Decoding OSHA’s Latest Guidance on Recordable Musculoskeletal Injuries
OSHA guidelines can be confusing, even to the most seasoned HR pro. Recently, OSHA issued a memorandum with the subject line “Enforcement Guidance Under OSHA’s Recordkeeping Regulation When First Aid, Active Release Techniques (ART), and Exercise/Stretching Are Used to Treat Musculoskeletal Injuries and Illnesses.” Quite the subject line!
The Administration provided guidance on whether or not musculoskeletal injuries and illnesses are recordable, if the only treatment provided is first aid, Active Release Techniques (ART), and/or exercises and stretching. At Amp Health, we’re particularly interested in the section on exercises and stretching.
All of the information in the memo is associated with OSHA’s section 1904.7, which states that “a work-related injury or illness meets the general recording criteria if it results in any of the following: death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, or loss of consciousness.”
That’s all fairly clear, but then OSHA adds, “In addition, a case that involves a significant injury or illness diagnosed by a physician or other licensed health care professional meets the general recording criteria even if it does not result in death, days away from work, restricted work or job transfer, medical treatment beyond first aid, or loss of consciousness.”
First Aid
The memo deals specifically with musculoskeletal injuries, and notes each criteria operates independently of the others, so if an injury only requires first aid, but also results in a work restriction, it’s reportable. OSHA also defines first aid, and notes that first aid can be administered by anyone, regardless of their professional status or job title.
ART
After defining first aid, the memo discusses ART, which is considered “massage” by OSHA and is classified as first aid. As long as ART is the only treatment provided to a worker, it’s considered first aid and isn’t recordable.
Exercise and Stretching
Since exercise and stretching can be used to both prevent (preferable) and to treat injuries, there may be some confusion. However, the OSHA memo states:
“If, as part of an employee wellness program, a Certified Athletic Trainer (ATC) recommends a daily pre-shift exercise to employees who do not exhibit signs or symptoms of an abnormal condition, there is no case to record. In order for an exercise or stretching program to be considered medical treatment beyond first aid, there must first be a work-related injury or illness.”
In other words, if an employee is taking part in a preventative exercise or stretching program in order to prevent injuries, there’s no case to record. The memo adds that if a worker sustains an injury outside of work, and exercise or stretching is part of the treatment, it’s not recordable—even if they need to do the exercise and stretching at work. The memo reiterates, “Again, for a case to be recordable, a work-related injury or illness must exist.”
Get the Benefits and Avoid Recordable Events
No one wants OSHA recordable events. Employees don’t want to be hurt or sick. HR doesn’t want the extra work. The C-suite doesn’t want the loss of productivity and other expenses that can come along with recordable injuries and illnesses.
Amp Health gives you tools to avoid work-related injuries and illnesses by assessing the risk of musculoskeletal injuries, helping to manage that risk, and ultimately preventing injuries from happening to begin with.