Background: During daily activities, stability is maintained to enhance the function of muscles surrounding the lumbopelvic and hip structures. The core muscles such as the rectus abdominis (RA), external oblique (EO), and internal oblique (IO) responsible for this stability. One effective static exercise for strengthening these muscles is the plank. Objects: This study aimed to compare abdominal electromyographic activation when an unstable support surface was applied to the upper and lower extremities during a standard and a knee plank. Methods: A total of 30 adults (15 males and 15 females) participated in this study. Surface electromyography electrodes were placed on the RA, EO, and IO muscles. Data were collected under six conditions for males, including two plank postures (standard and knee planks) and three unstable surface conditions (a dynamic balance cushion applied to the upper extremities, lower extremities, or no cushion). Female participants performed only the knee plank. A mixed-effects model with a random intercept was used to analyze muscle activation across plank posture and surface position, with statistical significance set at α = 0.05. Results: In males, the standard plank elicited greater muscle activation than the knee plank across all muscles (p < 0.0001). Additionally, applying an unstable support surface to the upper extremities significantly increased muscle activation in both plank postures in EO and IO (p < 0.001). Other muscle, RA, was only affected by the unstable support surface in the standard plank position only. In females, the knee plank with upper limb instability resulted in the highest muscle activation for all muscles. Conclusion: These findings highlight the importance of surface instability in core muscle engagement. However, future studies should further investigate abdominal muscle activation with a more detailed analysis and the inclusion of a control group to enhance comparative validity.

Background: With the increase of seated work, interest in forward head posture (FHP) has grown. Prolonged computer tasks with FHP have been considered a factor that increases the stiffness and tone of the upper trapezius (UT) muscle. Traditionally, many studies have measured the craniovertebral angle (CVA) in standing positions to assess FHP, making it difficult to determine whether the CVA measured in a habitual working posture correlates with the stiffness and tone of the UT muscle in office workers. Objects: This study aimed to investigate the relationship among CVA, UT muscle stiffness, and tone in both habitual working and standing postures among asymptomatic office workers. Methods: Forty asymptomatic office workers participated in the study. CVA was measured in both habitual working and standing postures. Stiffness and tone of the UT muscle were assessed after a 10-minute computer task. Pearson’s correlation coefficient was used to investigate the relationship between CVA and stiffness and tone of the UT muscle. Results: No significant correlations were found between CVA in standing posture and the stiffness and tone of the UT muscle. However, moderate negative correlations were observed between CVA measured in the habitual working posture and both the stiffness (dominant: r = –0.490, non-dominant r = –0.465) and tone (dominant: r = –0.501, non-dominant r = –0.446) of the UT muscle. Conclusion: This study highlights that decreased CVA in habitual working posture is associated with increased stiffness and tone of the UT muscle in asymptomatic office workers. Therefore, measuring CVA in the habitual working posture should be considered when evaluating stiffness and tone of the UT muscle.

Background: Balance disorder is a prevalent clinical manifestation following stroke, often causing considerable discomfort and gait disability. Various water-based therapeutic approaches have been developed to address balance and gait disorder. Objects: The purpose of this study was to investigate the effects of water-based gait training using auditory stimulation on balance and gait abilities in stroke patients. Methods: All subjects were randomly divided into three groups: water-based gait training using auditory stimulation group (WAG) (n = 24), water-based gait training group (WG) (n = 24), and control group (n = 22). Subjects in WAG and WG underwent water-based gait training for 30 minutes, 3 times a week for 6 weeks. All Subjects were assessed for muscle strength, balance, gait, motor function, and activity of daily living pre- and post-intervention. Results: Results showed that all outcome measures significantly improved post-intervention (p < 0.05). Additionally, WAG was found to significantly improve in Medical Research Council (MRC), Berg Balance Scale (BBS), and Timed Up and Go (TUG) test compared to WG, and WG showed significant differences compared to the control group in MRC and Fugl-Meyer Assessment (FMA) (p < 0.05). WAG exhibited significant differences in all areas except Modified Bathel Index (MBI) in the between-group comparison with the control group (p < 0.05). Conclusion: These results suggest that water-based gait training using auditory stimulation may be effective strategy to improve muscle strength, balance and gait ability for with stroke.

