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How should an employer count a case that results in a work restriction?
  • Employers must record cases of injury or illness that restrict an employee from performing routine job functions.

When a physician or healthcare professional recommends restricted work, employers should record it only if it affects one or more of the employee’s routine job functions. To determine whether this is the case, employers should evaluate the restriction in light of the routine functions of the injured or ill employee’s job. If the restriction from the employer or the physician/healthcare professional keeps employees from performing one or more of their routine job functions, or from working the full workday the employee would otherwise have worked, the employee’s work has been restricted and the case must be recorded.

For recordkeeping purposes, an employee’s routine functions are those work activities the employee regularly performs at least once per week.

If an employee works only for a partial work shift because of a work-related injury or illness, it should be recorded as a day of job transfer or restriction, except for the day on which the injury occurred or the illness began.

If a physician/healthcare professional recommends vague restrictions, such as that the employee engage only in “light duty” or “take it easy for a week,” an employer should ask the physician/healthcare professional whether the employee can do all the routine job functions and work the entirety of a normally assigned work shift. If the answer to both questions is yes, then the case does not involve a work restriction and does not have to be recorded as such. However, if the answer to one or both questions is no, the case involves restricted work and must be recorded as a restricted work case. In cases where it is not possible to get clarification from the physician/healthcare professional who recommended the restriction, an employer should record the injury or illness as a case involving restricted work.

When a physician/healthcare professional recommends a job restriction meeting the Occupational Safety and Health Administration (OSHA)’s definition, but the employee does all of the routine job functions anyway, employers still must record the injury or illness on the OSHA 300 Log as a restricted work case. If job restrictions are recommended, the employer must ensure that the employee complies with that restriction. If the employer receives recommendations from two or more physicians/healthcare professionals, the case should be recorded based on which recommendation is the most authoritative.

What if a case results in both days away from work and days of work restrictions?

The employer must check the box that reflects the most severe outcome associated with a given injury or illness. The severity of any case decreases on the log from column G (Death) to column J (Other recordable case). Since days away from work is a more severe outcome than restricted work, the employer is required to remove the check initially placed in the box for job transfer or restriction and enter a check in the box for days away from work (column H). Employers are allowed to cap the number of days away and/or restricted work/job transfer when a case involves 180 calendar days. For purposes of recordability, the employer would enter “180 days” in the “Job transfer or restriction” column and may also enter “1 day” in the "Days away from work" column to prevent confusion or computer-related problems.

What if a case results in a transfer to another job?

If an injured or ill employee is assigned to a job other than that employee’s regular job even for part of the day, the case involves transfer to another job. Both job transfer and restricted work cases are recorded in the same box on the OSHA 300 Log, starting from the day after the injury or illness occurred.

Days of job transfer or restriction are counted in the same way as days away from work. However, if an employer permanently assigns the injured or ill employee to a job that has been modified or permanently changed in a manner that eliminates the routine functions the employee was restricted from performing, the day count can stop when the modification or change is made permanent. In these cases, the employer should count at least one day of restricted work or job transfer.