APWU

Union Battles USPS Over Ergonomic Hazards

Greg Bell, Director
Industrial Relations

(This article was first published in the July/August 2009 issue of The American Postal Worker magazine.)

Locally filed OSHA complaints and a national Unfair Labor Practice Charge are among the actions taken by the APWU in our ongoing battle with the Postal Service over ergonomic hazards on the Delivery Bar Code Sorter (DBCS). In a March 25, 2009, letter to local presidents, the national union urged locals to file individual complaints with the Occupational Safety & Health Administration (OSHA) for each facility that has a DBCS within the installation.

In addition, we filed an Unfair Labor Practice charge with the National Labor Relations Board on Dec. 22, 2008, and an amended charge on March 9, 2009, protesting the Postal Service’s refusal to meet and bargain in good faith about ergonomic issues revealed in an OSHA report. We also protested the Postal Service’s failure to provide information that we repeatedly have requested.

Background

In late October 2007, OSHA conducted an assessment of the DBCS operations at the Denver P&DC. OSHA’s review documented that ergonomic risks associated with the DBCS operations are still present, and that some of the findings are similar to the findings of two prior National Institute for Occupational Safety and Health (NIOSH) Health Hazard Evaluations.

Despite the OSHA reports, the Postal Service has refused every attempt by the APWU to discuss the hazards, and continues to willfully expose postal employees to risks associated with the operation of the DBCS.

In addition to ignoring OSHA and NIOSH reports, the Postal Service ignores its own handbooks, manuals, and training programs, as well as the DBCS manufacturer’s manuals for the safe and healthful operation of the equipment. The Postal Service insists that it is making progress in reducing injuries, and that the DBCS is not a cause of Musculoskeletal Disorders (MSD).

OSHA and NIOSH, on the other hand, have documented that employees are exposed to hazards and are at risk for injuries due to improper equipment installation, including foot-print allocation; support equipment placement and organization; improper allocation of heavy volumes of mail to higher-risk sorting bins; ergonomically unsound loading- and sweeping-procedures; and are subject to various administrative deficiencies such as inadequate work-rest cycles/rotation; insufficient training (both initial and refresher), and questionable equipment-maintenance practices.

Documented Hazards

These documented problems are nothing new. In 1991 and 1992, NIOSH investigators evaluated the potential for ergonomic hazards on three types of automated mail-processing machines, one of which was the first-generation DBCS.

These types of DBCS machines have 102 stackers arranged in three tiers at heights of 22 inches, 36.5 inches and 50.25 inches above the floor. The latest- generation DBCS machines have more than 200 stackers, which are arranged in four rows, ranging in height from 21.5 inches to 56 inches.

In a 1993 report, NIOSH investigators concluded that the automated equipment used by the USPS “put employees at potential risk for low back and upper extremity musculoskeletal disorders” due to the awkward postures workers had to assume and the repetitive tasks they had to perform. The report noted in particular the design flaws at the DBCS sweeper position.

The main flaw cited in the report ( NIOSH HETA 92- 0073-2337, USPS General Mail Facility, Denver, CO, July 1991 ) was the height of the three rows of stackers. The first row is too low, and thus requires excessive trunk flexion (bending over) while sweeping mail; the third row is too high for most workers, who are unable to avoid reaching above shoulder height to sweep mail.

Due to the excessive ligament forces exerted at the knee during deep-knee flexion, the report cautioned against bending the knees as an acceptable method of sweeping the bottom row of stackers. Another risk factor noted in the report was the high number of repetitions of upper-extremity motions from sweeping 102 stacking locations from a machine capable of sorting 35,000 pieces of mail per hour.

The recommendations for DBCS operations contained in the July 1993 NIOSH report were as follows:

  • Assign additional workers to the machines to help with sweeping.
  • Limit the time that workers spend on the machines.
  • Provide additional rest breaks for workers on these machines.
  • In the long term, automate the sweeping position of the DBCS.

In March 2006, NIOSH provided the Postal Service with a re-evaluation of DBCS operations. In addition to the recommendations in the 2003 report were the following:

  • Conduct periodic training and monitoring of worker activities to reinforce safe work practices that have been taught and developed at the USPS.
  • Rotate workers frequently between the feeder and sweeper positions. Rotation should take place at least once per hour, but more frequent rotation such as every 30 or 50 minutes may be more beneficial.
  • To ensure that the amount of mail accumulated in the stacker does not exceed desired levels, the feeder should occasionally stop loading new mail into the DBCS and instead help the sweeper.
  • Encourage workers to use sound work practices such as the “Power Lift” while working on the DBCS machines, particularly at the feeder position where the wide stance and lift with the legs techniques are most applicable.
  • Determine and implement a mail-processing rate of work that will help workers avoid injury. This can be established either through time-and-motion studies or by manipulating the volume of mail processed (per hour or per day) until injury rates are under control. As noted above, reducing the rate of work is the most effective administrative means of injury control when engineering controls are not implemented, such as in the case of the DBCS.

NLRB Complaint

On May 1, 2009, the NLRB issued a formal Complaint and Notice of Hearing for the Postal Service’s continued failure and refusal to provide the union with requested documents pertaining to the DBCS-7, the latest version of the machine, as well as information regarding internal reviews of OSHA’s assessment of the DBCS.

In addition to asking the Board to force the Postal Service to provide the requested documentation, the union sought injunctive relief that would require the USPS to meet to discuss these ergonomic issues. The NLRB Regional Director agreed and was prepared to go to court to force the Postal Service to meet. Faced with the threat of an injunction, the Postal Service backed down.

Since then, the Postal Service has met once, but the NRLB Regional Director issued a complaint, nonetheless, because of the “unreasonable delay” in giving the union relevant information. The Regional Director has scheduled a hearing on July 20, 2009, on the allegations in the complaint.

In the meantime, any local with a DBCS that has not yet filed an OSHA complaint should do so as soon as possible. The form necessary for filing a complaint, as well as a packet of information that must be submitted with it, is available on the Industrial Relations pages at www.apwu.org.

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