Background: Ankle flexibility is important for maintaining proper biomechanical function. Static stretching is used to improve flexibility with minimal risk; however, its effects are often temporary. Transfer of energy capacitive and resistive (TECAR) therapy has the potential to enhance muscle flexibility and circulation through deep heat applications. However, comparative studies evaluating the effectiveness of TECAR therapy and static stretching are lacking. Objects: This study aimed to compare the effects of static stretching therapy (ST) and combined TECAR and static stretching therapy (T-ST) in subjects with gastrocnemius muscle (GCM) tightness. Methods: Twenty-seven participants with bilateral GCM tightness were enrolled. To administer the ST and T-ST, which were each applied to both legs, the participants stood for 15 minutes on a wedge with a 0°–15° incline, with both feet on the wedge during ST and with TECAR therapy in resistive energy transfer mode applied to only one side of the GCM during T-ST. Muscle stiffness (MyotonPRO), dorsiflexion range of motion (DF-ROM), peak torque, and pennation angle (PA) of the GCM were measured before and after the intervention. Normality was confirmed using the Shapiro–Wilk test. Differences between the ST and T-ST leg conditions and between pre- and post-intervention changes in the legs were analyzed using paired t-tests. Results: There were no significant differences in any of the measured variables between the legs before the intervention. ST and T-ST legs showed significant improvements in all measured variables after the intervention (p < 0.05). T-ST legs demonstrated a significantly greater increase in DF and a greater decrease in PA than ST legs (p < 0.05). Conclusion: T-ST outperformed ST in reducing PA and increasing DF-ROM by promoting deep tissue relaxation and stimulating metabolic activity. This may lead to reduced pain and greater flexibility compared to ST. Maintaining an optimal PA ensures efficient force transmission during exercise, as evidenced by the observed increase in peak torque.

Background: Portable, small computers and smartphones are now considered essential tools in modern society and smartphone ownership and usage rates are rising every year. However, excessive smartphone use can have musculoskeletal and postural implications, leading to “smartphone addiction” and related dysfunctions. Objects: This study aimed to investigate the effects of smartphone addiction on scapular position and muscle activity during shoulder abduction in asymptomatic individuals. Methods: A total of 45 participants were classified into high-risk, middle-risk, and low-risk groups based on their smartphone addiction levels. Scapular position was measured using the scapular index, round shoulder posture (RSP), lateral scapular slide test, and scapulohumeral rhythm spine angle. Muscle activity was assessed using electromyography of the upper trapezius (UT), lower trapezius (LT), serratus anterior (SA), and anterior deltoid (AD) muscles during shoulder abduction. Results: Smartphone addiction was significantly associated with altered scapular position and muscle activity. The high-risk group exhibited greater forward head posture and more pronounced RSP. Additionally, the high-risk group had lower SA activation and higher UT, LT, and AD muscle activity, indicating compensatory mechanisms due to altered scapular positioning. Conclusion: These findings suggest that excessive smartphone use contributes to postural deviations and altered muscle activation patterns, which may lead to musculoskeletal dysfunction over time. Clinicians should consider smartphone use when assessing patients with scapular dysfunction, and future studies should explore interventions to mitigate these effects.

