In a letter to OSHA chief Dr. David Michaels, American Industrial Hygiene Association President Cathy L. Cole, CIH, CSP writes “there is a need to restore the musculoskeletal disorder (MSD) column on the OSHA 300 log and (AIHA) supports efforts by the Occupational Safety and Health Administration (OSHA) to include this column on future OSHA 300 logs.”

AIHA recommends inclusion of a list of risk factors for MSDs in order to assist OSHA record keepers — who are familiar with the work and tasks of their own employees — within companies. Referring to risk factors has been found helpful by companies who already do their own MSD reporting. These risk factors would include such items as:
  • Awkward, twisted postures
  • Extended forward bending of trunk
  • Trunk rotation
  • Whole body and/or upper extremity vibrations
  • Forceful upper body exertions
  • Work above heart level
  • Repetitive work
  • Extended static work without possibility of repositioning
  • Long durations
  • Extended reaches
  • Heavy, awkward lifting
  • Forceful wrist deviation or pinch grips
  • Neck extension
  • Forceful exertions with exposure to pressure points
  • Extended work without adequate footing


  • AIHA also asserts injury under-reporting”is particularly egregious in the case of MSDs as contrasted with acute/traumatic injuries because the cause of an MSD is not a single, identifiable, and observable incident such as occurs with such acute injuries as burns, fractures, or cuts. Since MSDs occur over time the question ‘what were you doing when the injury occurred’ is irrelevant. Workers are often not educated to report long-term discomfort or pain that may have been treated over months and years by a medical professional and never reported as work-related. They may need to report an injury on the day it occurs, a requirement not applicable to MSDs.

    “Workers often assume that MSDs are simply age-related or arthritic. The fact is, however, that whether an MSD is reported in the OSHA log or is ‘hidden’ by non-reporting, the company still pays for it, either through workers’ compensation or through its own health insurance premiums and medical claims. It will be of substantial benefit to draw further attention to the actual injury/illness picture by capturing MSD data. “

    According to AIHA, the association’s Ergonomics Committee “consists of dozens of certified ergonomists who practice in a wide variety of venues. They work for, with and within many U.S. companies who have already developed their own methodology of a daily MSD classification for all reported injuries.

    “These companies all use this classification as a simple method for focusing time, energy and financial health and safety and engineering efforts to reduce injuries.

    AIHA President Cole concludes her letter to Dr. Michaels writing: “As Dr. Laura Welch said in her March 9 testimony, having an MSD classification shows the patterns of injury. Patterns make it easy to devote time and dollars to that which costs a business in productivity and human suffering. The next step will be for companies to perform their own risk factor analyses and functional job descriptions for work tasks that are present for job classifications with high rates of MSDs.”