation Services for Small Business.28Cooperative Programs. 29Occupational Safety and Health Training. 29OSHA Educational Materials. 29NIOSH Health Hazard Evaluation Program. 30Getting Help with Health Hazards. 30OSHA Regional Offices. 31How to Contact OSHA. 32

viOCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

FOREWORDOriginally published in 2004, these updatedguidelines provide recommendations for poultryprocessing facilities to reduce the numberand severity of work-related musculoskeletaldisorders (MSDs). In preparing the followingrecommendations, OSHA reviewed existingpractices and programs as well as availablescientific information on ergonomic-related riskfactors in poultry processing facilities. OSHA’sguidelines are designed specifically for the poultryprocessing industry; however, other industriesmay find the recommendations and solutionspresented useful.The heart of these guidelines is the processfor protecting workers and the description ofvarious solutions that have been implementedby poultry processors. OSHA recommends thatpoultry processors consider these solutions in thecontext of a systematic process that includes theelements described in the pages that follow.OSHA recognizes that small employers in particularmay not have or need as comprehensive a processas would result from implementation of every actiondescribed in this document. The agency also realizesthat many small employers may need assistancein implementing an appropriate process to preventMSDs. OSHA provides free consultation servicesto help small employers with ergonomics andother safety and health issues. These consultationservices are independent of OSHA’s enforcementactivity. Information can be found in the back ofthese guidelines and on the OSHA Consultation webpage at www.osha.gov/consultation.PREVENTION OF MUSCULOSKELETAL INJURIES IN POULTRY PROCESSING1

INTRODUCTIONIn the mid-1980s, the poultry processing industrybegan to focus on the problem of work-relatedmusculoskeletal disorders (MSDs). MSDsinclude injury to the nerves, tendons, musclesand supporting structures of the hands, wrists,elbows, shoulders, neck and low back (1, 2). In1986, members of the poultry processing industrydeveloped a guideline advocating training,identifying ergonomic hazards, and developingsolutions to reduce ergonomic risk factors andearly medical intervention as a means to reducethe occurrence of MSDs and their associatedcosts (3).In August 1993, OSHA published its ErgonomicsProgram Management Guidelines forMeatpacking Plants [meatpacking guidelines](4). The meatpacking guidelines specificallyrecommended that employers implement anergonomics process to identify and correctergonomics-related problems in their worksites.Then in 2004, OSHA published the first versionof these guidelines, Guidelines for PoultryProcessing — Ergonomics for the Prevention ofMusculoskeletal Disorders.MSDs continue to be common among workersin the poultry processing industry. In fact, theincidence rate of occupational illness casesreported in this industry in 2011 and 2012 hasremained high at more than five times the averagefor all U.S. industries (5). The rate in poultryplants of one musculoskeletal disorder, carpaltunnel syndrome, was more than three timesthe national average in 2012 and seven timesthe national average in 2011 (6). Poultry industryemployers were also more than three times in2012 and almost six times in 2011 more likely toidentify repetitive motion as the exposure resultingin a serious injury compared to employers in allindustries (6). According to the Bureau of LaborStatistics, of the total 3,620 occupational injuryand illness cases requiring days away from workthat were reported among workers in the poultryprocessing industry in 2011 and 2012, 33% (1,190cases) were MSDs (7).2Many poultry processing jobs are physicallydemanding and involve factors that increase therisk of developing an MSD. These factors includerepetition, force, awkward and static postures,and vibration (8). In addition, many operations inpoultry processing occur with a chilled productor in a cold environment. Cold temperatures incombination with these ergonomic risk factorsincrease the potential for MSDs to develop (1).In these guidelines, we use the term MSD to referto a variety of injuries and illnesses that occur fromrepeated use or overexertion, including: Carpal tunnel syndrome;Tendinitis;Rotator cuff injuries (a shoulder problem);Epicondylitis (an elbow problem);Trigger finger; andMuscle strains and low back injuries.Studies published in the scientific literatureand research reports also confirm experiencesdocumented in the poultry industry. A recentstudy of poultry plant workers reported that theprevalence of carpal tunnel syndrome was 2.5times higher in poultry workers than in non-poultrymanual laborers (9). The authors found that poultryworkers who performed tasks requiring the mostrepetitive hand manipulation (cutting, eviscerating,washing, trimming, deboning, and multiple tasks)had a higher rate of carpal tunnel syndrome thanthose performing other tasks along the productionline (packing, sanitation, chilling, and others).NIOSH scientists have conducted several HealthHazard Evaluations (HHEs) that looked at theergonomic-related risk factors in poultry processingplants. Five HHEs have focused on ergonomicfactors and MSDs. At a turkey processing plant,NIOSH investigators found that workers employedin jobs requiring faster repetitions had a higherincidence of MSDs than those doing slower jobs(10). Similarly, at another poultry plant, NIOSHreported a higher incidence of MSDs, particularlyin the deboning department which had the highestworker exposure to repetitive and forceful handwrist motion (11). In a more recent evaluation ofMSDs in employees at a poultry processing plant inSouth Carolina, NIOSH scientists performed nerveOCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

