Recent data from the U.S. Bureau of Labor Statistics shows that nearly one million musculoskeletal disorders (MSDs) resulted in days away from work, job restrictions, or transfers (DART) in the private sector during 2021-2022. These disorders—ranging from back pain and muscle strains to tendonitis and carpal tunnel syndrome—represent a significant challenge for employers across industries.
At OccMedMD, Dr. John Webb specializes in helping employers navigate the complex OSHA requirements surrounding musculoskeletal injuries while providing effective treatment for affected workers. Understanding which treatments require OSHA recording and which don’t can significantly impact your company’s safety metrics and regulatory compliance.
OSHA Recording Guidelines for Musculoskeletal Treatments
Musculoskeletal injuries affect the body’s movement system—bones, muscles, tendons, ligaments, joints, and supporting tissues. Common workplace risk factors include repetitive motions, awkward postures, excessive force, and poor ergonomics. When these injuries occur, the level of medical intervention determines whether the incident must be recorded on your OSHA logs.
First Aid Treatments (Non-Recordable)
According to OSHA regulation 29 CFR 1904.7(b)(5)(ii), the following musculoskeletal treatments are considered first aid and do not require recording:
- Application of bandages, gauze pads, or similar dressings
- Hot or cold therapy
- Non-prescription medication at non-prescription strength
- Basic massage (not including specific therapeutic techniques)
- Temporary immobilization devices during transport
Dr. Webb advises employers that these first aid measures can effectively treat many minor musculoskeletal conditions without triggering OSHA recording requirements. However, he cautions that repeated administration of first aid for the same condition within four weeks may indicate an unreported injury that could draw OSHA scrutiny.
Active Release Technique (ART) and Soft Tissue Therapy
Active Release Technique is commonly used to address musculoskeletal conditions in industrial settings. Dr. Webb explains that ART is generally considered first aid (and thus non-recordable) when limited to soft tissue massage, regardless of who administers it.
However, important distinctions exist:
- ART or soft tissue work that involves manipulation of the skeletal system becomes recordable
- ART that extends beyond conventional massage techniques is considered medical treatment
- Extended or repeated ART for the same condition may become recordable
- ART practitioners must not provide work restriction recommendations to maintain non-recordable status
At OccMedMD, Dr. Webb ensures all soft tissue therapies are properly classified and documented to maintain OSHA compliance.
Exercise and Stretching Programs
Dr. Webb advises that prescribed exercises or stretching routines specifically recommended as treatment for a workplace musculoskeletal injury are considered medical treatment and require OSHA recording. The professional status of the person prescribing these exercises doesn’t affect this requirement.
It’s important to note that general wellness programs that include stretching and exercise—when not prescribed for specific injuries—are not considered medical treatments and don’t require recording.
The Importance of Proper OSHA Recording
Dr. Webb emphasizes that accurate OSHA record keeping serves several critical purposes:
- Avoids unnecessary recording of minor injuries that can be properly managed as first aid
- Maintains transparent compliance with regulatory requirements
- Ensures consistency in communication between employers, employees, and healthcare providers
- Builds trust with your workforce through proper injury management
- Helps control healthcare costs by appropriately classifying treatments
When employers partner with OccMedMD, Dr. Webb’s expertise ensures proper classification of treatments while providing effective care for injured workers.
Healthcare Provider Responsibilities
As an occupational medicine physician, Dr. Webb maintains detailed documentation of all patient evaluations and treatments. This thorough approach ensures:
- Complete medical records that properly classify treatments as first aid or medical intervention
- Appropriate documentation if OSHA officials request clarification
- Clear communication with employers about recordability determinations
- Consistent application of OSHA guidelines across all patient interactions
Early Intervention: The Key to Minimizing Recordable Injuries
Dr. Webb strongly advocates for early intervention as the most effective strategy for managing musculoskeletal conditions. When employees receive prompt assessment and appropriate first aid measures, many conditions can be effectively managed without progressing to the point of requiring recordable medical treatment.
OccMedMD’s early intervention approach includes:
- Immediate telephone triage with Dr. Webb when injuries occur
- Expert assessment to determine appropriate treatment level
- Provision of specialized first aid kits tailored to common industry-specific injuries
- Training for supervisors on appropriate first aid measures
- Development of ergonomic programs to prevent musculoskeletal disorders
OccMedMD’s Approach to Musculoskeletal Treatment
Dr. John Webb has developed comprehensive protocols for managing workplace musculoskeletal conditions while maintaining OSHA compliance:
- Thorough evaluation of each injury to determine appropriate classification
- Clear documentation of all treatments provided
- Appropriate use of first aid measures when indicated
- Development of ergonomic interventions to prevent recurrence
- Regular follow-up to ensure proper healing and prevent progression
For employers concerned about both worker health and OSHA recordability, OccMedMD provides the expertise needed to navigate these complex requirements.
Partner with OccMedMD for Expert Guidance
Understanding which musculoskeletal treatments require OSHA recording can be challenging. At OccMedMD, Dr. John Webb combines extensive occupational medicine experience with detailed knowledge of OSHA regulations to help employers maintain compliance while providing excellent care for injured workers.
Our services include:
- Expert classification of treatments as recordable or non-recordable
- Development of customized first aid protocols for common workplace injuries
- Training for supervisors on proper injury response
- Ergonomic assessments to prevent musculoskeletal disorders
- Comprehensive documentation to support OSHA compliance
For assistance with workplace musculoskeletal conditions or questions about OSHA recordability, contact OccMedMD at (314) 370-2737 or email wc@occmedmd.com. For immediate injury triage, call our 24/7 line at (314) 370-2737.