Background: Logistics service workers (LSWs) face significant occupational challenges, with ankle sprains being the second most prevalent work-related musculoskeletal disorder. Foot posture, assessed through the navicular drop test, can significantly influence dynamic balance performance, which is crucial for injury prevention in physically demanding occupational settings. Objects: This study aimed to investigate differences in dynamic balance performance among LSWs with pronated, supinated, and normal foot types using the Y-Balance test (YBT), comparing reach distances across anterior, posteromedial, and posterolateral directions. Methods: A total of 205 LSWs were classified into three groups based on navicular drop measurements: supinated (n = 44), normal (n = 94), and pronated (n = 67) foot types. The YBT was performed on the dominant leg, measuring reach distances in three directions. Participants’ demographic characteristics were recorded, and statistical analyses were conducted using one-way analysis of variance (ANOVA) with Bonferroni correction. Results: Significant differences in YBT performance were observed across all three directions (anterior: p = 0.009, posterolateral: p = 0.015, posteromedial: p = 0.014). The supinated and normal foot groups showed significantly greater reach distances compared to the pronated group (p < 0.026 for anterior direction). In the posterolateral direction, the supinated group demonstrated significantly better performance compared to the pronated group (p = 0.014). Similarly, the posteromedial direction revealed significantly higher reach distances for the supinated group compared to the pronated group (p = 0.012). Conclusion: The study reveals that foot type significantly impacts dynamic balance performance among LSWs. Workers with pronated feet demonstrate reduced balance capabilities, while those with supinated feet show the most superior dynamic balance performance.

Background: Chronic low back pain (CLBP) is associated with trunk and lower extremity muscle weakness. Kneeling squat (KS) is a hip-focused exercise commonly used in the activities of daily living. However, research on trunk and lower extremity muscle activity across movement phases (ascending, holding, and descending) during KS remains limited and warrants further investigation. Objects: To determine the muscle activity of transversus abdominis/internal oblique (TrA/IO), erector spinae, gluteus maximus (Gmax), gluteus medius (Gmed), rectus femoris (RF) in the contraction phases of KS in individuals with CLBP. Methods: Surface electromyography data were recorded during KS across the ascending, holding, and descending phases on the side with CLBP. A 60-bit metronome was used to control the exercise speed. Results: The muscle activity of the TrA/IO was significantly higher during the holding phase than during the ascending and descending phases. The Gmax and Gmed were significantly higher during the holding phase than during the descending phase, whereas, RF was significantly higher during the ascending phase than during the holding and descending phases. Conclusion: The holding phase of KS may be recommended as a trunk and lower extremity exercise to increase in TrA/IO, Gmax, and Gmed muscle activity. Additionally, the ascending phase activates RF muscle in individuals with CLBP.

Background: Hamstring shortness (HS) contributes to the limit of hip and knee range of motion and can limit the execution of multi-segmental movement exercises such as squatting, thereby altering the muscle activation. The double leg squat (DS) is fundamental exercise for knee injury rehabilitation programs. However, it may aggravate knee joint injury and cause low back pain. The Bulgarian split squat (BSS) is a one-leg squat exercise with greater knee joint stability than DS. Measuring muscle activation during the squat will provide insight into the contribution of hamstring activation and quadriceps and hamstring (Q:H) ratio to the knee in participants with HS. Objects: This study compares hamstring activation and Q:H ratios during squat exercises in individuals with and without HS. Methods: This study classified 30 healthy participants, based on active knee extension, into two groups: with HS and without HS. Surface electromyography was performed to determine muscle activation of the medial hamstring (MH) and biceps femoris of the hamstrings and coactivation of the Q:H. All participants performed DS and BSS. Results: MH activity was significantly higher in the with HS group than in the without HS group during all exercises, and the Q:H ratio was significantly closer to 1.0 during BBS compared to DS. Additionally, the with HS group had a significantly lower Q:H ratio than without HS group. Conclusion: In comparison between exercises, BBS can bring the Q:H ratio closer to 1.0 compared to DS, which may enhance knee stability. However, in between-group comparisons, the increased tension due to the shortening of the hamstrings leads to heightened hamstring activation, resulting in a Q:H ratio that is closer to 1.0 compared to the without HS group. Therefore, relying solely on the Q:H ratio to assess knee stability may be risky.