conduction testing on employees to evaluate theirmedian nerve function in the hands and wrists. Theresearchers also conducted a job hazard analysesand collected information from employees byquestionnaire. NIOSH found that 42% of employeeswho worked on the production line and whoparticipated in the study had evidence of carpaltunnel syndrome. Carpal tunnel syndrome wasdefined by decrements in nerve conduction andhand and wrist symptoms (8).Employers should consider an MSD to be workrelated if an event or exposure in the workenvironment either caused or contributed to theMSD, or significantly aggravated a pre-existing MSDas required by OSHA’s recordkeeping rule. For moreinformation, see OSHA’s recordkeeping web pageat www.osha.gov/recordkeeping.These guidelines present recommendations forthe workplace with the goal of reducing workrelated MSDs. Poultry processing companies thathave already instituted processes that reduce riskfactors for MSDs have found that these changesresulted in savings by lowering injury and illnessrates, reducing workers’ compensation costs, andimproving efficiency (12, 13).A PROCESS FOR PROTECTINGWORKERSThese guidelines are specifically designed forpoultry processing operations and update OSHA’searlier poultry processing guidelines.While poultry processing facilities vary, an effectiveprocess to prevent MSDs among poultry plantworkers generally includes all the critical elementslisted below (management support, employeeinvolvement, effective training, periodic review ofinjury and illness reports to help identify problems,encouraging and utilizing early reports of injuries,implementing effective solutions, and evaluatingprogress) and can be tailored to an individualprocessing facility’s operations. OSHA recommendsthat employers develop a process to systematicallyaddress ergonomics-related risk factors in theirwork environments and incorporate them into theirexisting safety and health programs.Provide Management SupportA strong management commitment is critical tothe effective implementation of the ergonomicsprocess. OSHA recommends that managementsupport be visible to all workers. Management canprovide visible support by: Consistently communicating the importance ofworker safety and health;Assigning and communicating responsibility forthe various aspects of the ergonomics processto appropriate managers, supervisors and otheremployees;Committing adequate resources to theergonomics process;Integrating safety and health concernsinto production processes and productionimprovements; andEnsuring compliance with the OSH Act’sprohibition on retaliating against workers whoreport work-related injuries and illnesses.Involve WorkersAn effective ergonomics process also includesactive employee involvement. Involvingworkers improves problem-solving and hazardidentification capabilities for the ergonomicsprocess. Involving employees in the ergonomicsprocess also leads to greater acceptance whenworkplace modifications are proposed andimplemented. The following are some ways toinvolve workers in the ergonomics process: Regularly communicate with employees abouteffective workplace practices and provideemployees with information relevant to theergonomic process;Implement a procedure that encourages earlyreporting of symptoms of MSDs without fearof reprisal;Develop a system to engage employees in thedesign of work, equipment and procedures, thereporting of workplace hazards, and training;Establish an employee complaint or suggestionprocedure designed to allow employees to raiseergonomic issues without fear of reprisal;Request employee feedback on workplacemodifications;PREVENTION OF MUSCULOSKELETAL INJURIES IN POULTRY PROCESSING3

