Circumstances That Require Recording Employee Restricted Activity On The OSHA 300

Catapult Advisors occasionally receives questions about recording employee work restrictions on the OSHA 300 (Log of Work-Related Injuries and Illnesses).

Employee work restrictions due to occupational injury or illness need to be recorded on the OSHA 300 if the restriction affects one or more of an employee’s routine job functions (Catapult recommends that the attending physician understand what the employee duties are and the related physical and mental requirements – a clear job description should be sent to the physician.)

Even if a physician requirement that reduces the amount of such work that can be performed should be considered a restriction. As an example, sometimes a physician will restrict an employee from working the employee’s normal full day.  Employers, on occasion, may temporarily transfer an employee with restrictions to another position. These two scenarios should also be recorded as restricted activity on the log.

If you permanently assign the injured or ill employee to a job that has been modified or accommodates the employee’s restrictions, you may stop the restriction day count when the transfer is made permanent. Essentially, the worker is no longer in restricted duty for their current “true” position at that time.

You must however, count at least one day of restricted work or job transfer for such cases.  Weekends and holidays should also be included when counting days of restricted activity.

Work restrictions that do not affect any of an employee’s routine job functions or do not prevent an employee from working a normal workday need not be recorded. As an example, an office employee who is told not to lift more than 50 lbs. likely is not changing her routine job duties to ensure that restriction is accommodated.

For more information about OSHA recordkeeping requirements go here.

Written by a Catapult Advisor.

Reviewed for NC/SC law only.

Click on the button link below to download this FAQ on Circumstances That Require Recording Employee Restricted Activity On The OSHA 300.
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