Question: An employee reports minor work-related pain in their hips and the occupational health nurse provides the employee with therapeutic exercises and stretches. Is it recordable?
Answer: YES. Therapeutic exercise is considered medical treatment and therefore is considered to be recordable if it results from a work-related injury.
Letter of Interpretation: If a physician or licensed health care professional recommends therapeutic exercise in response to a work-related injury or illness, the case is considered to involve medical treatment and the case is recordable.
OSHA addressed the topic of therapeutic exercise in the preamble to the final rule for recording and reporting occupational injuries and illnesses (FR 66:13, page 5992). OSHA stated that it considers therapeutic exercise as a form of physical therapy and intentionally did not include it as a first aid treatment under 1904.7(b)(5)(ii). 1904.7(b)(5)(ii)(M) states that physical therapy or chiropractic treatment are considered medical treatment for recordkeeping purposes and are not considered first aid. 1904.7(b)(5)(ii) states that the treatments included under 1904.7(b)(5)(ii) is a comprehensive list of first aid treatments.
Any treatment not included on this list is not considered first aid for OSHA recordkeeping purposes.