Background: Chronic low back pain (CLBP) is a common health problem among female caregivers. In Korea, 70.4% of caregivers experience LBP after caregiving. The prevalence of LBP was higher in female caregivers of patients who required physical assistance with transfer than in those caring for patients who did not require physical assistance. Lifting movements, such as patient transfer and positioning, are associated with lumbopelvic stability (LPS) and knee muscle strength. However, no studies have investigated the differences in LPS and knee muscle strength between female caregivers with and without CLBP. Objects: This study was conducted to investigate the differences of the LPS, knee extension strength (KES) and knee flexion strength (KFS) between female caregivers with and without CLBP. Methods: Thirty-one female caregivers participated in this study. Participants were divided into two groups: (1) caregivers without CLBP (n = 13) and (2) caregivers with CLBP (n = 18). LPS, KES, and KFS levels were measured. An independent t-test was used to compare the LPS, KES, and KFS between caregivers with and without CLBP. The statistical significance was set at α of 0.05. Results: The LPS and KES scores were significantly lower in caregivers with CLBP than those without. In contrast, the KFS did not differ significantly between the groups. Conclusion: This study observed associations of both LPS and KES with CLBP among female caregivers.

Background: Aquatic exercise utilizing hot springs helps individuals with nonspecific knee pain by reducing joint stress and providing a safe environment for movement. It can improve muscle strength and balance, enhancing overall functional mobility. Objects: This study aims to examine the muscle strength of knee flexion, knee extension, dorsiflexion, and plantar flexion, as well as to investigate static and dynamic balance in middleaged females after performing hot spring aquatic exercise for 4 weeks. Methods: Twenty-two middle-aged females participated in the study. The participants performed hot spring aquatic exercise for 4 weeks. The hot spring aquatic exercise consisted of aquatic walking, aquatic stretching, aquatic side step, aquatic forward reach, aquatic squat, leg lift, and aquatic arm and leg rotation. Muscle strength was measured using microFET2, while static balance was assessed through the one-leg stance test, and dynamic balance was evaluated using the Y-balance test. This study utilized the paired t-test for statistical analysis, with a significance level set at 0.05. Results: The muscle strength of bilateral knee flexion showed a significant increase in the pre- and post-comparison (p < 0.05), and the muscle strength of bilateral knee extension also improved significantly (p < 0.05). In addition, a significant increase was observed in the muscle strength of bilateral dorsiflexion (p < 0.05). The one-leg stance test performed while supporting on the right leg showed a significant increase in the pre- and post-comparison (p < 0.05). Furthermore, the dynamic balance measurements performed while supporting on both the right and left legs demonstrated significant improvements in both legs when compared before and after the intervention (p < 0.05). Conclusion: In individuals with nonspecific knee pain, a 4-week hot spring aquatic exercise program can contribute to the improvement of lower extremity strength, as well as static and dynamic balance ability.

Background: Stroke often results in impaired postural control and asymmetric weight distribution, which negatively affect balance and functional mobility. Previous research has demonstrated that balance training interventions incorporating proprioceptive stimulation and visual feedback can enhance postural stability in stroke survivors. However, there remains debate regarding the relative effectiveness of these two approaches. While proprioception-based training emphasizes sensory input from mechanoreceptors to improve postural control, visual feedback-based training leverages external cues to facilitate balance adjustments. Objectives: To investigation the effects of proprioception-based trunk exercise and visual-auditory feedback-based trunk exercise on sitting balance in patients with chronic stroke. Design: Randomized controlled trial. Methods: A total of 24 participants diagnosed with chronic stroke were randomly assigned to two groups: the proprioception-based trunk exercise group (PTG, n=10) and the visual-auditory feedback-based trunk exercise group (VTG, n=11). Both groups participated in a 6-week intervention program, five sessions per week, lasting 25 minutes per session. Outcome measures included the Limitation of Stability (LOS), the Korean version of the Trunk Impairment Scale (K-TIS), and the Postural Assessment Scale for Stroke (PASS). Pre- and post-intervention assessments were analyzed using paired t-tests and independent t-tests to evaluate within-group and between-group differences. Results: Both PTG and VTG groups demonstrated significant improvements in LOS, K-TIS, and PASS scores following the intervention (P<.05). However, there were no statistically significant differences between the two groups in the amount of change observed. Conclusion: The findings suggest that both proprioception-based and visualauditory feedback-based trunk exercises are effective in improving sitting balance in chronic stroke patients. The lack of a significant difference between the groups indicates that both approaches provide comparable benefits. Future research should explore long-term effects and investigate potential differences in various functional domains beyond sitting balance.

