OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.
JUN 8 1990
MEMORANDUM FOR: REGIONAL ADMINISTRATORS
THRU: LEO CAREY, DIRECTOR
OFFICE OF FIELD PROGRAMS
FROM: PATRICIA K. CLARK, DIRECTOR
DESIGNATE DIRECTORATE OF COMPLIANCE PROGRAMS
SUBJECT: Cumulative Trauma Disorders at United States Postal
Service Facilities
The Office of Federal Agency Programs (OFAP) has been notified by several Regional Offices that they have been receiving numerous reports concerning hazards at United States Postal Service (USPS) facilities. A few of these relate to back injuries from flat sorting operations, but most allege cumulative trauma disorders (CTDs) caused by Multi-Position Letter Sorting Machines (MPLSMs) (also referred to as Letter Sorting Machines (LSMs)) and Parcel Sorting Machines (PSMs) These reports were either handled by OSHA Area Offices in accordance with established procedures or OFAP was contacted for further guidance. In some instances where Notices of Unsafe or Unhealthful Working Conditions were issued by the Area Office, the USPS is disagreeing with the Notices.
Since the operations discussed in the hazard reports appear to be essentially the same throughout the country, several Regional Offices have suggested that the National Office explore the dimensions of the problem and, if warranted, develop a nationwide strategy for responding to reports of hazards involving MPLSMs and PSMs.
Two of these employee hazard reports were responded to in USPS facilities at Columbus, Ohio and Peoria, Illinois. Dr. William Marras of Ohio State University was contracted to accompany OSHA staff at these sites, in order to analyze the ergonomic problems associated with the above mentioned operations. Dr. Marras is an Industrial Engineer with ergonomics expertise. Upon receipt of Dr. Marras' reports concerning these two inspections, a determination will be made as to the scope of the problem and if further site visits are necessary in order to develop National policy.
In the meantime, when a formal complaint concerning CTDs is received, you should:
1. Notify the complainant by letter that OSHA will conduct a limited inspection because we are developing a nationwide strategy for dealing with the MPLSM or PSM machines and its ergonomic impact on employees and that he/she will be notified of our progress.
2. Conduct the limited inspection to ensure that the alleged hazard does, in fact, involve an MPLSM or PSM.
3 Conduct an onsite records check and make copies of the appropriate injury/illness records for the case file.
4. Notify the United States Post Office facility manager at the closing conference that OSHA is developing a nationwide strategy for dealing with ergonomic hazards associated with the machines and that a follow-up visit may be needed at a later date.
Any other alleged hazards identified in the complaint should be addressed following normal Field operations Manual procedures.
If you have already investigated a complaint relating to MPLSM or PSM operations, do not issue a Notice at this time. Notify the complainant and the facility manager that OSHA is developing a nationwide strategy for dealing with ergonomic hazards associated with these machines and that he/she will be notified of any further OSHA actions. If you have already issued a Notice to a post Office facility, do not issue a Notice of Failure-to-Abate until we notify you of our nationwide policy.
If you have any questions, please contact Mr. John E. Plummer on FTS 523-9329.