The Occupational Safety and Health Administration (OSHA) has proposed to revise its Occupational Injury and Illness Recording and Reporting (Recordkeeping) rule to include a column on the OSHA Form 300 Injury and Illness Log that employers would check if a case they already are required to record is a musculoskeletal disorder (MSD). The proposed rule would also require that employers put the totals from the MSD column on the annual summary at the end of the year (OSHA Form 300A Annual Summary).
The proposed rule would define an MSD as a disorder of the muscles, nerves, tendons, ligaments, joints, cartilage or spinal discs that was not caused by a slip, trip, fall, motor vehicle accident or similar accident.
This proposal only covers MSDs that employers are already required to record under the longstanding OSHA Recordkeeping rule. Recordable cases, including MSDs, are generally those that are new, work-related, and involve medical treatment beyond first aid, restricted work or days away from work.
In an effort to assure that impacts of the proposed rule are fully considered, OSHA and the Small Business Administration Office of Advocacy (SBA Advocacy) are sponsoring three teleconferences with small businesses to gather information about their experiences in recording work-related MSDs and how they believe the proposed rule would impact them.

The teleconferences are scheduled for 1:30 p.m., Monday, April 11, 2011 and 9 a.m. and 1:30 p.m., Tuesday, April 12, 2011.
Each teleconference is expected to last about 2 to 3 hours.
Those attending the conference in person will meet at OSHA's Washington, D.C. office at 200 Constitution Ave., NW, Washington D.C. 20210, Room N-3437 C & D.

SBA Advocacy and OSHA will select the participants for each teleconference. Small businesses interested in participating and organizations interested in nominating small businesses should see the contact information listed below.
Only the selected small businesses will be allowed to participate in the teleconference, but the public will be invited to listen in on the teleconference in person at OSHA's Washington, D.C. office.
Participants will be asked to provide information about their current recordkeeping practices and how they believe the proposed MSD column rule would impact them.
OSHA will provide participants with background information and a list of issues for discussion in advance of the teleconference. The information will also be made available to the public.
Participation in the meeting is completely independent of OSHA enforcement activities.
The teleconferences will not be electronically recorded or transcribed. OSHA staff will take notes during the teleconferences, but specific sources of comments will not be identified.
Participants will not be compensated for time or other expenses incurred in connection with participating in the teleconference.
Participants may also send in written comments following the teleconference.
After the teleconferences are completed, OSHA will open the record on the proposed rule to allow interested persons, particularly small businesses, to comment on the teleconferences and the issues raised during them.

If you are interested in participating in one of these teleconferences, please contact Regina Powers, by Monday, April 4, and indicate the teleconference in which you wish to participate.

Robert Burt
Director, Office of Regulatory Analysis
OSHA
U.S. Department of Labor
202-693-1952

Bruce Lundegren
Assistant Chief Counsel
Office of Advocacy
U.S. Small Business Administration
202-205-6144