On May 21, 2010 OSHA published an interpretation relating to exercise that has caused some confusion and concern among safety and human resource managers.

You can read the full interpretation here.

Specifically, the interpretation request asked if “exercise is considered medical treatment” as defined in OSHA’s recordkeeping regulations.

OSHA’s response was, “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.”

Where the Confusion Occurs

Note that although the question posed to OSHA asked if “exercise is considered medical treatment”, OSHA’s response specifies “therapeutic exercise in response to a work-related injury or illness.” OSHA states in its response that it considers “therapeutic exercise” a form of physical therapy, and that physical therapy is considered medical treatment for recordkeeping purposes.

The purpose of this paper is to clear up any confusion and lay the groundwork for identifying the most effective injury prevention strategy.

Therapeutic vs Preventive Exercise

All forms of exercise are not “therapeutic” and many forms of exercise are preventive in nature. It’s instructive to further define these two forms of exercise:

Therapeutic exercise (reactive) – Physical therapy and therapeutic exercise are prescribed by a physician as part of a treatment plan in response to a diagnosed injury or illness. Practice acts in most states prohibit physical therapist, athletic trainers, and other health care providers from providing therapeutic exercise without a written order from the physician.

• Therapeutic exercise, prescribed by a physician in response to a work-related injury or illness, is an OSHA recordable case.

When an injury occurs, therapeutic exercise can be prescribed as part of a treatment plan.

Preventive exercise (proactive) – Preventive exercise is recommended by a wide range of health experts and can be used by individuals and employees to attain a variety of proven health benefits including enhanced wellness and prevention of injury and illness.

• Preventive exercise is not considered medical treatment, and therefore is not an OSHA recordable case.

Before an injury occurs, preventive exercise, in combination with other injury prevention tools, can be used to counteract daily fatigue to prevent an injury from occurring.

What We Practice

The early intervention strategy employed by the Injury Prevention Specialists at ErgoPlus is about prevention, not treatment.

Preventive consultations are available to each and every employee. The self-help techniques recommended are not therapeutic in nature, and serve as a means to help employees counteract daily fatigue.

Employees are encouraged to seek self-help advice to prevent injury and illness. When an employee requests self-help advice for any concern (related to work activities or not) and does not desire or request a medical evaluation, our injury prevention specialists will consult with the employee to review and encourage a variety of prevention tools and techniques.

These techniques are advocated and reviewed in our injury prevention training program and in handouts or publications that are available to all employees.

These injury prevention tools include:

• preventive warm-up exercises
• proper lifting techniques
• proper body mechanics
• identification of ergonomic improvement opportunities
• preventive counteractive stretching exercises
• proper resting/sleeping posture
• strengthening exercises to maintain muscle and joint balance
• fatigue recovery and sleep
• proper hydration, proper nutrition
• adopting good health habits
• personal fitness and wellness

Our Approach

While we believe that ergonomics is a very important part of injury/illness prevention, this approach is not enough on its own because risk factors associated with the workplace are not the only causative factors. To focus solely on work risk factors would solve only one piece of the puzzle. Risk factors associated with the person, as well as the workplace, must not be overlooked. Employees need to be educated about the tools and techniques that they can employ to prevent injury and illness. Early preventive intervention is an important and effective education strategy to help employees prevent fatigue and discomfort that can turn into an injury or illness.

This strategy encourages employees to seek and utilize self-help advice from injury prevention specialists before reaching a point where pain develops and functional capacity is affected to the extent that medical treatment is required. This ounce of prevention will often help employees avoid pain and functional loss, which is always the right thing to do.

Summary

In summary, various types of exercises are employed for two reasons: 1) Reactively for injury and illness treatment and 2) Proactively to counteract hourly/daily fatigue, and to maintain or build strength and fitness levels in order to prevent injury and illness. So, how do we know if exercise is being used for treatment or prevention?

The following may help us answer this question.

You’ll know that exercise is being used for treatment (therapeutic exercise, recordable) when…

• there is a injury or illness diagnosed by a physician licensed to do so
• the treating physician prescribes therapeutic exercise
• the exercise prescription is for one person

You’ll know that exercise is being used for prevention (preventive exercise, not recordable) when…

• there is no diagnosed injury or illness
• there is no physician prescription for therapeutic exercise
• the exercises are recommended for all employees