Your New Form 300

OSHA's new fiscal year began Oct. 1 and within hours the new-for-2004 Form 300 (Log of Work-Related Injuries and Illnesses) was unveiled. OSHA announced in December 2002 it would add a separate column for hearing loss cases but would not add a column for musculoskeletal disorders. The new form and column take effect Jan. 1, 2004.

The hearing loss column, which is the fifth column in the section defining the type of injury or illness being recorded, is a major change. OSHA also placed the "days away from work" column in front of the "days on job transfer or restriction" column. OSHA said it followed public suggestions for an easier form by providing clearer formulas for calculating incidence rates and new recording criteria for occupational hearing loss in the "Overview" section.

A new 300A Summary Form was released a few days later. Employers won't need the version with a hearing loss column until they're ready to post 2004 injury summaries in February 2005. The summary page must be posted annually from Feb. 1 to April 30; you can get a hard copy of the new forms by calling 800-321-OSHA or visiting www.osha.gov.

What all of this means: In early 2005, the nation's recent progress at reducing recordables probably will cease. Not because workers all over the country suddenly have lost their hearing, but because the new two-part test in OSHA's 1904.10 recording criteria will cause many more hearing loss cases to be recorded. Finally, this change means the true scope of occupational hearing loss will become quantifiable, industy by industry, on a national scale. OSHA revised 1904 with a caveat urging employers (and, implicitly, me and my media colleagues) not to compare the first year of data under this new regime with data from prior years, when the 25 dB criteria for recordkeeping was used. "OSHA recognizes this increase, and will take the changes in the recordkeeping rule into account when evaluating an employer's injury and illness experience," the agency promised.

Ergonomics was OSHA's biggest issue just three years ago, but the anger aimed at OSHA over ergonomics has disappeared. As months of delay piled up, we knew John L. Henshaw & Co. wouldn't keep the MSD column on Form 300. By now, its absence is inconsequential. Log your work-related ergonomic injuries under "Injury" or column (6), "All other illnesses." That's all there is to it.

This article originally appeared in the December 2003 issue of Occupational Health & Safety.

About the Author

Jerry Laws is Editor of Occupational Health & Safety magazine, which is owned by 1105 Media Inc.

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