Form employee groups to help identifyproblems, analyze tasks and recommendsolutions; andAssure that no employee is retaliated againstfor exercising his or her rights under OSHAlaw, including reporting a potential hazard,symptoms or work-related injury.At a minimum, OSHA recommends that theseemployees be trained in the following areas: Provide TrainingTraining is also an important element of theergonomics process. Effective training ensuresthat all employees, including contract andtemporary workers, are aware of ergonomicsand its benefits, are able to identify ergonomicsrelated concerns in the workplace, are taught howto minimize the risk of injury, and understandthe importance of reporting early symptoms ofmusculoskeletal disorders (14). Training should beprovided by individuals who have experience inergonomics in the poultry processing industry andshould also be provided in a manner and languagethat all workers can understand.All Employees TrainingOSHA recommends that all employees receivegeneral awareness training on ergonomic issues.This training can be integrated into initial safetyand health training. When training is effective theworkers will: Learn the proper use of equipment, tools, andmachine controls;Recognize early symptoms of MSDs and theimportance of early reporting ;Learn the procedures for reporting work-relatedinjuries and illnesses as required by OSHA’sinjury and illness recording and reportingregulation at www.osha.gov/recordkeeping;Learn about the company’s ergonomics process;Learn how to identify ergonomic risk factors; andLearn the process for reporting ergonomicconcerns and providing feedback to theemployer.OSHA also recommends that poultry processingemployees — including all production workers,supervisors and managers, engineers andmaintenance personnel, as well as health-careproviders — receive job-specific training onpreventing MSDs.4 Proper care, use, sharpening and handlingtechniques for knives and scissors;Use of any special tools and devices;Use of safety equipment, including personalprotective equipment (PPE), as it relates to MSDprevention (such as the proper fit of gloves);Use of proper lifting techniques and liftingdevices; andUse of ergonomic stands and platforms.Managers and SupervisorsManagers and supervisors should be familiar withthe ergonomics process, the importance of earlyreporting of MSDs and their responsibilities in thatprocess. OSHA also recommends that managersreceive sufficient training in the ergonomic issuesassociated with their areas of responsibility, so thatthey can effectively implement the ergonomicsprocess. Supervisors should also receive trainingon the OSH Act’s prohibition against retaliatingagainst workers who report work-related injuriesand illnesses.Engineers and Maintenance PersonnelOSHA recommends that engineers andmaintenance personnel be trained in how to preventand correct ergonomic problems through proper joband workstation design and proper maintenance.OSHA also recommends that plant engineers andmaintenance personnel be trained in the ergonomicprinciples associated with the tasks the employeesdo and tools they use on the job.Healthcare ProvidersMany poultry processors employ healthcarestaff to deliver occupational health services.OSHA recommends that these healthcareproviders receive training in the prevention,early recognition, evaluation, treatment, andrehabilitation of MSDs. OSHA also recommendsthat these healthcare providers be familiar withthe various jobs in the poultry processing facilityso that they are aware of the types of ergonomicrelated risks workers may face when performingcertain job tasks, including light duty jobs to whichinjured workers may be assigned.OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

