It’s that time of year again: Top injury recordkeeping questions answered
For supervisors and safety professionals, OSHA recordkeeping can feel like a puzzle, especially when tracking days away, job transfers, work restrictions, and determining what to do when an injured employee leaves the company. These situations often raise questions about what is truly recordable, and the answers aren’t always obvious, so we are here to clear up some of that confusion.
When does a job transfer or restriction become recordable?
OSHA’s rule in 29 CFR 1904.7 states that an injury or illness is recordable if it results in days away, restricted work, or a job transfer. “Restricted work” means the employee cannot perform one or more routine job functions or cannot work a full shift because of the injury.
“Routine job functions” are the tasks an employee regularly performs as part of their job, typically at least once a week. So, even if a restriction limits only occasional or non-routine duties, it may not count as restricted work. But if the restriction prevents the employee from doing routine tasks, then it is recordable.
As an example, Rachel strains her wrist lifting boxes. Her doctor says, “No lifting over 10 pounds for two weeks.” Rachel still comes to work, but instead of her usual warehouse duties, she does light clerical tasks. Because this restriction prevents her from performing normal job functions, it counts as restricted work and must be logged on the OSHA 300 form. However, if Rachel’s normal job functions did not involve lifting more than 10 pounds, say she primarily worked at a computer, then the restriction would not impact her routine tasks and would not be recordable.
What about restrictions that aren’t injury-based?
This is where confusion often creeps in. OSHA clarified in a 2016 letter of interpretation that restrictions imposed for reasons unrelated to physical ability, such as protecting product quality or operational efficiency, are not recordable. For example, Brandon cuts his finger but can still do his job. The company keeps him out of a sterile area to avoid contamination, not because he’s physically limited. OSHA says that’s not a recordable restriction because it’s about quality control, not capability.
Additionally, OSHA clarifies an important point about productivity. A slowdown in speed or efficiency does not make a case recordable as long as the employee can still perform all of their normal job functions. Recordability is based on physical limitations, not business-driven decisions or reduced output.
For example, if Ed injures his arm and works more slowly but still completes all his usual tasks, that’s not restricted work. Productivity loss alone doesn’t trigger recordability, the key factor is whether the injury prevents the employee from performing routine job duties.
How does counting days away, restrictions, or transfer work?
Once you determine a case is recordable, OSHA requires you to start counting the day after the injury or illness occurs and continue until the employee resumes all routine job functions without restriction. This is spelled out in 29 CFR 1904.7(b)(3)(vii). The count includes calendar days, not just scheduled workdays, and weekends and holidays are part of the total.
For example, if Cindy spends three days doing inventory instead of her usual production work, those three days go in the OSHA 300 log. If her restriction spans a weekend, those days count too, even if she wasn’t scheduled to work.
OSHA also sets a cap of 180 calendar days for combined totals of days away from work, restricted work, and job transfer. If the injury or illness continues beyond that point, you stop counting once the overall total reaches 180 days, even if the employee remains under limitations.
What if an injured employee leaves the company?
This scenario often creates uncertainty for supervisors. If an injured employee leaves, what happens to your OSHA log? OSHA addresses this in 1904.7(b)(3)(viii). The rule is straightforward but requires a bit of determination from the employer:
- If the departure is unrelated to the injury, you stop counting restricted days and days away from work on the employee’s last day. For example, Jeff accepts a promotion at another company. His wrist injury had him on light duty, but his decision to leave was for career advancement. You record the days up to his last shift and stop there.
- If the departure is related to the injury, you must estimate the total number of days the employee would have been restricted or away and record that estimate. OSHA expects employers to make a reasonable projection based on medical advice and typical recovery times. For instance, Gina resigns because her back injury prevents her from performing essential job functions. Her doctor anticipated six weeks of restrictions. Even though she left after two weeks, you record the estimated six weeks.
OSHA emphasizes that these estimates should be made in good faith. You’re not expected to predict the future perfectly, but you should use available information, such as physician recommendations or similar cases, to make a reasonable determination.
Key to remember: OSHA recordkeeping can seem complex, and many times create more questions than answers, but the agency offers clarity through its letters of interpretation. When in doubt, rely on these official resources, they’re designed to help employers make accurate, compliant decisions.
