Magazine article The Small Business Advocate

Advocacy Asks OSHA to Reassess Cost of MSD Reporting Rule

Magazine article The Small Business Advocate

Advocacy Asks OSHA to Reassess Cost of MSD Reporting Rule

Article excerpt

The Office of Advocacy recently filed comments on an Occupational Safety and Health Administration (OSHA) proposal, the Occupational Injury and Illness Recording and Reporting Requirements Rule or "MSD reporting rule." Advocacy is concerned that OSHA may have understated the cost and complexity of complying with the rule, especially for small businesses.

OSHA's proposed rule, published on November 18, 2009, would require employers with 10 or more employees (unless exempt) to record certain work-related musculoskeletal disorders (MSDs, also known as ergonomie injuries) in their OSHA 300 Log. The log is a record of work-related injuries and illnesses that certain employers are required to maintain.

MSDs are defined by OSHA as disorders of the muscles, nerves, tendons, ligaments, joints, cartilage and spinal discs (e.g., carpal tunnel and rotator cuff syndrome, herniated spinal disc, low back pain); they do not include disorders caused by slips, trips, falls, motor vehicle accidents, or other similar accidents. The proposed rule would add a new column to the 300 Log specifically for recording MSDs; however, OSHA does not indicate where on the OSHA 300 Log this new column would be located, or whether an MSD is an injury, illness, or a hybrid of the two.

OSHA states that the proposed rule would only require employers to check a new MSD box on their OSHA 300 Log and that employers are already required to report this information on the current form. As such, OSHA concludes that compliance with the proposed rule would involve five minutes per employer to read and understand the new rule, and one minute per MSD injury or illness to check the new box. …

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