What is significant about February … other than remembering Valentine’s Day? You are correct if you say posting your OSHA Log 300 Summary on February 1. But, February 2010 has more … Ergonomics is back on the OSHA stage!

OSHA is proposing to modify Log 300. The modification proposes specific reporting of musculoskeletal disorder (MSD; aka ergonomic) injuries. This proposal virtually restates requirements proposed in 2001. Let’s revisit 2001 … déjà vu Ergonomics Standard!

On January 16, 2001, an OSHA Ergonomics Standard was finalized (President Clinton). On March 20, this Ergonomics Standard was rescinded (President Bush).

At the time our politicians were finalizing-rescinding the OSHA Ergonomics Standard, ergonomic injuries (MSDs) accounted for one-third of all reported occupational injuries and illnesses. These disorders constituted the largest job-related injury and illness problem in the United States. In 1997, employers reported a total of 626,000 lost workday MSDs. These disorders accounted for $1 of every $3 spent for workers’ compensation in that year.

Once the Ergonomics Standard was rescinded, the requirement for specific reporting of ergonomic injuries was withdrawn. Have ergonomic (MSD) injuries been reduced in the following years? If the politicians don’t see an ergonomics problem, employers should see an ergonomics problem … workers are surely suffering ergonomic injuries!

Given no reporting data, we do not really know the actual injury rate related to ergonomic injury. Given the lack of an Ergonomics Standard and enfeebled OSHA enforcement armed only with the General Duty Clause, it is unlikely that MSD injury rate has reduced over the past ten years.

What is the significance of MSD data collection? Reporting specific injury types reveals the extent and severity of the specific injury. If MSD injuries dominate the injury picture today as they did ten years ago, there will probably be increased interest in reviving an OSHA Ergonomics Standard. Don’t worry … OSHA standards making does not move quickly.

Hearing loss injuries have been specifically reported for the past ten years, and, employers have surely reported hearing loss injuries. Yet, the OSHA Hearing Conservation Standard is approaching three decades without substantive change; even though the standard is recognized as fundamentally un-protective compared to almost any other noise standard on the Planet.

What does this mean … other than filling out another column on the OSHA Log 300? I suggest that this is an opportunity for employers to better understand workplace injuries.

OSHA may or may not require reporting of specific injuries. A worker may or may not report an injury that should be known by his employer. Yet, a business person has a vested interest in worker health and safety. Isn’t worker reliability critical to business success?

My message is twofold. First, expect future OSHA’s Log 300 reporting to include specific reporting of ergonomic injuries (musculoskeletal disorders). Second, regardless of OSHA reporting requirements, a clear understanding of ergonomic injury – and other workplace injuries – is good business!

For more information, view OSHA’s proposal. This notice was published in the Jan. 29 edition of the Federal Register.

Filed under: Employer Liability, OSHA Compliance, Occupational Safety