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Addressing the 300 log problem

March 1, 2011

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The proposed rule change on OSHA’s injury and illness recording and reporting requirement regulation to add a musculoskeletal disorder column to the OSHA Form 300 log comes with its share of critics.

OSHA insists the rule change does not add any new employer requirements. Currently, employers have to record any MSD injury on the job. The rule change would require employers to place MSD injuries under a specific MSD column instead of the “other” or “injury” column.

But critics have railed against the rule, particularly toward OSHA’s estimates of employer costs. According to OSHA, it will take affected employers five minutes to first familiarize themselves with the rule change and then one minute to properly record each case in the MSD column.

Critics point out under the current regulation, an employer does not have to differentiate between injuries – a struck-by injury was simply an injury. In the proposed rule change, an employer has to decide if that struck-by injury was just a struck-by, or if MSDs played a role.

“Making those determinations are really difficult,” said Brad Hammock, an attorney at Washington-based Jackson Lewis who worked with OSHA on its first attempt at an ergonomics standard during the Clinton administration. “If you don’t have some idea about ergonomics, some idea about MSDs … then you can’t effectively check the box.”

Many small-business owners have no safety professionals on staff to make that determination; it falls on the owner. Karen Harned, director of the Washington-based National Federation of Independent Business small-business legal center, worried that business owners may err on the side of caution and incorrectly record an injury as an MSD, leading to inaccurate results.

Furthermore, there is the problem of determining whether an MSD injury on the job was really work-related or not. “People have lives outside of work,” Harned said. “How do you determine what’s caused by your work environment versus what’s caused by life outside of work?”

The rule change has its proponents. In a letter submitted to OSHA during the rule’s comment period, the Washington-based International Brotherhood of Teamsters suggested an MSD column would help address underreporting of MSDs. David LeGrande, occupational safety and health director for the Washington-based Communications Workers of America, said the collected data could be used to help identify and resolve work-related MSDs, a point also made by OSHA.

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