As therapists, we prescribe stretching and strengthening exercises all the time. It's a fundamental part of what we do, and most of us probably don't think twice about recommending a few exercises when someone complains of discomfort. But when you're working in occupational health, that seemingly simple recommendation can have implications that many clinicians don't fully understand. Under OSHA recordkeeping regulations, prescribing therapeutic stretching or strengthening exercises to treat a work-related injury is generally considered medical treatment beyond first aid, which can make the injury OSHA recordable. This applies regardless of whether the recommendation comes from a physical therapist, occupational therapist, athletic trainer, or another individual. OSHA is concerned with the treatment being provided, not simply who is providing it.
Consider an employee working in a manufacturing facility who reports shoulder discomfort after performing repetitive work. They visit an onsite clinician who performs a brief assessment and recommends a few stretches to address the symptoms. From a clinical perspective, that may seem like a reasonable and relatively minor intervention. However, if those exercises are being prescribed to treat a work-related condition, the clinician has likely provided medical treatment beyond first aid. The employee may not have missed any work, required a physician visit, or received anything that we would traditionally consider significant medical treatment, but the exercise prescription alone can be enough to make the case recordable. I think this is something many clinicians overlook, particularly those who transition from traditional rehabilitation into occupational health and early intervention programs.
This brings me to workplace stretching programs, which I believe have value for several reasons, although maybe not the reasons we have historically promoted. We have been using stretching programs in industrial environments for decades, often with the idea that they will reduce workplace injuries. The research, however, has not consistently demonstrated that stretching alone is effective at reducing injury rates. That doesn't mean these programs are without value. I think we need to look at them a little differently and recognize the other benefits they can provide to both employees and employers.
One of those benefits is having an established stretching and movement program that is available to an entire department or workforce rather than being developed specifically for an employee who is experiencing discomfort. OSHA recognizes a distinction between general wellness activities and therapeutic exercises prescribed to treat a particular work-related injury. For example, if an employer has an established stretching program that employees participate in at the beginning of their shifts, an employee who later experiences discomfort can continue participating in that routine without the routine automatically becoming medical treatment. However, the distinction is important. If a clinician specifically recommends those same exercises as treatment for an employee's work-related injury, or modifies the program to address that individual's symptoms, it may constitute medical treatment beyond first aid. Having an established program does not provide a way around OSHA recordkeeping requirements, but it does give employees access to general wellness activities that exist independently of an injury.
I also believe these programs create an opportunity for employees to become more aware of how their bodies are feeling. Think about how many people arrive at work, begin their shift, and immediately start performing physically demanding tasks without giving much thought to how they feel that day. A few minutes of stretching or movement may help someone recognize that their shoulder feels tighter than usual, their back is bothering them, or a particular movement is uncomfortable. That doesn't necessarily mean an injury has occurred, but it creates an opportunity for greater awareness and potentially an earlier conversation about discomfort or changes in physical function. I think that awareness is valuable, especially in environments where employees perform repetitive or physically demanding work throughout the day.
There is also something to be said about what these programs communicate to employees. When an employer dedicates time during the workday to stretching, movement, or other wellness activities, it demonstrates an interest in employee health. Of course, that commitment needs to go beyond having everyone stretch for five minutes before their shift. We cannot expect stretching to compensate for excessive force requirements, repetitive activities, awkward postures, or inadequate recovery time. Those exposures still need to be addressed through ergonomics, job design, and other workplace improvements. But when stretching programs are part of a broader effort to improve employee health and safety, I believe they can have a meaningful place in the workplace.
Where I think we need to do better is in preparing clinicians to work within these environments. Most physical therapists, occupational therapists, and athletic trainers have extensive education in anatomy, biomechanics, injury management, and therapeutic exercise. What many have not received is the same level of education regarding OSHA recordkeeping, the limitations of first aid, and the regulatory considerations associated with onsite injury prevention and early intervention programs. We enter these environments with a clinical mindset, and our natural response when someone reports discomfort is to assess the problem and recommend an intervention. That approach may be entirely appropriate in a traditional clinical setting, but in occupational health, we need to understand the implications of those decisions before we make them.
I want to be clear that this is not about avoiding appropriate treatment to keep injuries from becoming recordable. If an employee needs medical treatment, they should receive it, and the case should be documented and recorded appropriately. What concerns me is when clinicians unknowingly cross the line between first aid and medical treatment because they simply don't understand the distinction. If you're providing onsite early intervention services, you should know what OSHA considers first aid, what constitutes medical treatment, and how your recommendations affect the employer's recordkeeping responsibilities. You should also understand the physical demands of the work being performed so your recommendations consider the actual workplace exposures rather than focusing only on the employee's symptoms.
This is one of the reasons we place so much emphasis on occupational health education at Matheson Education & Training Solutions. Through our worksite injury and early intervention training, we teach clinicians how to approach workplace concerns while understanding the rules and responsibilities that come with working in an industrial environment. We want clinicians to be able to recognize potential concerns, understand the difference between general wellness and individualized treatment, and make decisions that are clinically appropriate while remaining consistent with OSHA requirements. Being a good therapist is an excellent foundation, but it doesn't automatically mean someone understands occupational health. That additional knowledge is important, and I believe we have a responsibility to better prepare the clinicians who are providing these services.
Learn more about Matheson's Worksite Injury and occupational health training.
References
OSHA. 29 CFR 1904.7: General Recording Criteria.
OSHA. Enforcement Guidance on First Aid, Active Release Techniques, and Exercise/Stretching. May 2, 2024.
OSHA. Determining Whether Daily Stretches Are Considered Medical Treatment or First Aid. December 14, 2015.
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