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

May 2, 2024

MEMORANDUM FOR:
REGIONAL ADMINISTRATORS
STATE DESIGNEES
THROUGH:
AMANDA EDENS
Deputy Assistant Secretary of Labor for Occupational Safety and Health
FROM:
SCOTT KETCHAM
Acting Director, Directorate of Enforcement Programs
LEE ANNE JILLINGS
Director, Directorate of Technical Support and Emergency Management
SUBJECT:
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

This memorandum provides guidance to help determine whether musculoskeletal injuries and illnesses are recordable under OSHA’s injury and illness recordkeeping regulation at 29 CFR 1904 when the only treatment given is first aid, Active Release Techniques (ART), and/or exercises and stretching.

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