Update on OSHA Musculoskeletal Disorder First-aid Guidance

Musculoskeletal disorders (MSDs) are among the most common workplace injuries, often resulting from repetitive strain, overexertion, or awkward postures. OSHA provides specific guidance on when treatment for MSDs qualifies as first aid versus recordable medical care. Employers need to clearly understand these distinctions to maintain compliance and prevent unnecessary recordables. This fact sheet outlines key OSHA criteria, examples of compliant first-aid measures, and best practices for managing MSDs on the job.

About the Guidance

On May 2, 2024, OSHA sent regional administrators and state agency designees the memorandum: Enforcement Guidance Under OSHA’s Recordkeeping Regulation When First Aid, Active Release Techniques (ART), and Exercise/Stretching are Used to Treat Musculoskeletal Injuries and Illnesses. The memorandum was directed to federal and state agency regulators to help them determine whether a work-related musculoskeletal condition is recordable under 29 CFR 1904 – Recording and Reporting Occupational Injuries and Illnesses. The guidance refers specifically to first aid, ART, exercise, and stretching as non-recordable modalities.

WorkCare’s Position

WorkCare carefully reviewed the memorandum and re-affirmed that its virtual and onsite clinicians comply with all aspects of OSHA’s standards, including the following:

• All WorkCare health professionals may deliver non-recordable first aid in the occupational setting.
• First-aid guidance may be provided virtually by WorkCare’s Incident Intervention telehealth triage nurses, physicians and industrial injury prevention specialists (IIPSs), and in person by our onsite providers.
• WorkCare’s licensed healthcare professionals may use OSHA-approved first-aid methods such as:
  • Warm-up and stretch-and-flex instructions
  • Application of hot or cold therapy
  • Application of massage
  • Cleaning, flushing or soaking wounds on skin surface
  • Using wound coverings, e.g., bandages, gauze pads, butterfly bandages or sterilized strips
  • Offering fluids to help prevent heat stress

OSHA encourages employers to provide workforce well-being resources. WorkCare supports workplace activities to help reduce injury risk, such as warmup, stretching, and cool down. WorkCare also delivers health education on topics such as sleep hygiene, nutrition, and stress management. Our clinicians do not prescribe specific stretches for the treatment of an individual employee’s musculoskeletal condition. In such cases, the treatment is considered recordable.

Did You Know?

• Work-related musculoskeletal injuries and illnesses are generally not recordable when managed with first aid.
• Follow-up consultation with a WorkCare’s  telehealth triage provider during recovery does not cause a musculoskeletal case to become a recordable injury.
• OSHA encourages employers to rely on licensed healthcare professionals to provide an appropriate care plan for injured or ill employees.
• A recordability determination depends on the type of care that is provided, not the number of injury care visits an employee has with a healthcare provider.

At WorkCare, our goal is to always to provide the right care, at the right time, in the right setting to improve quality of life for employees and enhance business results for employers. Contact us to learn more.