MSD Column Withdrawn

Key Takeaways:

• OSHA has officially withdrawn its proposal to add a musculoskeletal disorder (MSD) column to the OSHA 300 Log, concluding it wouldn’t improve national statistics, enforcement, or workplace-level prevention. Employers will still record MSDs under existing rules, but without a separate column.
• At ErgoScience, we believe this is a missed opportunity. A dedicated MSD column would make these injuries more visible, help identify patterns earlier, and drive preventive action—especially for organizations without sophisticated tracking systems. MSDs remain one of the most costly and prevalent workplace injuries, and visibility is the first step toward prevention.

In a recent development, OSHA has officially withdrawn its proposal to amend the OSHA 300 Log to include a separate column for musculoskeletal disorders (MSDs). This decision, highlighted in Industrial Health and Safety News (ISHN) on July 18, 2025, reflects a long and complex rulemaking history and the agency’s conclusion that such a column would not significantly improve national injury data, aid enforcement, or support workplace-level interventions.

Background: The MSD Column—A Rulemaking Rollercoaster

OSHA first introduced the idea of an MSD-specific column on its injury and illness reporting form—the OSHA 300 Log—in 2001. The aim was to better identify and track work-related MSDs. However, the rule was delayed and ultimately revoked in 2003, with OSHA stating the data gained wouldn’t meaningfully improve injury statistics or enforcement capabilities.

The idea resurfaced in 2010, when OSHA reopened public comments and engaged small businesses in discussions. Despite these efforts, the agency has now decided to abandon the proposal once again.

Why OSHA Withdrew the Proposal

After reviewing updated comments and records, OSHA concluded that the arguments for the MSD column remain unchanged since 2003. Specifically, the data does not support the idea that such a column would:

1. Improve national injury statistics
2. Enhance OSHA’s enforcement capabilities
3. Provide useful data for employers or workers at the establishment level

Let’s look at each of these areas more closely.

1. No Clear Benefit to National Injury Statistics

Supporters of the MSD column argued it would provide better aggregate data and make it easier to estimate cases not resulting in days away from work (DAFW). However, OSHA found this reasoning flawed for several key reasons:

• Current Data is Sufficient: The Bureau of Labor Statistics (BLS) already collects detailed MSD data from DAFW cases, including affected body part and activity involved.
• Aggregate Data Is Not Actionable: A raw count of all MSDs—without context or specific case characteristics—would not offer helpful insights. It would group together a wide range of disorders (e.g., back pain, carpal tunnel, sprains) with different causes and treatments, making it difficult to analyze or act on.
• No New Evidence: Commenters failed to provide new or compelling information to counter OSHA's 2003 conclusion that the MSD column wouldn’t add value to existing BLS data.

Claims of Underreporting Not Substantiated

Some commenters argued that MSDs are underreported because employers keep workers on light duty or use medications to avoid classifying the injuries as DAFW. Others said an MSD column would raise awareness and lead to more accurate reporting.

OSHA disagreed, stating that:

• There’s no solid evidence proving employers manipulate records to avoid DAFW classifications.
• Adding a column wouldn’t change reporting obligations. Employers are already required to document MSDs under current rules, regardless of whether the term "MSD" is used.
• Better data still wouldn’t come from a checkbox. Without detailed characteristics, the raw number of MSD cases has limited value.

2. Would Not Improve OSHA’s Enforcement or Targeting

OSHA also found that adding an MSD column would not enhance its ability to target enforcement or outreach efforts. Here’s why:

• Lack of Detail: The column would simply indicate that an MSD occurred, without offering information about the nature of the injury or its cause—critical factors in determining workplace hazards.
• Existing Tools Are Better: OSHA already uses the detailed injury descriptions found in the 300 Logs and 301 Incident Reports, and the agency can request additional documentation during inspections if needed.
• Misleading Data Risks: A total number of MSDs without context might lead to poor policy decisions or misdirected enforcement efforts.

Some industry groups warned that an MSD column could give the illusion of insight without real clarity. For example, the U.S. Chamber of Commerce pointed out that unlike well-defined conditions such as hearing loss or respiratory illnesses, MSDs involve many different causes, making it difficult to act on aggregated data.

