Comments on Occupational Injury and Illness Recording

On behalf of the Retail Industry Leaders Association (RILA), I respectfully submit these comments in response to the Occupational Safety and Health Administration’s (OSHA) Proposed Rulemaking for Occupational Injury and Illness Recording and Reporting Requirements that was noticed in the Federal Register on January 29, 2010 (75 Federal Register 4728-4741). RILA recognizes the importance of accurate recordkeeping in helping the agency to address significant work-related safety and health issues. However, we are concerned about the proposed rulemaking and believe that restoring a column to the OSHA 300 Log to record work-related musculoskeletal disorders (MSD) would yield potentially misleading information about workplace injuries and illnesses. Retailers strive each day to provide a workplace that protects and prevents occupational injuries and illnesses and we want to ensure that the information your agency receives accurately reflects our challenges so that we can continue to decrease workplace injuries and illnesses.