First Aid and OSHA Recordables, a Follow-up: Can Workplace Exercise Qualify as Recordable Medical Treatment?

[fa icon="calendar'] Apr 20, 2016 8:00:00 AM / by Deborah Lechner

Some time ago we presented a post on first aid and OSHA recordable injuries in the workplace, and since we've received a great deal of feedback on that post, we thought some follow-up would be in order. One particular issue mentioned in that piece that sparked a fair bit of feedback was workplace exercise, which, in some circumstances, can be considered physical therapy under OSHA regulations. Here we'll clarify that issue, helping employers understand when, according to OSHA, workplace stretching or other exercises can cross the line from first aid to OSHA recordable medical treatment.OSHA classifies any on-the-job injury or illness as a recordable event if it requires medical treatment beyond first aid. Under OSHA guidelines, exercises tailored to address specific employee complaints are considered medical treatment that goes beyond first aid. So does that mean that workplace stretching and/or exercise programs designed to aid in preventing such complaints are off-limits? Not at all – provided you take care to keep your program on the right side of that first aid/recordables line.

When it comes to workplace exercise, staying on the right side of OSHA regulations is all about specificity, timing, and consistency. No exercises are off-limits in terms of OSHA compliance so long as they are job-specific rather than injury specific. By job-specific, we mean exercises designed specifically for a given job and for the prevention of injury for all employees performing that job.

In using the exercise approach for prevention, the clinician is merely reminding the employee with discomfort to do the job-specific exercises that have been previously established as beneficial for anyone doing the job. In most cases, these previously established exercises will benefit the employee with the complaint as well. And if there is a reason not to do the job-specific exercises, that can be pointed out to the employee too.

It is best, in terms of compliance, if your stretching/exercise program is in place before an employee complains of work-related pain or injury, and if all employees performing similar duties have been instructed in these job-specific exercises. To include exercise as part of the prevention experience for the employee, takes some planning to develop and implement job-specific exercises in advance.

Why is the inclusion of exercise in prevention efforts so important? A literature review conducted by Linton and van Tulder, published in Spine in 2001, examined 27 studies that met their criteria as having adequate scientific merit to be included in their review.

These investigators examined the relative effectiveness of back braces, education programs, ergonomics, risk factor modification, and exercises. Of all the prevention interventions examined, exercise was the only intervention that showed consistently positive effects on prevention.

Preventing Workplace Injuries

Why are these points so important to compliance? An exercise/stretching program that is specifically tailored for the physical demands of the jobs in your workplace and designed to aid in reducing physical strain on all employees performing those jobs – as opposed to singling out employees who may be feeling that strain – is clearly an injury prevention program.

Should a complaint of pain, stiffness or injury arise, your exercise program cannot be interpreted as medical treatment prescribed in response to that specific workplace injury or incident. Additionally, the employee can be reminded to perform the job-specific stretches/exercises that they and their co-workers have previously been taught and should have been doing all along. That recommendation will not, under these circumstances, place those exercises into OSHA's medical treatment beyond first aid category.

Topics: Legal Issues, OSHA Requirements

Deborah Lechner

Written by Deborah Lechner

Deborah Lechner, ErgoScience President, combines an extensive research background with 25-plus years of clinical experience. Under her leadership, ErgoScience continues to use the science of work to improve workplace safety, productivity and profitability.