Standard Interpretations - Table of Contents
• Standard Number: 1904.7; 1904.7(b)(5)(ii)(M)

May 21, 2010

Dr. Betsy Buehrer
3M Corporate Occupational Medicine
3M Center
Building 220-6W-08
St. Paul, Minnesota 55133-3428

Mr. Michael Nash
3M General Counsel
3M Center
P.O. Box 33428
St. Paul Minnesota 55133-3428

Dear Dr. Buehrer and Mr. Nash,

Thank you for your February 18, 2010 letter to the Occupational Safety and Health Administration (OSHA) regarding OSHA's recordkeeping regulation contained in 29 CFR Part 1904 - Recordkeeping and Reporting Occupational Injuries and Illnesses. In an effort to provide you with prompt and accurate responses, we developed and continue to refine a set of Frequently Asked Questions (FAQ), in addition to maintaining a log of Letters of Interpretation (LOI) on the OSHA Recordkeeping we site.

Your letter requests an interpretation relating to exercises recommended for a short period of time by an on-site health care professional when an employee is experiencing minor pain that has been determined to be work-related. Specifically, you ask if exercise is considered medical treatment as defined in OSHA's recordkeeping regulations.

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.

OSHA addressed the topic of therapeutic exercise in the preamble to the final rule for recording and reporting occupational injuries and illnesses (FR 66:13, page 5992). OSHA stated that it considers therapeutic exercise as a form of physical therapy and intentionally did not include it as a first aid treatment under 1904.7(b)(5)(ii). 1904.7(b)(5)(ii)(M) states that physical therapy or chiropractic treatment are considered medical treatment for recordkeeping purposes and are not considered first aid. 1904.7(b)(5)(ii) states that the treatments included under 1904.7(b)(5)(ii) is a comprehensive list of first aid treatments. Any treatment not included o