OSHA Moves to Restore MSD Column to 300 Form

OSHA is proposing to revise its Occupational Injury and Illness Recording and Reporting regulation by restoring a column on the OSHA Form 300 to better identify work-related musculoskeletal disorders (MSDs), such as carpal tunnel syndrome and tendonitis. The rule does not change existing requirements for when and under what circumstances employers must record MDSs on their injury and illness logs.

Many employers are currently required to keep a record of workplace injuries and illnesses, including work-related MSDs, on the OSHA Form 300 (Log of Work-Related Injuries and Illnesses). The proposed rule would require employers to place a check mark in a column for all MSDs they have recorded. OSHA plans to host a public meeting on this proposal March 9; requests to speak at the meeting are due by Feb. 16.

The proposed requirements are identical to those contained in the OSHA recordkeeping regulation that was issued in 2001. Prior to 2001, OSHA's injury and illness logs contained a column for repetitive trauma disorders that included noise and MSDs. In 2001, OSHA separated noise and MSDs into two separate columns, but the MSD column was deleted in 2003 before the provision became effective. OSHA is now proposing to restore the MSD column to the OSHA Form 300 log.

"Restoring the MSD column will improve the ability of workers and employers to identify and prevent work-related musculoskeletal disorders by providing simple and easily accessible information," said OSHA chief Dr. David Michaels. "It will also improve the accuracy and completeness of national work-related injury and illness data."

For more information, view OSHA's proposal at: www.dol.gov/federalregister/msdcolumn. This notice also is in today's edition of the Federal Register.

Interested parties may submit comments on the proposed rule electronically at www.regulations.gov, the federal e-rulemaking portal; or by mailing three copies to the OSHA Docket Office, Room N-2625, U.S. Department of Labor, 200 Constitution Ave. NW, Washington, D.C. 20210; or by fax at 202-693-1648 if the comments and attachments do not exceed 10 pages. Comments must include the agency name and docket number for this rulemaking, which is Docket Number OSHA-2009-0044. The deadline for submitting comments is March 15.

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