Basing their decision on the assumption that reporting work-related musculoskeletal disorders (MSDs) would benefit neither employer nor employee, OSHA has decided not to include a separate column requiring employers to report MSDs in their record keeping.
According to an OSHA press statement on the decision, made public on June 30, 2003, "OSHA concluded that an additional recordkeeping column would not substantially improve the national injury statistics, nor would it be of benefit to employers and workers because the column would not provide additional information useful to identifying possible causes or methods to prevent injury."
OSHA Administrator John Henshaw noted that the lack of MSD-specific reporting "does not change the current way injuries or illnesses are recorded and does not affect an employer's obligation to record work-related injuries, including [MSDs]." Rather, Henshaw noted that employers will still need to lump MSDs in with the "injury" or "all other illness" categories.
However, one reason why OSHA may have decided not to include a specific MSD reporting requirement could be because of the agency's inability to determine their own definition of an MSD. In the June 30, 2003 Federal Register, OSHA noted that "a number of participants in the ergonomics forums had argued that the [proposed record-keeping] definition of MSD combines too many disparate types of disorders to be useful. They pointed out that there are at least two distinct categories of disorders covered by the definition; disorders caused by a single event, such as a heavy lift, and disorders caused by repetitive or cumulative events, such as repetitive lifting, typing or assembly line work. To produce more relevant statistics, these participants suggested, OSHA should narrow the definition to focus on a group of disorders having common characteristics." However, neither OSHA nor its Ergonomics Task Force has determined a more specific definition of an MSD at this time.
OSHA also reported in the Federal Register that, "If the MSD column were implemented, employers participating in the [Bureau of Labor Statistics (BLS)] survey would report annually the total number of MSD cases checked on the Log. This information would enable BLS to publish the total number and incidence rates of MSDs of all types." But "these . . . statistics would add only marginally to the information currently available. [T]he MSD column would add minimally to the national statistics on MSDs that resulted in days away from work. The new data would be relevant primarily for the purpose of estimating the number of MSDs that do not result in days away from work." However, OSHA states that it's impractical to analyze MSDs that don't result in missed workdays and therefore the information obtained would be unusable.