Can the employer be cited if the employee fails to follow a work restriction?

From the National Association of Manufacturers (NAM) legal challenge to OSHA’s Recording and Reporting regulations:

“Section 1904.7(b)(4)(viii) deals with the recordability of cases in which a physician or other health care professional has recommended a work restriction. The section also states that the employer "should ensure that the employee complies with [the recommended] restriction." This language is purely advisory and does not impose an enforceable duty upon employers to ensure that employees comply with the recommended restriction.”