OSH in a Physiotherapy Practice - Occupational Risk Assessment
Mark has run a physiotherapy practice for three years. When he hired a second physiotherapist and a receptionist, he received a letter from the National Labour…
Mark has run a physiotherapy practice for three years. When he hired a second physiotherapist and a receptionist, he received a letter from the National Labour Inspectorate (PIP): an inspection in 14 days. The inspector's first question was: "Could I see the occupational risk assessment for your job positions?" Mark had no idea what that was. The fine came to 2,000 PLN, plus an order to prepare the documentation within a month.
This scenario catches out many practice owners who think OSH (occupational health and safety) only applies to factories. In reality, anyone who employs even a single person becomes an employer under the Labour Code -- with a full package of obligations. In this article we'll show you what an occupational risk assessment is, how to prepare one for a physiotherapy practice, and what OSH documents you need to have.
When does OSH start to apply to you?
The key line is crossed the moment you hire your first employee on an employment contract.
- You work alone (sole practice) -- the OSH provisions of the Labour Code don't apply to you, because you're not an employer. You're only responsible for your own safety.
- You hire someone on an employment contract -- you become an employer and are subject to the full OSH regime (Article 207 et seq. of the Labour Code).
- You work with people on B2B or mandate contracts -- you have limited obligations: you must provide safe working conditions, though not the full apparatus of employee training.
The legal basis is the Labour Code (Section X) and the Regulation of the Minister of Labour and Social Policy of 26 September 1997 on general occupational health and safety provisions. The risk assessment itself is required directly by Article 226 of the Labour Code.
What is an occupational risk assessment?
An occupational risk assessment is a document in which you identify hazards at each job position, estimate the probability and severity of their occurrence, and set out measures to reduce the risk.
In a physiotherapy practice there are, contrary to appearances, quite a few hazards:
- Musculoskeletal strain -- the therapist performs massage and mobilisations, working in forced positions
- Biological hazards -- contact with patients, potentially infectious material, bodily fluids
- Chemical hazards -- disinfectants, gels, oils
- Electrical hazards -- equipment (TENS, ultrasound, laser, magnetotherapy)
- Slips and falls -- wet floors, equipment cables
- Psychological strain -- working with patients in pain, stress, time pressure
Risk assessment method -- the simplest approach
The most popular method, accepted by PIP, is the Risk Score or a simplified three-level scale under the Polish Standard PN-N-18002. For a small practice, the three-level scale is sufficient.
| Risk level | Probability | Consequences | Action |
|---|---|---|---|
| Low (L) | unlikely | negligible | monitoring |
| Medium (M) | probable | moderate | plan mitigating measures |
| High (H) | highly probable | severe | immediate action |
For each hazard you record the risk level and the measures to reduce it. Example for musculoskeletal strain on the therapist: medium risk, measures -- height-adjustable treatment couch, breaks between patients, ergonomics training.
What OSH documents do you need to have?
A PIP inspection at a physiotherapy practice most often checks this set:
- Occupational risk assessment for each position (physiotherapist, receptionist)
- OSH training records -- initial (before admission to work) and periodic
- Referrals for medical examinations and certificates from the occupational medicine physician
- OSH instructions for operating equipment and position-specific instructions
- Register of workplace accidents (even if empty)
- Measurement documentation for harmful factors (if present)
- Safety data sheets for chemical products (disinfectants)
OSH training -- who, and how often?
- Initial training -- every new employee before admission to work (general briefing + position-specific briefing)
- Periodic training -- employees in administrative/office positions every 6 years, in manual and exposed positions every 3 years
- The employer -- also undergoes periodic training for employers and people managing employees (every 5 years)
Training can be delivered by an authorised entity or an OSH specialist. The cost is usually 100-200 PLN per person. Periodic training can be delivered as guided self-study (e-learning) - an option available for years, with the exception of position-specific briefing. Since 2019, administrative and office workers at employers in lower risk categories are exempt from periodic training.
Medical examinations and occupational medicine
Every employee must have a valid certificate from an occupational medicine physician confirming no contraindications before starting work. The employer issues the referral, specifying the harmful factors involved (work at a monitor, physical strain, biological factors). The validity of the certificate depends on the physician's decision -- usually 2-4 years.
Without a valid certificate, an employee must not be admitted to work. This is one of the most common reasons for penalties during PIP inspections.
CTA: Don't want to prepare a risk assessment from scratch? The STANDARD package includes a ready-made occupational risk assessment template for physiotherapy practice positions, a full set of OSH instructions, and a checklist of documents for a PIP inspection. Just fill in your details and print. See FizjoReady packages →
Employer liability for negligence
The National Labour Inspectorate can impose an on-the-spot fine of up to 2,000 PLN, and in court proceedings a fine of up to 30,000 PLN for gross violations. A more serious consequence is civil liability: if a workplace accident occurs and you had no risk assessment or training in place, the injured employee can claim damages, and ZUS can pursue recourse against you.
In practice, most inspections end with an order to complete the documentation within a set deadline. Penalties go to those who ignored their obligations entirely or allowed an accident to happen.
Workstation ergonomics -- the practical minimum
Beyond the paperwork, it's worth genuinely taking care of working conditions:
- A treatment couch with electric height adjustment (reduces strain on the therapist's spine)
- A chair with lumbar support for reception staff
- Adequate lighting at workstations (min. 300-500 lux)
- Ventilation and temperature compliant with regulations (min. 18°C for light physical work)
- A first-aid kit with up-to-date supplies
Frequently asked questions
As a sole practitioner, do I need to carry out a risk assessment?
No, if you work alone and don't employ anyone on an employment contract. The obligation arises the moment you hire your first employee. It's still worth knowing the hazards for your own safety, especially when working with electrical equipment and chemical products.
Who can prepare the occupational risk assessment?
The employer can do it themselves using a ready-made template, or commission an OSH specialist. The law doesn't require an external OSH specialist to carry it out -- what matters is that the document is reliable, signed, and updated after every significant change at the workstation.
How often should the risk assessment be updated?
The assessment is updated after every significant change: a new position, new equipment, a change in technology, or after a workplace accident. There's no fixed annual deadline, but in practice it's worth reviewing the document once a year so it's up to date in case of an inspection.
Does the National Labour Inspectorate announce inspections in advance?
It doesn't have to -- the National Labour Inspectorate (PIP) may inspect businesses unannounced (labour inspection is exempt from the advance-notice requirement under ILO Convention No. 81). Common triggers are an employee complaint or a workplace accident. That's why it's worth keeping your OSH documentation in order on an ongoing basis, rather than only before a visit.
CTA: Want a complete set of OSH documents ready for a PIP inspection? FizjoReady's STANDARD package gives you a risk assessment template, instructions and a checklist in one file. See FizjoReady packages →
Related articles:
- Sanitary Inspectorate check at a physiotherapy practice
- Premises requirements for a physiotherapy practice
- Most common compliance mistakes in a physiotherapy practice