Background: Neck discomfort and movement limitations are common musculoskeletal problems among modern people. While cervical and thoracic joint mobilization are widely used interventions for cervical dysfunction, research comparing their immediate effectiveness in adults with asymmetrical cervical rotation is limited. Objectives: To compare the immediate effects of cervical versus thoracic joint mobilization in adults with adults with asymmetrical cervical rotation and discomfort. Design: Randomized controlled trial. Methods: Thirty adults with left-right differences in cervical rotation of more than 5 degrees were randomly assigned to a cervical mobilization group (CMG, n=15) or thoracic mobilization group (TMG, n=15). Both groups received Grade III mobilization for 15 minutes. Range of motion (ROM), pain (VAS), and neck disability index (NDI) were measured before and after intervention. Results: Both groups showed significant increases in ROM after intervention (P<.001). Within-group analysis revealed that the TMG showed significant pain reduction (P<.01) and significant reduction in left-right rotation asymmetry (P<.001), while the CMG showed improvement in ROM but no significant changes in asymmetry or pain (P>.05). Neither group showed significant changes in NDI. Between-group comparisons showed no significant differences in any outcome measures. Conclusion: Both cervical and thoracic joint mobilization increased cervical range of motion in adults with asymmetrical cervical rotation discomfort. The TMG demonstrated significant within-group improvements in left-right rotation asymmetry and pain reduction, suggesting potential clinical benefits of thoracic mobilization for certain aspects of cervical dysfunction.

Background: Functional sarcopenia, a subcategory of sarcopenia, has recently been introduced. It is defined by muscle weakness and reduced physical performance, regardless of muscle mass reduction, and may potentially affect overall rehabilitation outcomes in patients. Objectives: This study aimed to classify stroke patients into two groups based on the presence or absence of functional sarcopenia and to compare changes in balance and gait ability after receiving the same rehabilitation intervention. Design: A quasi-experimental design. Methods: A total of 44 stroke patients participated in this study and were classified into functional sarcopenia (n=22) and non-functional sarcopenia groups. Physical function tests were used to assess balance (Timed Up and Go, Berg Balance Scale) and gait (10-Meter Walk Test, Functional Ambulation Category). All participants underwent a four-week convalescent rehabilitation program, receiving five sessions per week, with each session lasting four hours per day. Results: After four weeks of convalescent rehabilitation, both groups showed significant improvements in all outcome measures (P<.05). However, when comparing the pre-post changes, no significant differences were found between the two groups in the changes of balance and gait outcomes (P>.05). Conclusion: These findings suggest that stroke patients with functional sarcopenia can achieve a similar level of functional recovery as those without functional sarcopenia when provided with appropriate rehabilitation interventions.

Background: Recent research suggests that the most effective and proactive method for correcting excessive pronation, which contributes to the lowering of the medial longitudinal arch, is to enhance both intrinsic and extrinsic foot muscles simultaneously. Objectives: This study aims to compare the effects of intrinsic and extrinsic foot muscle exercises on medial longitudinal arch height, plantar pressure distribution, and lactate levels in university students with flexible flatfoot. Design: Randomized controlled trial study. Methods: Twenty-two students with flexible flat foot participated in this study and were recruited by N University in Korea. The subjects were randomly divided into Intrinsic foot muscle strengthening group (IFG; n=11) that went through Intrinsic foot muscle strengthening exercise, Extrinsic foot muscle strengthening group (EFG; n=11) that went through extrinsic foot muscle strengthening exercise. SPSS was used for statistical analysis. Results: Both groups showed significant increases in medial arch height and first metatarsal bone pressure, while EFG also had increased pressure at the second to fourth metatarsal bones. No significant differences were found in lactate levels. Conclusion: Both intrinsic and extrinsic foot muscle strengthening exercises can be suggested as effective interventions for improving medial longitudinal arch height and plantar pressure.