Identify ProblemsAn important part of the ergonomic process is aperiodic review of the facility, including specificworkstation designs and work practices, and theoverall production process, from an ergonomicsperspective. This process includes reviewing thecompany’s injury and illness records and workerreports of symptoms and problems to identifyexisting problem areas. However, a more effectiveapproach, in combination with reviewing injuryand illness records, is to be proactive and identifypotential ergonomic issues that may have goneunnoticed or have resulted from facility changes,before they result in MSDs. OSHA recommendsthat poultry facilities establish a two-step processto systematically identify ergonomic-related riskfactors and their potential problems. This processshould account not only for current workplaceconditions, but also for planned changes toexisting and new facilities, processes, materials,and equipment.changes. The survey is one method for identifyingareas or jobs where potential problems exist andindicate the need for further investigation of that job.Identify Risk FactorsA more effective approach, in combination withreviewing injury and illness records, is to beproactive and identify potential ergonomic issuesthat may have gone unnoticed or have resultedfrom facility changes, before they result in MSDs.Ergonomics-related risk factors that may lead tothe development of MSDs in poultry processingfacilities include: Review Injury and Illness Information:Implement a Surveillance ProgramSurveillance for Injuries and Illnesses: To identifyexisting problems, employers should regularlyreview all reports of injury and illness. Thisincludes reviewing first-aid logs, nurse’s logs,OSHA 300 and 301 reports, reports of workers’compensation claims, insurance company reportsand employee reports of problems. All suchreports should be reviewed regularly and morefrequently if there are any process or staffingchanges. This regular monitoring should beconducted to determine if interventions (seepage 7: Implement Solutions) are necessaryto assure that no new problems are created. Asstated earlier, workers must be trained on the earlysigns and symptoms of musculoskeletal disordersand encouraged to report all symptoms early.OSHA’s Ergonomic Program Guidelines for theMeatpacking Industry (1993) (www.osha.gov/Publications/OSHA3123/3123.html) also include arecommendation for a Symptom Survey — whichcould be an especially important tool to monitoremployee health if there are any process or staffing Repetition — performing the same motion orseries of motions continually or frequently.The number of repetitious movements maybe affected by the speed of a conveyer belt, orthe number of workers available to do the job(crewing standards).Forceful exertion — the amount of physical effortto perform a demanding task (such as heavylifting, hanging/rehanging birds, pulling skin) orto maintain control of equipment or tools.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, maintaining a sustainedposture for a long period of time, as well asholding or using tools (e.g., knives or scissors)in a non-neutral or fixed position.Vibration — using vibrating hand-held powertools can increase the stress on the hands andarms. This is especially a problem if other riskfactors are present in the task.Cold temperatures in combination with theabove risk factors may also increase thepotential for MSDs to develop (1). Many of theoperations in poultry processing occur with achilled product or in a cold environment.The risk of MSD injury depends on the frequencyof the task performed, the level of required effort,the duration of the task, as well as other factors. Notall of these risk factors will be present in every job.Employers, however, should look for these factorswhen screening and analyzing jobs, operations,PREVENTION OF MUSCULOSKELETAL INJURIES IN POULTRY PROCESSING5

