Can Required Stretching Lead to OSHA Injuries?

By Jim Griffin, JD, Employment Counsel
Published May 7, 2019

In recent years, some employers, typically in more physically demanding work environments, have implemented required pre-shift or mid-shift stretching or exercise programs as part of an effort to reduce work-related injuries. An HR Source member recently contacted the HR Hotline to ask if these stretching or exercise programs could actually have the opposite effect and lead to recordable injuries on the Occupational Safety and Health Administration (OSHA) 300 series logs.    

construction workersPer OSHA guidance, the answer to this question is “Yes.” If an employee actually injures himself or herself while participating in required stretching or exercising, and the injury is recordable per OSHA standards. According to OSHA regulations, for employers subject to OSHA recordkeeping requirements, an injury or illness is recordable if it is work-related and it results in any of the following:

  • Death;
  • One or more lost calendar days;
  • Restriction of work or motion;
  • Loss of consciousness;
  • Transfer to another job; or
  • Medical treatment other than first aid.

Thus, any injury that is incurred during required stretching or exercise that results in one of the above would be recordable. This could even be true if the employee had a pre-existing injury that was aggravated by the required stretching or exercise. So, while an employer-implemented stretching or exercise program designed to prevent employee injuries does not itself violate any OSHA requirements, an employer would have to record any injuries incurred during the required program.

One other instance in which required stretching or exercise could be tied to a recordable injury is when a doctor or other healthcare professional prescribes the stretching or exercise to a single employee to treat a work-related injury (as opposed to an employer-implemented facility-wide program to prevent injury). Such prescribed treatment is considered medical treatment other than first aid, so the underlying injury becomes recordable.

HR Source members who would like to further discuss this issue should contact us at hotline@hrsource.org or 800-448-4584.

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