Final word: You don’t need to record MSDs
OSHA eliminates rule for separate column
Employers will not need to record work-related musculoskeletal disorders (MSDs) in a distinct column on the Occupational Safety and Health Administration (OSHA) 300 log, the agency announced.
While OSHA had once stated that MSD reporting was "essential to obtain an accurate picture of the MSD problem in the United States," under the Bush administration, the agency delayed the provision in the record-keeping rule and solicited comment on the reporting of MSDs. In late June, the agency announced its decision that the column is unnecessary and the extra reporting would not be required.
For hospital employee health departments, that means one less benchmarking tool. Hospitals can rely on data compiled by the Bureau of Labor Statistics, which is based on employer surveys related to lost workday cases. Hospitals also can gather their own data by reviewing injury reports.
"Being able to identify the MSD would have been helpful from a data-tracking perspective," says MaryAnn Gruden, MSN, CRNP, NP-C, COHN-S/CM, executive president of the Assoc-iation of Occupational Health Professionals in Healthcare (AOHP) in Warrendale, PA, and employee health coordinator at Western Pennsylvania Hospital in Pittsburgh.
"Now when we check the column of other injuries, we know most of them are MSDs, but we have to go back and look at the individual injuries," she adds.
In fact, better reporting of MSDs is essential for efforts to reduce injuries, contends Bill Borwegen, MPH, occupational safety and health director for the Service Employees International Union (SEIU) in Washington, DC.
"I guess this is the Republican solution to the ergonomics problem — to stop counting," he says. "The best way to get MSDs to drop is to make the coding much more difficult."
The MSD record-keeping rule was once part of a broader effort to reduce injuries through an ergonomic standard. OSHA now uses a comprehensive approach that includes voluntary guidelines, education and outreach, and enforcement under the general duty clause requiring employers to maintain a safe workplace.
If OSHA had implemented a special column to track MSDs, it also would have needed to issue a single definition of an MSD.
But in its Federal Register notice, OSHA said such a statistic would not be useful: "[T]he total number of cases tells nothing about the possible causes and prevention of ergonomic hazards. Simply knowing that a certain number of MSD cases have occurred does not permit one to determine which jobs or working conditions pose ergonomic hazards and how they may be abated.
"The MSD column would not assist with the kind of detailed analysis necessary to effectively abate MSDs at the establishment level. Conscientious employers, employees, and authorized representatives who wish to address MSDs in their workplaces will do so, as they have in the past, by examining the entire log, whether or not an MSD column is implemented," OSHA added.
(Editor’s note: A copy of the Federal Register notice is available from the June 30 listing at www.osha.gov/wutsnew.html.)
Employers will not need to record work-related musculoskeletal disorders (MSDs) in a distinct column on the Occupational Safety and Health Administration (OSHA) 300 log, the agency announced.You have reached your article limit for the month. Subscribe now to access this article plus other member-only content.
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