Physical therapy, therapeutic exercise, chiropractic care, Oh My!
When a worker gets hurt on the job, whether it’s a strained back from lifting or a sore shoulder from overhead work, the road to recovery often includes more than just rest and ice. Physical therapy, chiropractic care, and therapeutic exercise are common methods to treat these conditions, but they can also carry important implications for OSHA recordkeeping.
So, when do these treatment methods become recordable under OSHA’s rules? Let’s break it down.
What is recordable?
The first question to answer is what does “recordable” mean? Not all injuries are recorded on OSHA 300 logs. The agency outlines the criteria for recordability under 29 CFR 1904.7, which states that a work-related injury or illness is recordable if it results in:
- Death
- Days away from work
- Restricted work or job transfer
- Medical treatment beyond first aid
- Loss of consciousness
- Diagnosis of a significant injury or illness
How do I know if medical treatment is considered beyond first aid?
OSHA’s final rule on recordkeeping clearly states that if medical care includes treatments such as stitches, prescription medications, or the use of a rigid splint, the incident must be recorded. In contrast, first aid measures, like bandages, non-prescription pain relievers, or even massages, do not trigger recordability.
OSHA provides a list of what is considered first aid for recordkeeping purposes at 1904.7(b)(5)(ii), even stating, “this is a complete list of all treatments considered first aid for part 1904 purposes.”
Even if first aid care is repeated or provided by a licensed professional, that doesn’t make the injury recordable. Additional criteria like lost time or restricted work must also apply.
The most important thing to remember is that if it is not on the list, it is considered medical treatment beyond first aid for OSHA recordkeeping purposes.
Is physical therapy or chiropractic care recordable?
OSHA is pretty clear that both physical therapy and chiropractic care are considered medical treatment beyond first aid. That means any use of these treatments for a work-related injury or illness makes the case recordable.
1904.7(b)(5)(ii)(M) Physical therapy or chiropractic treatment are considered medical treatment for recordkeeping purposes and are not considered first aid.
Additionally, OSHA clarified that even one session may be recordable if it’s part of a treatment plan and it doesn’t matter whether treatment happens on-site or off-site.
Is exercise recordable?
Therapeutic exercise might seem like a simple stretching routine or light movement, but if it’s prescribed by a healthcare provider to treat a specific work-related injury, it’s considered medical treatment beyond first aid, and that makes it recordable.
In fact, OSHA has clarified this in a 2010 letter of interpretation, stating that it “considers therapeutic exercise as a form of physical therapy and intentionally did not include it as a first aid treatment.” Even if the exercises seem non-invasive or low impact, the key factor is intent, if they’re prescribed to treat a work-related injury, they are recordable.
However, one important thing to note is that preventive exercises like pre-shift stretching routines or ergonomic warm-ups are not recordable unless they’re part of a treatment plan for a diagnosed condition.
Key to remember: Physical therapy, chiropractic care, and therapeutic exercise are recordable if prescribed for a work-related injury. Even one session counts as medical treatment beyond first aid.
