When it comes to workplace injury, soft tissue massage is considered first aid for recordkeeping purposes, regardless of whether the health professional providing the treatment holds a certification in Active Release Techniques (ART): that’s the bottom-line message from the US Department of Labor Occupational Safety and Health Administration (OSHA) in response to APTA’s request for OSHA clarification on the subject. The OSHA response definitively establishes physical therapists (PTs) among the providers able to perform soft tissue interventions that constitute first aid in work settings.
The OSHA clarification (download your copy here) is a response from a February 2019 meeting secured by APTA government affairs staff in partnership with the APTA Academy of Orthopaedic Physical Therapy’s Occupational Health Special Interest Group and the APTA Private Practice Section. It clears up a previously foggy area of agency regulation involving what is and isn’t considered “medical treatment beyond first aid” in the workplace—an important distinction for OSHA, as any treatment beyond first aid must be reported as a work-related injury or illness.
While the regulations state that “using massages” is considered first aid, APTA pointed out that previous OSHA guidance recognizing ART as a soft tissue intervention led some employers to mistakenly believe that only ART-certified individuals could provide “massage.” APTA asked OSHA to confirm in writing that soft tissue management is considered first aid when it is performed by individuals who do not have ART certification—including non-ART-certified PTs.
OSHA did just that.
“OSHA considers the treatments listed in…the regulation to be first aid regardless of the professional status of the person providing the treatment,” writes Amanda Edens, director of OSHA’s Directorate of Technical Support and Emergency Management. “Even when these treatments are provided by a physician or other licensed health care professional, they are still considered first aid for purposes of [the regulation in question].” Edens went on to state, “Accordingly, soft tissue massage is first aid whether or not such treatment is performed by individuals with ART certification.”
The letter from OSHA also made it clear that the approach to recording soft tissue injuries and illnesses is the same as any other type of injury or illness, meaning that work-related injuries and illnesses “involving muscles, nerves, tendons, ligaments, joints, cartilage, and spinal discs” do in fact meet the general recording criteria if they involve medical treatment beyond first aid, days away from work, transfer, or restricted work.
“Although this may seem like a minor clarification, it’s a great win for PTs,” said Kara Gainer, APTA director of regulatory affairs. “It’s another affirmation that PTs play a valuable role in workplace health and safety, and can be an important part of employer prevention and wellness teams.”