Workplace Exercises and OSHA Recordability

This blog is based on this question that I was asked recently:  Our company is looking to reduce our recordable injuries.  We are thinking about having a physical therapist or someone like yourself to come in and observe our employees for safety and ergonomics.  Our intention is to have the employees be instructed in proper exercises they can perform to prevent injuries.  What do you think of this idea?  From HR Director of manufacturing firm

I’m glad to hear your goal is to reduce employee injuries, specifically OSHA recordable ones.  There are three ways to go about reducing injuries:  1) Focus on the employees and change them to fit the job, 2) Focus on the one specific workstation/area and make changes to it and 3) Focus on the work system that surrounds the problem area and make changes upstream and downstream to positively effect the entire work flow.  My experience has shown that focusing on the all three, with a greater emphasis on the second and third way produces more effective, sustainable results compared to focusing on changing people.  This isn’t to say that stretching and other exercises are never appropriate, but the return on investment is far greater when making changes to how the work gets done. 

However I must make you aware to a common and pervasive false belief when it comes to instructing employees in specific exercises.  OSHA has made ruling that providing custom exercises for specific employees is “medical treatment” and therefore is OSHA Recordable.  Note:  this does not apply for general stretching programs that are instructed and performed by all employees on the shop floor. 

If I understand you correctly, you are wanting an experienced ergonomist to come in, observe the work performed by each employee and provide individual instruction on what changes they should do in order for them to do the job safer and to instruct in specific exercises (OSHA calls this “therapeutic exercise”) to prevent//minimize injury.  Instructing employees how position him/herself better to do the job IS NOT OSHA recordable.  Providing specific exercises for that employee(s) to lower the risk of injury IS OSHA recordable. 

Here are two links that further explain OSHA’S position on this:

https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=27674

https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=27698