or workstations to determine which risk factorsare present. Jobs and tasks that have multiple riskfactors have a higher probability of causing MSDs (2).Job hazard analyses should be routinelyperformed on all tasks that are identified ashaving the potential to cause injury. Analysisshould include body posture evaluation, forcemeasurements, tools selection and theirmaintenance, PPE availability, and dimensionsand adjustability of the workstations. An adequateanalysis would be expected to identify all riskfactors present in each job or workstation studied.medical management, as needed, and allows thepoultry plant to correctly identify work areas orspecific tasks where injuries occur or are mostsevere. This information helps direct the efforts toaddress ergonomic risk factors as well as to guidehealthcare providers in making return-to-work andlight-duty work decisions.OSHA recommends that employers implement aprocess that addresses the following areas:The goal of encouraging early reporting is toproperly assess, diagnose, and treat MSDsthat occur in poultry plants before they lead todebilitating injury. This provides an opportunityto evaluate jobs and tasks and ensure promptAccurate injury and illness recordkeeping.Complete, descriptive, and accurate injury andillness records can be used to identify problemareas and evaluate progress. Early reportsprovide a mechanism to track MSD injuriesplant-wide and evaluate the effectivenessof work changes. Eliminating all barriers toemployee reporting of injuries will help ensureaccurate records.Early recognition and reporting. Early reportingof symptoms of MSDs reduces injury severity,the likelihood of permanent disability, and thenumber and costs of workers’ compensationclaims. It also identifies possible risk areas inthe plant for intervention (3, 15, 16).Systematic evaluation and referral. A definedprocess or protocol for evaluating employeereports, providing conservative treatment andwork restrictions, and referring employees formedical attention provides an effective andconsistent approach for minimizing the severityof MSDs (3, 12, 15).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 cold therapy,nonsteroidal anti-inflammatory agents,exercise, or night splints, depending on thenature and severity of the problem (3, 11, 16).Conservative return-to-work (restrictedduty). Modified or restricted work, jobaccommodations or light duty for a workerwith an MSD, can allow the worker to continueto perform productive work for the employerwhile continuing to allow recovery from injury.Some MSDs require weeks (or months, in rarecases) of restricted work to allow for completerecovery (3, 15, 16).6OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATIONAnother effective method to identify ergonomic riskfactors is to observe whether workers are: makingmodifications to their tools, equipment, or workareas to address potential risk factors; shaking theirarms and hands; rolling their shoulders; or bringingproducts, such as back belts or wrist braces, into theworkplace. These actions can mean that workers areexperiencing signs of developing MSDs. Encourage and Utilize Early Reportsof InjuriesAccurate and comprehensive injury reporting isimportant to the success of an ergonomic process.Early reporting, diagnosis, and intervention canlimit injury severity, improve the effectiveness oftreatment, minimize the likelihood of disabilityor permanent damage, and reduce workers’compensation claims (3, 13, 15). Employershave found that early reporting, combined withappropriate medical treatment and/or workrestrictions, can help employees recover fullywithout more serious and costly consequences.OSHA’s injury and illness recording and reportingregulation (29 CFR 1904) requires employers to keeprecords of work-related injuries and illnesses. Thisinformation, if recorded accurately and completely,can be an important tool in proper evaluation ofyour workplace. Under the OSH Act, employeesmay not be retaliated against for reporting a workrelated injury or illness (29 U.S.C. 660(c)).

Systematic monitoring of employees’ health.Monitoring employee health will help toprevent MSDs. Employers should considerinstituting a medical surveillance program formusculoskeletal disorders to monitor employeehealth and determine the effectiveness ofexposure prevention and medical managementstrategies. The following source providesinformation on medical monitoring andsurveillance (www.osha.gov/Publications/OSHA3123/3123.html; (8)).Additional use of medical resources. Healthcare professionals play a number of importantroles as ergonomic team members. Systematicfollow-up of employee reports of injury providesan opportunity to reinforce good work practices,modify conservative treatment plans, adjust workrestrictions, or refer the employee for medicalattention (3, 15, 16). Some poultry processingfacilities employ a healthcare professional withtraining in the prevention and treatment ofMSDs to receive and address reports of injuries.Employing healthcare professionals, and/orestablishing permanent relationships with outsidehealth-care professionals, allows the employerto quickly and effectively respond to employeereports of injury, evaluate employees, makemedical referral recommendations, providetreatment and monitor the recovery of injuredemployees. OSHA recommends that thesehealthcare providers, at a minimum, conductperiodic, systematic workplace walkthroughsto remain knowledgeable about operationsand work practices at the workplace, to identifypotential light duty jobs and to maintain closecontact with the employees. A healthcareprofessional’s knowledge of the facility willallow him or her to assist the injured workerduring the healing process and in post-injurywork placement (3, 15).Training. Early reporting of signs and symptomsof MSDs and conservative return to workprograms is particularly important. Trainingshould encourage employees to report earlyindications of MSDs before more serious MSDsdevelop.Implement SolutionsThe number and severity of MSDs resulting fromexposure to the identified risk factors, as wellas their associated costs, can be substantiallyreduced by implementing changes in theworkplace that are based on sound ergonomicprinciples (1).Ergonomic solutions for poultry processinginclude engineering changes to workstationsand equipment, administrative actions, workpractices, and personal protective equipment(PPE). The recommended solutions p

and research reports also confirm experiences documented in the poultry industry. A recent study of poultry plant workers reported that the prevalence of carpal tunnel syndrome was 2.5 times higher in poultry workers than in non-poultry manual laborers (9). The authors found th

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