OSHA & reporting exercise recommendations on the OSHA 300 log

OSHA releases interpretation letter on the requirements for reporting exercise recommendations on the OSHA 300 log

In an interpretation letter dated September 9, 2016, the Occupational Safety and Health Administration (OSHA) clarified the requirement to record exercise recommendations on the OSHA 300 log.

The letter differentiates between preventative exercise as an intervention strategy and therapeutic exercise used to treat a work-related injury or illness.

OSHA’s recordkeeping regulation, 29 CFR 1904 does require the recording of therapeutic exercise when used to address the symptoms of a work-related injury or illness.

This is because OSHA considers therapeutic exercise as a form of physical therapy which is not included in OSHA’s list of first aid treatments, exempt from the recording requirement.

However, OSHA does not require employers to record exercise prescribed as a purely precautionary measure to an employee who does not exhibit any signs or symptoms of an injury or illness. OSHA provides examples of preventative exercise, such as minor exercises for computer users to minimize the potential for musculoskeletal disorders, or stretching for employees driving long distances.

OSHA also does not require the recording of exercise prescribed for injuries or illnesses that are not work-related.