Which musculoskeletal treatments are recordable? OSHA memo gives details

Washington — A new guidance memo from OSHA outlines whether certain treatments for musculoskeletal injuries are recordable.

One such treatment detailed in the memo is active release techniques, or ART – a “patented movement-based massage technique that targets soft tissues such as muscles, tendons, ligaments, fascia and nerves.” ART is usually performed by a physical therapist or chiropractor.

OSHA considers ART “massage,” which is on the list of first aid treatments under 1904.7(b)(5)(ii). So, the agency considers ART “to be first aid regardless of the professional status of the person providing the treatment.”

The memo directs OSHA compliance safety and health officers to interview an injured worker to determine the type and extent of treatment.

“For example, an injury would be recordable if the application of ART exceeds what is considered ‘massage’ (e.g., the practitioner applies ART in a way that results in manipulation of the skeleton). However, in some cases, the injured employee may not be able to provide detailed information about the type of treatment they received.

“Accordingly, since licensed practitioners, whether chiropractors, physical therapists or others, are all obligated to maintain records concerning patient condition and treatments provided, the CSHO should also request access to review those records.”

OSHA notes that ART practitioners can’t make recommendations on work restrictions, and making those recommendations “means they are not practicing ART.”

Stretching or therapeutic exercise isn’t included on the list of first aid treatments for musculoskeletal injuries and is considered medical treatment when used for a particular work-related injury or illness.

“If an employee exhibits symptoms of a work-related injury or illness, the recommendation to conduct exercise/stretching, either at work or at home, to treat a work-related injury or illness makes the case recordable, regardless of the professional status of the person making the recommendation,” the memo states.

Daily pre-shift stretching for “employees who do not exhibit signs or symptoms of an abnormal condition” isn’t part of the recording criteria.