By: Nic Hayes
In light of the recent memorandum from OSHA, it is crucial to be informed on what changes are on the horizon to remain compliant. The memorandum focuses on appropriate treatment and recordkeeping highlighting three key points:
1. Clarification of First Aid vs. Medical Treatment: It outlines which treatments are considered first aid and which are considered beyond first aid; treatment beyond first aid requires that the injury be recorded.
2. Guidance on Specific Treatments: It gives clarification on the use of Active Release Technique (ART) on whether it should be classified as first aid or medical treatment. Additionally, it clarifies the use of exercise or stretching as a treatment modality.
3. Accurate Recordkeeping: OSHA clarifies how to maintain accurate injury and illness records.
While the memorandum does not necessarily change anything that has previously been outlined by OSHA, it provides additional clarification on workplace recordkeeping and first-aid practices that employers should be aware of. To ensure they remain compliant, employers should review these key issues:
Clarify the Distinction Between First Aid and Medical Treatment
Review OSHA’s definitions of “first-aid” versus “medical treatment beyond first-aid” to ensure proper classification of treatments for musculoskeletal conditions.
Evaluate the Use of Active Release Techniques
Assess whether ART treatments are performed for massage purposes (considered first-aid) or therapeutic purposes (potentially considered medical treatment).
Monitor Exercise and Stretching Treatments
Determine whether exercises are part of a general wellness program (not recordable) or directly linked to treating a work-related injury (may be recordable). Document the nature and purpose of prescribed exercises to justify recordkeeping decisions.
Enhance Training for Record Keepers
Provide updated training to employees responsible for OSHA recordkeeping to ensure they understand and apply the distinctions correctly.
Document Decision-Making Processes
Implement a system for recording supporting documentation, such as healthcare provider notes, treatment plans, and internal communications about the case.
Collaborate with Medical Providers
Ensure healthcare providers understand the distinctions in OSHA's memorandum when treating workplace injuries.
Promote Accurate and Consistent Recordkeeping
Standardize recordkeeping practices across the organization to ensure compliance with OSHA’s updated policies, procedures, and guidelines.
Stay Updated on Changes
Monitor OSHA communications for any further updates or clarifications here.
Remain Complaint with Work Right
While it may seem like a challenge to keep up with OSHA’s clarifications and updates, partnering with a solution like Work Right can help your organization remain compliant while also providing injury prevention services to your employees.
Work Right is an injury prevention services company that partners with clients to provide an onsite Injury Prevention Specialist, either an Athletic Trainer or Physical Therapist, to help the workforce better prepare for the workplace demands of manual work tasks. With a combination of early personal performance screening, training in a task-specific daily stretching routine, and resources to treat non-work related issues that arise, Work Right is able to utilize principles of sports injury prevention while also staying OSHA compliant.
Early Personal Performance Screening
During new hire, many Work Right clients will utilize a computer-based functional movement screening to identify any movement or strength deficiencies that could potentially interfere with job tasks, giving workers an advantage by being able to act proactively.
Pre-Shift Stretching
When working with new clients, Work Right will initiate a pre-shift stretching program or audit the client’s current program as part of their focus on injury prevention. To prioritize the performance of the workforce, Work Right conducts frequent re-training or auditing of the program as well.
Non-Work Related
By taking care of the entire person, injuries in general can be prevented as most clients see significantly more non-work related cases that can be preventively treated. 30-60% of cases seen in the Work Right wellness program are non-work related cases, so the same programs that see a decrease in overall workplace injuries can also be applied to non-work injuries.
Compliance
Work Right is adept at navigating the criteria set forth by OSHA in regards to when and how a condition can be treated.
“Work Right has doubled-down on standard operating procedures, audits, and compliance checks to ensure we're giving customers a toolkit to understand the program they have onsite is following the appropriate protocols.”
-Nic Patee
President, Work Right NW
In addition to being able to provide compliant care to workers, Work Right can also help clients with their responses to OSHA’s “Questions for Employers”. For their current clients, they are helping to prepare them by creating standard practices and procedures such as workplace prevention programs before injuries occur that keep clients compliant.
We are proud to feature Work Right on the Granite List.