Background: Prolonged use of computers and mobile devices has contributed to postural abnormalities such as Rounded Shoulder Posture (RSP), which is characterized by muscle imbalances that can lead to pain and functional limitations. Correcting these imbalances through targeted stretching and strengthening exercises was expected to help improve postural alignment and muscle function. Objectives: This study aimed to investigate the effects of a six-week integrated exercise program targeting the pectoralis minor (PM), upper trapezius (UT), and lower trapezius (LT) on postural alignment and muscle activation in female adults with RSP. Design: Single-group pre-post test study. Methods: Eighteen female university students (aged 20–22 years) with RSP participated in a six-week intervention consisting of PM stretching, UT stretching, and LT strengthening exercises. RSP severity was assessed using acromion-to-ground distance, PM length was measured with a caliper, and surface electromyography (sEMG) was used to evaluate UT and LT muscle activity. Normality was verified using the Shapiro-Wilk test, and paired t-tests were conducted for statistical analysis (α=0.05). Results: After the intervention, significant improvements were observed in all measured variables. Acromion-to-ground distance decreased (P<0.001), PM length increased (P<0.001), UT activation decreased (P<0.01), and LT activation increased (P<0.01). Conclusion: The six-week integrated exercise program effectively improved postural alignment and muscle activation in women with RSP by addressing muscle shortening, overactivity, and weakness. These findings suggest that combined stretching and strengthening exercises can serve as a practical and effective approach for RSP correction. Future studies with longer durations and diverse populations are recommended to further validate these results and enhance clinical applicability.

Background: As the length of stay for rehabilitation and medical care services for occupational injury patients continues to increase, this study aims to explore alternative solutions that can support the corporation's efforts to develop rehabilitation treatment programs in response. Objectives: By analyzing the most frequent diseases among occupational injury patients over the past five years and comparing the average length of stay (LOS) for each disease by disease type, occupation, gender, and type of accident, it is expected that the necessity for developing rehabilitation treatment programs for occupational injury patients can be identified. Furthermore, when applying the developed treatment programs, a reasonable LOS can be derived. Design: Patient clinical data lab. Methods: From January 2017 to December 2021, data from 292,423 occupational injury patients who submitted their initial medical treatment applications to the Korea Workers' Compensation & Welfare Service (KWCWS) and received approval for their occupational injuries were de-identified. After data preprocessing, the cases were categorized by diagnosis, and statistical analysis was conducted using Excel ver. 21.0. Results: In the intensive rehabilitation treatment process, inpatient and outpatient care show a very strong correlation with r=0.8817, followed by the total number of treatment days (r=0.6431) and the number of treatment sessions (r=0.6441). Conclusion: It is necessary to establish application criteria for injury groups that significantly impact the average medical care days and medical care benefits of industrial accident patients. These criteria should consider factors such as exceeding the average length of medical care for specific injury groups (orthopedic/neurological), gender differences (female patient group), discrepancies in inpatient and outpatient medical care benefits, the proportion of high disability grades (Grade 1-3), common injury (accident) types, and the top 1/2/3 associated injury groups by occupation type. Based on these criteria, simultaneous management of the provision timing of rehabilitation service programs and the average medical care days for the 50 most common injury groups is required.

Background: Subacromial impingement syndrome (SAIS) is a prevalent cause of shoulder pain, often linked to abnormal scapular positioning and movement. Prior research suggests that scapular stabilization exercises (SSE) may improve SAIS symptoms, but there's a lack of research on the specific quantitative effects of SSE on scapular position and function. Objectives: To investigated the effects of SSE on scapular position and shoulder function in patients with SAIS. Design: A randomized controlled trial. Methods: Thirty participants with SAIS, diagnosed using the Scapular Dyskinesis Test (SDT), were randomly assigned to either a scapular stabilization exercise group (SSEG, n=15) or a traditional rehabilitation training group (TRTG, n=15). Both groups received eight weeks of intervention. Outcome measures included the scapular index (SI), measured using digital vernier calipers, and the Shoulder Pain and Disability Index (SPADI). Results: The SSE group showed statistically significant increases in scapular index (SI) and significant decreases in Shoulder Pain and Disability Index (SPADI) pain and disability scores. The TRTG showed no statistically significant changes in these measures. The SSE group demonstrated statistically significant improvements in SI and SPADI scores compared to the TRTG. Conclusion: These findings suggest that SSE may be a valuable treatment option for improving shoulder function and reducing pain in patients with SAIS. Further research is needed to validate these findings and explore the longterm effects of SSE.

