Quarter Two 2024

New OSHA Guidance on Stretching Exercises Used to Treat or Prevent MSDs

The Occupational Safety and Health Administration (OSHA) has issued new guidance for its inspectors regarding the recordability of Active Release Techniques (ART) and stretching exercises used by employers to prevent or treat musculoskeletal disorders (MSDs) in the workplace. The guidance clarifies that employers must be cautious about recommending these techniques, as OSHA may consider them recordable injuries under its injury and illness recordkeeping regulation.

Employers are required to maintain records under OSHA’s regulation (29 CFR § 1904), documenting injuries or illnesses that result in various outcomes like medical treatment beyond first aid, restricted work, or other specified conditions. The definition of “injury or illness” includes abnormal conditions or disorders, which can be based on subjective signs like an employee’s report of pain, not just objective medical evidence.

The guidance distinguishes between recommended stretching for general soreness (not recordable) and stretching recommended for an abnormal condition or disorder (potentially recordable). OSHA’s recent memorandum aims to clarify its stance on what constitutes “medical treatment beyond first aid,” providing direction for employers implementing ART and stretching programs to ensure compliance with recordkeeping requirements.

This new guideline gives Compliance Safety and Health Officers (CSHOs) the authority to issue citations under the medical services and first aid standard (29 CFR § 1910.151(a)). Employers must consistently oversee employees’ first aid and medical care requests to ensure they receive appropriate treatment. Failing to assess the need for further treatment could lead to citations.

Exercise and stretching, which are generally part of safe work practices, can continue to be recommended for tasks or equipment handling. However, following recent guidelines, employers should link stretching recommendations to precautionary measures that workers can adopt.

Furthermore, employers should monitor the frequency of stretching used as first aid to avoid giving the impression that adequate medical care isn’t being provided to injured or ill employees. This means not repeatedly applying first aid treatments to the same worker for the same concerns.