In case you missed it, OSHA wants to make employers list specific musculoskeletal disorder (MSD) information on the OSHA Form 300.

A little background. On Jan. 19, 2001, in the final days of the Clinton Administration, OSHA published a Recordkeeping rule that would have created a new column on the Form 300 for employers to check off to report work-related MSDs, defined as “disorders of the muscles, nerves, tendons, ligaments, joints, cartilage and spinal discs, except those caused by slips, trips, falls, motor vehicle accidents and similar accidents.”

But in 2003, the Bush Administration’s OSHA announced that the MSD information gathered would serve no useful purpose. So it scuttled the rule and took the MSD column off the Form 300 (although it did add a new column for occupational hearing loss.)

After consulting with the Advisory Committee on Construction Safety and Health, OSHA has once more changed its position. On January 28, the agency proposed restoring the 2001 recordkeeping rule, including the definition of MSDs. To see the proposal, www.dol.gov/federalregister/msdcolumn. “Restoring the MSD column will improve the ability of workers and employers to identify and prevent work-related MSDs,” according to OSHA head David Michaels. The information the MSD column will provide will also significantly enhance the accuracy and completeness of national MSD data, he added.

OSHA will be taking comments on the proposal until March 15. To submit one, use http://www.regulations.gov. 

OSHA is downplaying the impact of the proposal saying employers will have to spend “5 minutes” getting familiar with the rule, and another “1 minute” completing the Form 300 to report MSD information. Yeah, maybe. But what might seem like a minor matter of paperwork could lead to something much more burdensome if, as many suspect, the move signals OSHA’s intent to bring back the extensive ergonomics standard that the Clinton Administration created but didn’t live long enough to see into effect.

Story Tools:  Email This Post  Print This Post Top