OSHA Recordkeeping Handbook - denix

§1904.12Thus, the total MSD count in an establishment couldinclude a number of disparate disorders that have littlein common. More importantly, the total number ofcases tells nothing about the possible causes andprevention of ergonomic hazards. Simply knowingthat a certain number of MSD cases have occurreddoes not permit one to determine which jobs orworking conditions pose ergonomic hazards andhow they may be abated.To effectively analyze and address ergonomicinjuries that are occurring in workplaces, employersand others must be able to link specific types ofinjuries to specific characteristics of jobs or workingconditions. This requires evaluation of each individualcase to determine the part of the body affected,the nature of the job performed by the injuredemployee and other relevant data. Such informationis currently available in the case-description sectionof the 300 Log and in the 301 Incident Report.Evaluation of these case-entry data, particularly thejob title and the description of the injury and affectedbody part contained in Columns C and F on the 300Log, will enable employers, workers and OSHA toidentify specific types of MSDs, to link specific MSDinjuries to specific ergonomic risk factors, and toidentify trends in certain jobs or work practices overtime.The MSD column would not assist with the kindof detailed analysis necessary to effectively abateMSDs at the establishment level. Conscientiousemployers, employees and authorized representativeswho wish to address MSDs in their workplaceswill do so, as they have in the past, by examining theentire Log, whether or not an MSD column is implemented.Some employers and others may wish touse the Section 1904.12 definition of MSD as part oftheir comprehensive records analysis or they maywish to use a different definition more suited to theirspecific working conditions. For example, nursinghome employers may wish to focus particularly onback cases in analyzing the effectiveness of patientlifting and repositioning abatement measures. On theother hand, employers and others who do not wishto perform a comprehensive analysis would not beable to use an MSD column as a substitute for theanalysis.To the extent that the aggregate total of MSDcases is of some relevance, the number can easily bedetermined without a column. Based on the description-of-injuryinformation in column F of the Log, onecan very quickly identify which cases are MSDsunder the Section 1904.12 definition, or an alternativedefinition such as the one in OSHA’s meatpackingguidelines. The MSD column is simply not necessaryfor this purpose. For these reasons, OSHA concludesthat the MSD column would not be a useful tool atthe establishment level.A related point argued by some is that an MSDcolumn is needed to ensure effective enforcement ofthe general duty clause. However, the column hasnever been in effect and has not been a factor inenforcement of the clause. It is difficult to see the utilityof simply checking an MSD column given thedetailed nature of the information needed by OSHAto sustain a general duty clause citation. The casedescription data in the 300 and 301 forms is availableto assist OSHA in its inspection activities. This informationpermits a more comprehensive understandingof MSDs in workplaces than would a singleaggregate statistic produced by a column. Accordingly,there is no need for an MSD column on theLog for enforcement purposes.The other justification cited for the MSD column isthat it is necessary to improve the accuracy and usefulnessof the national injury and illness statistics.However, OSHA concludes that MSD column wouldnot materially improve the national statistics onMSDs. The national statistics already include comprehensiveinformation about MSDs that result indays away from work, including the total numberand incidence rate of these disorders. As to otherMSDs, the MSD column would allow the Bureau ofLabor Statistics (BLS) to calculate the total number ofthese cases, but not to analyze their characteristics inany way. OSHA does not believe that a new statisticon total MSDs would be useful without the ability toassess the specific characteristics of these disorders.To obtain additional data necessary to allow BLS toassess the characteristics of MSDs that do notrequire days away from work would require significantchanges to the BLS survey system not contemplatedin the proposed recordkeeping rule and notrequested by any party.Why the MSD Column Would Not SignificantlyImprove the BLS Statistics.If the MSD column were implemented, employersparticipating in the BLS survey would report annuallythe total number of MSD cases checked on the Log.This information would enable BLS to publish thetotal number and incidence rates of MSDs of alltypes. Thus, the statistical tables depicting the totalnumber and incidence rates of non-fatal injuries andillnesses by industry would include an additional columnfor total MSD cases. (See, e.g., WorkplaceInjuries and Illnesses in 2000, Tables S14 and S16.)104OSHA RECORDKEEPINGHANDBOOK