Enforcement and Inspection

OSHA Proposes MSD Change for OSHA Form 300

OSHA is proposing to revise its Occupational Injury and Illness Recording and Reporting (recordkeeping) regulation by restoring a column on the OSHA Form 300 to better identify work-related musculoskeletal disorders (MSDs).

The proposed rule wouldn’t change the existing requirements for when and under what circumstances you must record MSDs on your injury and illness log. It would simply require you to place a check mark in a column for all MSDs you’ve recorded.

The proposed requirements are identical to those contained in the OSHA recordkeeping regulation that was issued in 2001. Prior to 2001, injury and illness logs contained a column for repetitive trauma disorders that included noise and MSDs. Then in 2001, OSHA separated noise and MSDs into two separate columns. However, the MSD column was deleted in 2003 under the Bush administration before the provision became effective.


The comment period on the proposed rule change ends today (March 15, 2010). You still have time to fax comments or submit them electronically. Or if you send a letter postmarked today, it will also be accepted.

  • Electronic submissions: http://www.regulations.gov (follow online instructions)
  • Fax: OSHA Docket Office, (202) 693-1648 (not to exceed 10 pages with attachments)
  • Mail: OSHA Docket Office, Docket Number OSHA-2009-0044, U.S. Department of Labor, Room N-2625, 200 Constitution Avenue, NW, Washington, DC 20210

For more details about the proposed revisions, go to OSHA’s website.

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MSD Facts

MSDs include a group of medical conditions that involve the nerves, tendons, muscles, and supporting structures such as discs in the backbone. Examples of common workplace MSDs include carpal tunnel syndrome, tendonitis, neck pain, and lower back pain.

MSDs occur most often in jobs that involve:

  • Repetition—performing the same motion over and over for long periods each day
  • Physical force—constant lifting, pushing, or pulling
  • Awkward postures—for example, working with the back and neck bent or twisted, or working with the hands above the head
  • Contact stress—for instance, using the hand or knee as a hammer
  • Vibration—using vibrating tools

Symptoms of MSDs vary depending on the part of the body affected:

  • Back and neck—shooting pain, stiffness
  • Shoulders—pain, stiffness, loss of mobility
  • Arms and legs—shooting or stabbing pains, numbness
  • Elbow or knee joints—pain, swelling, stiffness, soreness
  • Hands and wrists—pain, swelling, tingling, numbness, coldness, burning sensation, loss of strength or coordination
  • Fingers—loss of mobility, snapping or jerking movements, loss of strength, loss of feeling, severe pain
  • Thumbs—pain at the base of the thumb
  • Feet and toes—tingling, numbness, coldness, stiffness, burning sensation

The earlier MSDs are diagnosed and treated, the better the outcome.

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Although OSHA currently has no ergonomic standard, it has developed guidelines for various industries, including nursing homes, retail grocery operations, poultry processing facilities, and printing plants.

OSHA says that many of the ergonomic principles found in these guidelines can be adapted for other industries. The guidelines are posted on OSHA’s website.

Even though there is no ergonomic standard (and possibly no guidelines specific to your industry), OSHA says that you still have an obligation under the General Duty Clause of the OSH Act to keep your workplace free of recognized serious hazards, including ergonomic hazards. OSHA warns that it will cite employers under the General Duty Clause or issue ergonomic hazard letters, where appropriate, as part of its overall enforcement program.

In tomorrow’s Advisor we’ll provide some tips for reducing ergonomic risks.

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3 thoughts on “OSHA Proposes MSD Change for OSHA Form 300”

  1. Whether a worker is injured on or off the job, the result is often the same—lost workdays, lost productivity, and hefty healthcare costs. That makes getting all injured employees back to work ASAP a priority.

  2. Whether a worker is injured on or off the job, the result is often the same—lost workdays, lost productivity, and hefty healthcare costs. That makes getting all injured employees back to work ASAP a priority.

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