Following its recent interpretation that "therapeutic exercise" constitutes medical treatment for OSHA recordability purposes, OSHA has now stated that an exercise regime recommended by a Certified Athletic Trainer for an employee who exhibits any signs or symptoms of a work-related injury involves medical treatment and is a recordable case.  OSHA made this interpretation in a letter recently posted on its website.

In the same letter, OSHA also provided guidance on whether specific types of exercise constitutes medical treatment.  OSHA states that if a Certified Athletic Trainer "utilizes stretching" to relieve symptoms of a work-related injury or illness, the "stretching" constitutes medical treatment.  OSHA also states that a written home exercise program provided by a Certified Athletic Trainer for signs or symptoms of a work-related injury or illness constitutes medical treatment for recordkeeping purposes.

OSHA’s interpretation is particularly important for musculoskeletal disorders (MSDs), as MSDs are often managed, in part, through exercise regimes.  OSHA does note in the letter that exercise given as a purely precautionary measure (i.e., before the onsite of signs or symptoms) would not qualify for recordability.  However, if an employee experiences any signs or symptoms of a work-related injury or illness — even very early signs or symptoms — exercise given to manage those signs or symptoms would constitute medical treatment for recordability purposes.

Employers should take note of this new interpretation and adjust their recordkeeping practices accordingly.