OSHA Offers Interpretation Letter on ‘Daily Stretching Program’

On May 24, the Occupational Safety and Health Administration (OSHA) released an interpretation letter in response to a question on whether a supervisor’s advice to continue participating in daily stretching exercises constitutes medical treatment for recordkeeping purposes.

According to the letter, OSHA received a request for clarification from an employer that requires “all of its employees to engage in stretching exercises at the beginning of each shift and hourly during the shift.” At the request of this employer, one of the employees who reported some “minor discomfort…associated with his work tasks” was asked to continue the daily stretching program. In this instance, the employee who continued the stretching program did not report back with any ongoing or additional discomfort.  

OSHA then responded to this scenario, saying “the supervisor’s advice to continue with the already existing program of stretching does not constitute medical treatment beyond first aid for recordkeeping purposes,” meaning the injury did not meet the requirements that it had to be reported.

However, OSHA did note this interpretation is for existing stretching programs in order to prevent possible injuries, but stretching exercises implemented after an injury are considered “medical treatment,” according to the letter