OSHA Keeps Recordkeeping Form Requirements

Recently, the Occupational Safety and Health Administration announced that it would not add a column for recording musculoskeletal disorders ("MSDs") to its 300 Log for Injury and Illness Recording and Recordkeeping.

In January 2001, OSHA revised its recordkeeping rule (29 C.F.R. § 1904.12(a)) to require employers to check a new MSD column on the OSHA 300 Log if an employee experienced a work-related MSD. However, the effective date of the MSD requirement was postponed so that OSHA could hold a series of forums to develop a comprehensive plan to address ergonomic hazards. After holding the ergonomic forums, OSHA decided not to modify the recordkeeping form. Consequently, an MSD column will not be added to the 300 Log and the current method of recording injuries or illnesses will continue.

A review of the recordkeeping requirements published by OSHA in January 2001 is in our OSHA Employer Alert. If you have questions regarding this final rule or if you would like assistance in preparing for an OSHA inspection, please contact a member of our OSHA Practice Group.