Background: The growing need for objective and accurate evaluation in Taekwondo poomsae competitions has highlighted the limitations of subjective human judgment. Objectives: This study aims to develop an automated scoring framework using camera-based pose estimation and advanced neural networks to improve the consistency and accuracy of poomsae evaluation. Design: Comparative analysis of neural network architectures on a large-scale dataset of poomsae movements. Methods: A dataset of 902,306 labeled frames, captured from 48 participants performing 62 distinct movements using synchronized multi-view cameras, was analyzed. Five neural networks (HNN, 1D CNN, GCN, MLP, SANN) were implemented and evaluated using accuracy, precision, recall, and F1-score. Results: The HNN demonstrated superior performance with an F1-score of 0.78 in classifying Taekwondo poomsae postures. The 1D CNN followed with an F1-score of 0.76, while GCN, MLP, and SANN achieved F1-scores of 0.74, 0.70, and 0.66, respectively. The HNN's hierarchical feature extraction approach proved effective in capturing the complex spatial and temporal patterns inherent in poomsae movements. Conclusion: Hierarchical Neural Networks outperform other architectures in poomsae classification, establishing a foundation for objective and scalable scoring systems in competitive settings.

경호수칙(警護守則, Security Protocols)은 경호 대상자의 신변 보호와 안전을 확보하기 위해 경호 요원들이 따라야 할 기본적인 원칙과 행동 지 침을 의미한다. 현재 우리나라 경호수칙은 법적 근거가 명확히 발견되지 않 지만 경비업법, 경호 기관별 경호 매뉴얼과 규정 등에 기반하여 수립되는 것으로 보여진다. 이와 같은 경호수칙은 경호 활동이 일관되고 효과적으로 이루어지도록 하는 기준이 되며 일반인과 경호대상자가 예상 가능할 수 있 어야 할 것이다. 그러므로 경호수칙은 경호기관과 경호원간의 비공개 경호 매뉴얼과 규정 에만 맡겨둘 수 없으며, 고 경호 과정이나 결과적으로 국민 모두에게 영향 을 끼치기 때문에 단순한 사적 계약으로 치부하는 것은 매우 곤란하다. 최 근 연예인의 과잉 경호로 인해 인천공항 등 공공장소에서 공공시설을 사용 하는 많은 사람들이 불편을 겪어 사회적 이슈가 되었다. 한편 대통령을 경 호하는 경호원이 과잉 경호를 함에 따라 대학교 졸업생이나 현직 국회의원 이 표현의 자유를 제한하는 결과를 초래하기도 하였다. 반면에 한편 과잉 경호 외에 경호수칙을 지키지 않는 다른 형태인 부실 경호도 문제가 되었 는데, 그 상황이 더욱 심각할 수 있는데 서울 용산구 대통령 집무실 주변 을 경비하는 서울경찰청 소속 101경비단에서 실탄 6발을 분실하는 사고가 발생했으나 현재까지 이를 찾지 못하였다. 미국 역시 미국 공화당 대통령 후보인 도널드 트럼프 전 대통령 경호를 책임진 비밀경호국이 2024년 7월 의 총격 암살 시도 사건과 관련한 경호 실패, 즉 부실 경호를 공식 인정하 기도 했다. 과잉경호와 부실경호 모두 경호 활동에서의 경호원의 경호수칙 을 위반한 경우로 추정할 수 있는데 경호원은 이와 같이 경호대상과 일반 인에게 손해를 발생시킨 경우 법적 책임에서 자유로울 수 없다. 특히 이러한 경우 가장 중요한 것은 경호기관이 경호 매뉴얼과 규정을 제공했는지에 따라 경호기관도 경호원과 부진정연대책임을 져야 할 것인데, 만일 경호 수칙 자체가 부재하였다면 이는 매우 심각한 일이 아닐 수 없 다. 현재 경비업법에는 경호원의 업무를 신변보호업이라고 하고는 있지만 실질적인 신변보호의 내용을 담고 있지 못하다. 경호수칙은 경호대상과 경호로 인하여 일반인에게 손해가 발생하지 않도 록 최소화하여야 할 필요가 존재한다. 첫째, 경호 대상자의 안전 보장, 즉, 물리적, 심리적 위협으로부터 경호 대상자를 보호하고 둘째, 과잉 경호 방 지 및 시민과의 조화를 위해 공공질서를 유지하는 것이다. 셋째, 과잉 경호 를 방지하여 시민과의 조화를 이루고 넷째, 정당한 경호 활동을 수행하기 위한 법적·윤리적 기준 준수하는 것이다. 끝으로 테러, 돌발 상황 등에 대 한 신속한 위기 대응 대처를 해야 할 것이다. 물론 개별적인 상황에서 경 호수칙은 상황에 따라 조정될 수 있지만 기본적으로 완전한 경호의 제공과 공공의 권리를 최소 침해하는 사이의 균형을 유지해야 할 필요가 있다. 본 논문에서는 경호대상과 일반인 간의 권리 보호를 위해 경호원의 경 호수칙 준수의 필요성을 살펴보고, 이에 대한 입법적 근거를 어떻게 마련하 는 것이 좋은지 연구해 보고자 한다.

