There’s a tendency to think of first aid as injury care, but it also applies to injury prevention.

Under federal OSHA definitions, massage and exercise guidance are listed as first aid injury prevention measures. However, when a provider prescribes specific therapeutic exercises in response to a work-related injury or illness, it is medical treatment and becomes OSHA-recordable.

To clarify ambiguities in specific situations, the Occupational Safety and Health Administration periodically issues Letters of Interpretation. On May 23, 2019, OSHA responded to an inquiry from Sharon Dunn, PT, PhD, president of the American Physical Therapy Association (APTA), who requested written guidance on the use of soft tissue management (massage).

There was a concern that when applied by physical therapists, massage would be considered medical treatment and not first aid. More specifically, the APTA wanted to know if various forms of massage could be performed at the first-aid level by therapists who do not have certification in Active Release Techniques (ART), an approach which has already been interpreted by OSHA as first aid.

In its response, OSHA notes that:

• Section 1904.7(b)(5)(ii) defines “using massages” as first aid for recordkeeping purposes.
• A determination about whether to record soft tissue cases is no different than it is for any other type of injury or illness.
• Professional status of the person providing soft tissue massage does not have any effect on what is considered first aid or medical treatment.

What This Means for WorkCare Clients

The letter of interpretation confirms what we already knew: WorkCare Industrial Massage – non-invasive techniques performed onsite by trained professionals to relieve an employee’s musculoskeletal discomfort before it becomes an injury in need of medical treatment – may be provided without worrying about triggering OSHA-recordable medical treatment.

Similar principles apply to other WorkCare employee health management solutions, including Bio-Ergonomic Surveillance using wearable technology, Stretch & Flex exercises and health coaching recommended by our certified Athletic Trainers and occupational physicians, as part of comprehensive injury prevention programs.

In addition, it means our collaborative team, including occupational physicians, nurses, athletic trainers, massage therapists, physical therapists and other skilled professionals, have the opportunity to reach more employees with preventive interventions to help them stay healthy and safe on the job and improve their quality of life.