Musculoskeletal disorders are some of the most common workplace injuries and OSHA is increasing its focus on ergonomic conditions. Employers should consider recommending stretches or simple exercises to help reduce injury risk, along with other ergonomic evaluations.
Developing a set of suggested stretches also provides an option for workers to alleviate minor discomfort without creating an OSHA-recordable case. Exercises recommended to treat a condition count as medical treatment for OSHA recordkeeping, but preventative exercises do not make a case recordable.
Many employers suggest simple exercises for computer users such as back, neck, and shoulder stretches. Employers could recommend similar wellness exercises for employees in other jobs. In a letter of interpretation (LOI) dated September 9, 2016, OSHA noted:
“Exercises that are generally part of safe work practices commonly recommended for anyone engaged in certain tasks or working with certain equipment are not considered medical treatment.”
For example, if a material handler experiences discomfort from performing job duties, then following the recommended wellness exercises to address the discomfort would not make a case recordable – even if the employee had not previously been performing those exercises.
Another LOI dated December 14, 2015, stated that if an employer implements a stretching program and an employee reports discomfort, a recommendation to continue those stretches would not be medical treatment. The employee would simply be following a preventative practice for all workers in that job.
However, if an employee experiences signs or symptoms of an injury or illness, then new or different exercises to alleviate that condition would count as medical treatment. The December 2015 letter said that “stretching exercises constitute medical treatment when they are recommended as a new course of action to address an employee’s work-related condition or disorder.”
For example, if the employer suggests stretching twice per day, but a medical professional recommends different exercises (or recommends the wellness stretches four times per day) to alleviate the disorder, the change would count as medical treatment.
Distinguishing between normal soreness and an “abnormal condition or disorder” (which is how OSHA defines an injury or illness) can be challenging. According to another LOI dated January 25, 2010, simple muscle soreness from starting a new work activity is not an “abnormal condition” and therefore not an injury or illness. However, that letter warns that subjective signs including “pain or other symptoms such as muscle soreness” could suggest that an abnormal condition exists.
Employers should work with employees to determine the causes and seriousness of the condition. Sore muscles should recover fairly quickly, but soreness that continues for days or restricts the range of motion may suggest an injury.
Although normal muscle soreness is not an “abnormal condition,” it could provide a warning that a serious condition is developing. Encouraging early reporting of symptoms can help the employer identify interventions (like stretching or an ergonomic evaluation) that could prevent a more serious condition.
In addition, encourage employees to report non-work conditions. If a non-work condition gets aggravated at work, it could become a recordable case. Ergonomic conditions often raise the challenge of determining how much the job duties contributed when evaluating workers’ compensation coverage. Suggesting stretching, exercises, or even restrictions for a non-work condition does not create a recordable case and may prevent a more serious (and work-related) condition from developing.
Even if an employee’s injury starts at home, any aggravation at work that results in new medical treatment creates a recordable case on the OSHA 300 Log. Tracking incidents can be a challenge, and even an employer with a strong safety record could end up recording cases. The Incident Center in the J. J. Keller® SAFETY MANAGEMENT SUITE helps you track recordable cases, count days away or restriction, and create the annual summary.