3. No Added Value at the Workplace Level

One of OSHA's major considerations was whether the MSD column would help employers and workers identify and address ergonomic risks in their workplaces. The conclusion: It wouldn’t.

• Employers Already Track MSDs: Many companies use more detailed internal systems to track and analyze injuries. For example, Dow Chemical and Domtar described robust internal databases that let them do trend analysis and prevention planning.
• Redundant and Unused: Small businesses noted during teleconferences that they primarily use the OSHA forms just for compliance—not for management decisions. Many rely on workers’ compensation reports or their own tools to analyze injury data.
• Column Wouldn’t Help Unions Much Either: While the AFL-CIO argued that an MSD column would ease retrospective analysis, OSHA responded that MSDs can already be identified from injury descriptions in the logs, and careful review is required either way.

Ultimately, OSHA determined that any value from the MSD column is already obtainable through existing means—just with a bit more effort. A checkbox would not replace the detailed analysis needed to link injuries to workplace conditions.

Real-World Examples Show MSD Column Would Be Redundant

Numerous companies and organizations submitted comments describing their own effective injury tracking systems:

• Dow Chemical: Uses a global injury database to track and prevent MSDs.
• Domtar: Analyzes MSD injuries by body part and incident type to develop corrective action plans.
• Long-Term Care (LTC) Providers: Use quality assurance teams and incident reports to monitor MSDs and argue that a column would just increase costs.

Even the United Food and Commercial Workers Union (UFCW) was able to perform meaningful analysis of MSDs in the meatpacking and poultry industries using existing 300 Logs—without the proposed column.

Final Thoughts: No Justification for the Change

OSHA emphasized that its withdrawal of the proposal does not affect existing employer obligations to record work-related injuries and illnesses, including MSDs. Employers must still fill out the 300 Log and 301 Incident Reports as usual.

But adding an MSD column would have:

• Introduced administrative work without producing actionable data
• Added complexity without improving national statistics
• Offered little help to OSHA’s enforcement and inspection processes
• Duplicated data; many employers already collect more effectively

In short, those proposing the change failed to demonstrate meaningful benefits in OSHA’s eyes.

OSHA’s Conclusion:

“MSD injuries are unique due to the variety of causes and symptoms. A simple column on the 300 Log would not provide the insight needed to address them effectively. The detailed information already collected remains the best way to understand and prevent these injuries.”

Bottom Line

• OSHA has withdrawn the proposal to add a musculoskeletal disorder (MSD) column to the 300 Log.
• The decision was based on a lack of compelling evidence that the column would improve statistics, enforcement, or workplace-level understanding of MSDs.
• Employers remain responsible for recording MSDs as part of injury and illness recordkeeping—but they won't be required to mark them in a separate column.

An MSD Consultant’s Viewpoint

As a consultant who works daily with employers, safety professionals, and frontline workers to prevent musculoskeletal disorders (MSDs), I respectfully disagree with OSHA’s recent decision to withdraw the proposal to add an MSD-specific column to the OSHA 300 Log. While the agency’s rationale is rooted in administrative pragmatism and statistical conservatism, the practical realities of injury prevention and workplace safety management tell a different story.

Here’s why the decision is a missed opportunity—and a step backward in efforts to reduce one of the most prevalent and costly workplace injury categories.

1. Aggregate Data Still Has Value—Even If Imperfect

OSHA argues that an MSD column would only produce aggregate numbers without detail, making it difficult to interpret. But in my experience, aggregate data is often the critical starting point for identifying injury trends.

An MSD column would:

• Flag patterns early: A sudden rise in MSDs—regardless of their cause—can alert safety professionals to a broader issue before it escalates.
• Facilitate targeted reviews: If one site reports significantly more MSDs than another, it prompts an internal investigation, even before deeper diagnostics begin.
• Encourage preventive action: Many companies react only when data is visible. A simple checkbox would make MSD trends easier to track, leading to faster intervention.

