Techno Bits/Technical Bulletins

In January 2001, OSHA issued a final rule concerning the recording of occupational injuries and illnesses. Employers would be required to use new forms and new criteria for identifying recordable events starting on January 1, 2002. In accordance with a memorandum from White House Chief of Staff Andrew Card, the new rule was reviewed by the agency. In July 2001, OSHA concluded that the rule should go into effect as originally scheduled except for the provisions concerning noise-induced hearing loss and soft tissue injuries (commonly called ergonomic injuries or musculoskeletal disorders). The agency proposed that these two provisions go into effect on January 1, 2003; in a Federal Register notice on October 12, 2001, OSHA made this proposal a final rule.

The criteria for recording injuries and illness under the new rules are basically the same as they are under the current rules, which have been in effect for more than two decades. Over the years the agency has published small changes to the rules and issued numerous clarifications. The new regulation codifies both the changes and clarifications using a question and answer format with tables, decision diagrams and examples.

Currently, a hearing loss is recordable if the employee has experienced a hearing loss of 25 dB or more from his/her original baseline hearing level. This criterion will be continued at least until January 1, 2003. During 2002, OSHA will review the available data to determine the degree of hearing loss that would constitute a recordable injury. The OSHA form 300 that was issued in January 2001 contained a column to check off hearing losses of 10 dB or more. A new version of the form, issued on October 12, 2001 does not contain this column.

The version of the OSHA log issued in January 2001 with the new recordkeeping rule (called form 300) contained a column for identifying injuries as musculoskeletal disorders (MSDs). OSHA is reviewing the whole issue of regulating ergonomic hazards, including the definition of an "ergonomic injury", and has conducted a series of fact-finding forums; accordingly, recordkeeping forms for 2002 have been modified to eliminate a column for checking off MSDs. During 2002, all work-related injuries, including MSDs will be recordable if they result in death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, loss of consciousness or are diagnosed as serious by a physician or other licensed health care professional. However it will not be necessary to identify the injury as a musculoskeletal disorder on the OSHA 300.

Employers can obtain the new recordkeeping forms and instructions for their use from OSHA's web site, www.osha-slc.gov/recordkeeping/Rkforms.html. The OSHA web site, www.osha.gov also contains useful information and training materials on the new recordkeeping rules.

Posted - Jan. 11, 2002