대상 판결은 ‘트리암시놀론 주사’를 통하여 비염치료를 한 병원에게 원고인 보험사가 피보험자들에 대한 부당이득반환채권을 피보전채권으로 하여 채권자 대위권으로 행사한 사건이다. 대상 판결은 전원합의체 판결로서 피보험자들의 무자력 요건이 갖추어지지 못하였다고 보았을 뿐 아니라, 밀접한 관련성도 부 정하였다. 그러나 반대의견은 보험자가 피보험자에 대하여 갖는 부당이득반환 채권과, 피보험자가 병원에 갖는 진료비 의 부당이득반환채권 사이에 채권자 대위소송의 ‘보전의 필요성’의 요건인 밀접한 관련성이 존재한다고 보았고, 강행규정 위반으로 인하여 진료행위가 무효가 됨으로써 부당이득반환청구권으 로 보험자에게 귀속이 되어야 할 것으로 보았다. 반대의견에서 지적한 것처럼 만약 병원에서 진료비 상당의 부당이득을 스스로 돌려놓지 않는다면, 채권자 대위소송의 보전의 필요성이 인정되지 않을 경우, 병원의 진료비 상당의 이득 을 피보험자들이 스스로 소액의 진료비를 되찾고자 번거로운 소송을 제기할 동인이나 현실적 가능성을 찾기 힘든 것이 현실인데, 환자의 입장에서는 법정 비급여와 임의비급여를 진료 시에 나누어 선택하기 힘들고, 실제로 보험재정 등의 한계를 이유로 국민건강보험에서 제공할 수 없는 진료의 경우, 국민건강 보험의 틀을 벗어나서라도 병원과 환자는 원하는 진료를 받을 수 있어야 할 것임에도 도리어 제한을 가하게 되어 옳지 않다. 보험사는 임의비급여든 법정 비급여든 보험계약에 따라 보험가입자가 받은 시술의 영수증만으로 보험료를 지급하므로 신 의료기술이 빠르게 등장하는 현실에서 임의비급여를 예외적으 로라도 채권자대위소송에서의 무자력 인정의 예외로 두어 밀접 관련성을 인 정할 수 있는 방안에 대하여 고찰하였다. 우리 법문에서 채권자대위권의 행사 에서 무자력의 요건은 명기되어 있지 않음에도 지나치게 엄격하게 해석되어 서는 안 될 것이며, 채권자대위소송의 실효성의 증대를 위하여 채권자대위소 송의 허용범위를 확대해 온 판례의 방향과 프랑스의 채권자대위소송의 개정 및 발전상황, 그리고 민사집행법과의 비교를 살펴보았다.