Therapeutic Intervention is Not Always Recordable

Therapeutic Intervention is Not Always Recordable

By Nick Dmitrovich with input from ATI Worksite Solutions and Athletico Employer Services


Physical therapy is a bit of a confusing subject when it comes to OSHA’s recordkeeping requirements.

How do we know which process is the correct one a company should follow?

OSHA and state practice acts define physical therapy as a prescribed intervention for the sake of treating an injury or illness, and that’s how physical therapy is referred to when it’s defined as an intervention beyond first aid in the regulations for recordkeeping.

According to OSHA, physical therapy prescribed or applied for the treatment of a work-related injury or illness makes the incident recordable.

However, in the same regulation 1907.7(b)(5)(ii), OSHA describes the use of massage as first aid and, therefore, permissible in providing without recording the incident. Further, OSHA published descriptions for the use of exercise when an injury or illness does not exist. Since both massage and exercises are modalities used by physical therapists for the treatment of injuries, confusion has emerged as to if it is “physical therapy” if these techniques are utilized.

To find a little clarity on this subject, we took a dive into the standards and reached out to experts for their input. We learned that it all boils down to the intent behind the activity and whether physical therapy is being used to treat an injury or if basic techniques and exercises are being used to prevent one from happening.


If it’s to prevent injuries, it’s not recordable.

Physical therapy, both as a term and as an industry, is a multi-faceted thing.  Techniques used by physical therapists are not always implemented exclusively for rehabilitative purposes. Often, it’s used proactively to keep people healthy. Today, one can frequently find elements of therapeutic activities incorporated into corporate wellness programs as part of an overall strategy to prevent injuries and other health concerns from occurring. When used in this way, physical therapy is not OSHA recordable.

“Think of it this way: if there was a hazard in your workplace, like a spill for example, you would intervene to address it before someone gets hurt. Physical therapy related activities can be early interventions too, though they would generally be defined as pre-conditioning programs, job-specific mobility programs, or physical education because they’re not being used as treatments,” explained Stacy Bierce, vice president of organizational development with ATI Worksite Solutions.

“Programs like these would evaluate an individual and their job functions and would work to condition that individual to be less susceptible to injuries that could arise from their regular tasks,” Bierce added. “They wouldn’t be used to treat a specific ailment but would instead work to keep an individual fit based on the needs of their job.”

OSHA is in agreement with this. The organization wrote, “If a treatment is administered as a purely precautionary measure to an employee who does not exhibit any signs or symptoms of an injury or illness, the case is not recordable. For a case to be recordable, an injury or illness must exist. For example, if, as part of an employee wellness program, an athletic trainer recommends exercise to employees that do not exhibit signs or symptoms of an abnormal condition, there is no case to record.”

Definitions are key in this area. Employees would not be referred to as “patients” and the activities should not be referred to as “therapy,” because those terms all pertain to recordable instances. Emphasis should be placed on the activities being proactive in nature as part of a company’s overall wellness strategy, not reactive as they would be described following an injury.


If it’s for an injury, it’s recordable.

In general, if an injury is involved, it’s recordable. There is still quite a bit of confusion among employers though, because physical therapy types of activities are broad in nature and can be recommended by a wide variety of health professionals.

OSHA publishes a large body of useful standard interpretations on its website each year, which are letters the organization has received from the public about attributes and terminology for its regulations. Looking back at items from 2010, 2011, and 2016, OSHA has responded to inquiries about physical therapy recordability on several occasions.

For the most part, the subject pertains most directly to standard 1904.7’s general recording criteria, specifically section 1904.7(b)(5). Notable details include:

  • If exercise is recommended by a medical professional to an employee who exhibits any signs or symptoms of a work-related injury, the case involves medical treatment and is a recordable case.
  • Work-related minor musculoskeletal discomfort treated with therapeutic exercise (physical therapy) constitutes a recordable case. OSHA considers “therapeutic exercise” to be a form of physical therapy.
  • Physical therapy or chiropractic treatments are considered medical treatment for recordkeeping purposes and are not considered first aid.


Recordable or Not, Physical Therapy Helps

Whether its to prevent an injury or to recover from one that’s occurred, physical therapy can be a helpful thing for companies if implemented correctly.

“There are times when physical therapy is the best path forward to ensure the employee gets back to 100% productivity as quickly as possible, ultimately saving resources by not losing an employee to catastrophic injury. That said, emphasis should be placed on reducing the risk of needing physical therapy in the first place by focusing more of the organization’s efforts on prevention of injuries,” said Geoff Wolfe, senior manager with Athletico Employer Services.

“Understanding, developing, and implementing the best strategy for an organization takes expertise in multiple domains and shouldn’t be taken lightly,” Wolfe added.

The end goal should always be to strive toward healthier employees, in any circumstances. As long as physical therapy activities are properly categorized by their intent, a company will be able to maintain full compliance and, ultimately, will achieve more positive outcomes.

Click to share!