When is exercise recordable? OSHA letter aims to clarify

Washington – A recent letter of interpretation from OSHA offers clarification on when the recommendation or use of exercise should be recorded on the OSHA 300 log.

The letter is in response to an inquiry from Scott Ege of Rockton, IL-based Ege WorkSmart Solutions. Ege asked OSHA to elaborate on the differences between the use of preventive exercise as an intervention strategy and therapeutic exercise used to treat a work-related injury or illness.

“Therapeutic exercise is bodily movement prescribed to correct impairment, improve musculoskeletal function, or maintain a state of well-being,” Amanda Edens, director of OSHA’s Directorate of Technical Support and Emergency Management, wrote in the Sept. 9 letter. “Therapeutic exercise is considered medical treatment when it is designed and administered to combat a particular injury, illness, or disorder as part of a treatment plan that includes termination of the therapeutic exercise once the objectives of its implementation have been met. Please be aware that if a treatment is administered as a purely precautionary measure to an employee who does not exhibit any signs or symptoms of an injury or illness, the case is not recordable. For a case to be recordable, an injury or illness must exist.”