Perfect data should not be the enemy of actionable data. An MSD column would not replace detailed logs but complement them by offering a clearer signal that something needs attention.

2. The Current Reporting System Obscures MSD Visibility

OSHA claims that employers already record MSDs under various labels (e.g., "strained back") and that nothing prevents them from analyzing those logs. While true in theory, this assumes a level of data hygiene and consistency that simply doesn’t exist in many organizations.

In practice:

• MSDs are buried in general injury categories.
• Terminology varies from site to site and even among individuals filling out reports.
• Case-by-case review is time-consuming and unrealistic for most employers.

Without a distinct identifier, MSDs often go unrecognized and under-analyzed, especially when non-specialists review the data. Adding a checkbox would standardize and simplify identification, reducing the barrier to meaningful analysis.

3. A Column Would Drive Cultural and Behavioral Change

Even if the column adds only modest statistical benefit, it has symbolic and behavioral value:

• It signals to employers and workers that MSDs are important enough to be tracked distinctly, on par with other serious health conditions like respiratory illness or hearing loss.
• It raises awareness at the point of data entry, prompting more thoughtful classification of injuries.
• It gives unions and worker advocates a straightforward way to identify patterns and engage employers constructively on ergonomic issues.

The presence of a dedicated MSD column would encourage more proactive prevention efforts, instead of reactive responses after patterns become severe or chronic.

4. The Decision Ignores the Evolving Nature of MSDs and Work

OSHA’s rationale rests heavily on conclusions from 2003, reaffirmed without significant adjustment in 2025. But much has changed:

• The nature of work is shifting—with more warehousing and distribution, repetitive tasks, and longer work shifts contributing to new and more prevalent MSD risks.
• More companies are using predictive analytics and ergonomic software—tools that could easily integrate with a standardized MSD column to improve targeting and interventions.
• An MSD category is just a starting point for further assessment.

By relying on outdated reasoning, OSHA risks missing opportunities to modernize injury prevention to reflect today’s workplaces.

5. Most organizations lack adequate tracking.

While a few large corporations already track MSDs internally with sophisticated systems, as noted in OSHA’s summary, most do not — they lack ergonomic expertise, even if they can afford expensive analytical tools. Most organizations would benefit from a simple, low-burden MSD column.

The MSD checkbox would:

• Help them recognize patterns they might otherwise miss
• Guide resource allocation toward prevention
• Serve as a training prompt for injury recognition and reporting

Contrary to OSHA’s implication, the column would not be a redundant burden for these employers—it would be a practical tool.

6. Underreporting Is Real—and Easier Visibility Can Help

OSHA dismisses concerns about underreporting, suggesting there’s no evidence that employers avoid recording MSDs to game the system. As someone who audits injury logs regularly, I can say with confidence: underreporting is real, and MSDs are among the most misclassified or omitted injuries.

Why?

• They often develop over time, so causation is less clear.
• Workers may hesitate to report symptoms, fearing stigma or job loss.

A visible, dedicated column would provide a low-stakes way to capture and monitor MSDs—raising the overall level of honesty and transparency in reporting.

Conclusion: OSHA Missed a Chance to Make Prevention Easier

MSDs account for nearly one-third of all workplace injuries in the U.S. and lead to billions in costs, lost productivity, and pain. OSHA’s withdrawal of the MSD column proposal ignores the real-world utility of simple, structured data collection in driving injury prevention.

The MSD column will not solve all problems—but it would have:

• Made MSDs more visible
• Helped employers catch patterns earlier
• Provided a foundation for better analysis and intervention
• Sent a strong message that ergonomic injuries matter

In the field of prevention, visibility leads to action. OSHA had an opportunity to make one of the most common injury types more visible and easier to manage—and chose not to take it.

We urge OSHA to revisit this decision, engage directly with front-line safety professionals, and consider how a practical, low-burden change like the MSD column could support the mission of reducing preventable injuries nationwide.

At ErgoScience, we’ve spent decades helping employers transform that visibility into action - protecting employees, lowering costs, and building safer workplaces. Ready to see how we can help your organization? Book a call with us today.