UAW Commentary

The Administration, in a concession to management, has deleted the column for musculoskeletal disorders from the new OSHA 300 form. This means that the previous listing for CTDs on the summary is gone. UAW Local Union representatives will therefore have to do this analysis themselves, rather than rely on the plant medical department or safety office to do it for them.

Local union representatives must obtain a copy of the OSHA 300 form, and review each diagnosis. Any strain or sprain injury not associated with another traumatic event such a trip, slip or fall, should be considered an MSD. Most such incidents are acute flare-ups of chronic conditions. Specific diagnoses of CTDs, or conditions listed as "pain" without a diagnosis should also be considered MSDs. The Health and Safety Department suggests that the most efficient way of doing this would be to obtain hard copy OSHA 301 and OSHA 300 forms, and mark these directly on the form itself.

Since the change in form is effective on January 1st, 2002, local union representative should begin this reanalysis at the start of the new year.

An ergonomic job analysis should be performed on each workstation where an MSD was reported within two months. A job correction should be implemented within six months of the completion of the job analysis.

In addition, the Administration has deleted the column for noise induced hearing loss. Employers are now free to omit recording of instances of standard threshold shift. However, under the noise standard, employers are still required to keep such a list. Local union representatives should, each year, obtain a list of persons who have received audiometric exams, and been diagnosed with standard threshold shift. In addition, local union representatives should verify that all persons in high noise areas have received their audiogram each year as required by the noise standard.