Therapy and restricted duty under 1997 injury recordkeeping guidance

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

December 3, 1997

Dee Woodhull
Manager, Safety, Industrial Hygiene,
and Workers Compensation
United Technologies Corporation
[Recipient address omitted]
Dear Mrs. Woodhull:

Thank you for your letter of July 23, 1997, requesting injury and illness recordkeeping interpretations with regard to several situations occurring in your workplace. Please excuse the long delay in our response. I will respond by restating your questions and then answering them. I will cite the Recordkeeping Guidelines for Occupational Injuries and Illnesses by page and Q&A number(s) whenever possible.

1. Should someone who receives a Rossiter Workout be recorded on the OSHA 200 Log, and if so, why and under what circumstances would the case be recordable?

As I understand it, the Rossiter program is a non-traditional form of treatment consisting of a series of "workouts" that involve various stretching exercises administered by trainers and co-workers who are not licensed health care professionals. According to the literature from Rossiter & Associates, Inc., the program is normally used for treatment of carpal tunnel syndrome and other repetitive motion arm and wrist injuries, or conditions commonly referred to as cumulative trauma disorders (CTDs).

The most comprehensive guidance for the recording of CTDs on the OSHA 200 Log is found on pages 14 and 15 of the Ergonomics Program Management Guidelines for Meatpacking Plants (photocopies enclosed). The ergonomics guidelines state a recordable CTD exists if there is at least one physical finding OR at least one subjective symptom (pain, numbness, tingling, aching, stiffness, or burning , etc.) combined with:

1) medical treatment (including self-administered treatment when made available to employees by their employer), or

2) lost workdays (includes restricted work activity), or

3) transfer/rotation to another job.

Examples of medical treatment include use of heat therapy, hot or cold compresses, whirlpool bath therapy, and hot or cold soaking therapy during second or subsequent visit to medical personnel. Medical treatment also includes a series of chiropractic treatments (Pp. 43 Q&A 45, Recordkeeping Guidelines). In a number of interpretative letters, OSHA has considered physical therapy to be a similar treatment. Therefore, physical therapy is considered medical treatment when administered on a second or subsequent visit to medical personnel, including self-administered treatment when made available to employees by their employer. To be considered medical treatment, self-administered treatment must be performed at the medical facility or on the employer's premises when provided by the employer. The treatment does not have to be supervised by medical personnel to be considered medical treatment. On the other hand, if the treatment is self-administered at home or if the treatment was given only on the initial visit to medical personnel, it is considered first aid and would not constitute medical treatment.

For OSHA injury and illness recordkeeping purposes, OSHA considers the Rossiter program a form of physical therapy. Therefore, cases where an employee is experiencing subjective symptoms associated with workplace repetitive motion or trauma that result in application of the Rossiter exercises two or more times on the employers premises, the case must be recorded on the OSHA 200 Log as an illness, with a check mark entered in column 7(f) and the appropriate entries in columns 9 through 13.

Q&A B-6 on Page 30 of the Guidelines states, "Entries on the log...should be made only when the exposure results in a recordable work injury or illness." If there are no symptoms or abnormal health conditions, then there is no recordable case, regardless of use of the Rossiter system or any other type of therapy. Furthermore, Q&A B-9 on Page 30 addresses the situation of receiving preventative care when not injured or ill. This care does not make a case recordable. If, however, the employee is symptomatic, the medical treatment criteria outlined above must be applied to determine if the case is recordable or not.

2. How should injuries or illnesses be recorded where no medical treatment is provided and where work restrictions apply only on the actual day of injury?

If the restriction does not go beyond the day of injury or onset of illness, the case is recorded as a nonfatal case without lost workdays in either column 6 or 13 (C-2, page 52).

3. How should strains/sprains in which a second treatment of heat or cold is applied be recorded?

Injuries for which application of heat or cold therapy during a second or subsequent visit to medical personnel was provided or should have been provided are recordable if the injury is work related.

I hope you find this information useful. If you have any further questions, please contact us at Area Code: (202) 219-6463.

Sincerely,

Stephen A. Newell
Director
OSHA Office of Statistics

[Requester letter reproduced on OSHA page; omitted here.]