The federal Occupational Safety and Health Administration (OSHA) may not have immediate plans to include a musculoskeletal disorder (MSD) column on the OSHA 300 Log, but their interpretation letters keep inching closer to employers having to record MSDs anyway. In its most recently released interpretation letter, OSHA indicated that an exercise regimen recommended by a certified athletic trainer to relieve symptoms of a work-related injury or illness would constitute medical treatment for recordkeeping purposes. Exercises such as stretching or light weight training to strengthen muscles would fit within the definition of medical treatment if recommended to manage symptoms of a work-related injury/illness. However, if the exercise is recommended merely as a precautionary measure (i.e. before the onset of symptoms), then it would not constitute medical treatment for purposes of recordability.
Tips: This interpretation letter comes just a few short months after OSHA released another interpretation letter dealing with MSDs, whereby OSHA said that even a one-time therapeutic treatment would constitute medical treatment for recordkeeping purposes. OSHAs message from this guidance is clear: if an employee receives any treatment in response to symptoms caused by a work-related injury or illness, you should consider it medical treatment. If you have questions about whether something should be recorded on your injury/illness log, contact your Vigilant safety professional.
The federal Occupational Safety and Health Administration (OSHA) may not have immediate plans to include a musculoskeletal disorder (MSD) column on the OSHA 300 Log, but their interpretation letters keep inching closer to employers having to record MSDs anyway.
