The National Association of Chemical Distributors (NACD) submitted comments to the Occupational Safety and Health Administration (OSHA), expressing concern over a proposal that would require employers to record musculoskeletal disorders (MSD) in a separate column under the Summary of Work-Related Injuries and Illnesses 300 Log.
“NACD members, through Responsible Distribution, are committed to the highest standards of workplace safety, as our safety data results year after year continue to prove. Placing an unreasonable and unnecessary burden on these Responsible Distributors is counterproductive to the overall goal of increased worker safety,” said NACD President Chris Jahn. “OSHA's MSD proposal would cost money and resources in an economy where many businesses continue to struggle.”
The comments specifically mention concerns with an increase in costs of software, employee screening, and staff resources. They also express concerns over the difficulty for employers to fully comply with the rule.
“The purpose of the OSHA 300 Log is to record illnesses and injuries experienced as a result of work,” said NACD in its comments. “This log has been an effective way to clearly track work-related injuries and illnesses. A requirement to track MSD injuries and illnesses is not nearly as clear because it is extremely difficult to determine whether an MSD is work- or non-work-related. Accurately reporting chronic and acute MSDs is not adequately addressed in this proposed rule and could lead to confusion and lack of compliance.”
NACD also expressed the concern that OSHA's proposed rule could be used beyond its stated uses of data collection. “NACD is concerned that the proposed rule, which will result in a negative economic impact for the chemical distribution industry, is a prelude towards a more expansive and burdensome ergonomics framework. We request that OSHA clarify in its final rule the potential uses, if any, for an MSD column outside of its stated purpose of accurate data collection for the Bureau of Labor Statistics.”
To read NACD's comments, access www.nacd.com/docs/advocacy/2010/pdf/NACDOSHAMSDComments033010.pdf.