An employee gets hurt on a Thursday afternoon and doesn't come back until the following Wednesday. How many days away from work does OSHA want on the log — five, four, or something else? Most people doing this by hand count wrong at least once, usually because they include the day of the injury itself. Days away from work is one of the six recording criteria in 29 CFR 1904.7(b)(3), and the counting method is mechanical, not a judgement call. This post walks through it step by step, with a worked calendar example, so you get the number right the first time.
What counts as a "day away from work" under OSHA?
Under 1904.7, a case is recordable on this criterion if the employee is unable to work all or any part of a day after the day of the injury or illness, because a physician or other licensed health care professional keeps them off work, or because the employer keeps them off work for the period the professional recommended. It doesn't matter whether the employee was scheduled to work that day. It doesn't matter if they only would have worked a partial shift. If they couldn't do their job because of the injury, and that inability falls after the day it happened, it's a day away.
There's a related but separate category worth knowing before you start counting: restricted work under 1904.7(b)(4) applies when the employee is at work but on modified duty rather than fully absent. The two get tracked as separate day counts on the OSHA 300 Log, and it's common for a single case to run through a restricted-duty period first and a days-away period later, or the other way round. Keep them apart. Mixing the two counts is one of the more common ways employers get the log wrong.
Why doesn't the day of the injury count?
This is the rule that trips up almost everyone doing this by hand, so it's worth stating plainly: the day of the injury itself is never counted, even if the employee left early or didn't work another minute that day. Counting begins the calendar day after the injury or illness occurred. An employee who's sent home at 10am on a Monday with a broken wrist doesn't get Monday counted as a day away — Monday is the injury day. Tuesday is day one.
This isn't OSHA being stingy. It's a deliberate line in the regulation, there so that every employer counts the same case the same way, rather than some counting a partial injury day as a full day away and others not. If you remember only one rule from this article, make it this one.
How do you count days away from work: calendar days or workdays?
Calendar days, not workdays. This is the second rule that catches people out, usually in the opposite direction from the first. Once the clock starts the day after the injury, it doesn't stop for weekends, doesn't stop for a public holiday, and doesn't stop just because the employee wasn't scheduled to work that particular day anyway. If the employee was kept off work by a physician's recommendation, every calendar day inside that recommended period counts, whether or not it was a day they'd normally have clocked in.
That surprises people who assume OSHA recordkeeping tracks scheduled shifts. It doesn't. A four-day-a-week warehouse employee who's off for two full weeks under doctor's orders gets 14 days away counted, not eight. The rule cares about the period the employee was medically unable to work, not the days they happened to be rostered.
Worked example: counting from a Thursday injury
Take a concrete case. An employee on a five-day, Monday-to-Friday schedule injures their back lifting a pallet on Thursday, 5 March. They finish the shift, mention it to their supervisor, and go home. On Friday morning it's worse, so they see a physician, who diagnoses a lumbar strain and writes them off work for ten calendar days.
Here's how that period counts:
| Date | Day of week | Scheduled to work? | Counted as day away? | Running total |
|---|---|---|---|---|
| Thu 5 Mar | Thursday | Yes | No — day of injury | 0 |
| Fri 6 Mar | Friday | Yes | Yes | 1 |
| Sat 7 Mar | Saturday | No | Yes | 2 |
| Sun 8 Mar | Sunday | No | Yes | 3 |
| Mon 9 Mar | Monday | Yes | Yes | 4 |
| Tue 10 Mar | Tuesday | Yes | Yes | 5 |
| Wed 11 Mar | Wednesday | Yes | Yes | 6 |
| Thu 12 Mar | Thursday | Yes | Yes | 7 |
| Fri 13 Mar | Friday | Yes | Yes | 8 |
| Sat 14 Mar | Saturday | No | Yes | 9 |
| Sun 15 Mar | Sunday | No | Yes | 10 |
Ten calendar days away from work, running 6–15 March. The injury day (5 March) isn't counted, and the two weekends inside the recovery period are counted even though the employee wasn't scheduled to work either one.
The final count on the 300 Log for this case is ten days away from work, entered against the injury logged for 5 March 2026. Not eight (the workdays), not eleven (if you'd mistakenly counted Thursday), just ten. That's the arithmetic the rule asks for, applied without any interpretation needed.
What is the OSHA 180-day cap and when does it apply?
You don't have to count forever. Once the days-away tally for a single case reaches 180 calendar days, you can stop, even if the employee is still out. OSHA capped the count deliberately, so that one severe, long-recovery case doesn't force a recordkeeper to keep updating the log indefinitely. Record 180 in the days-away column, close that count out, and move on. If the employee later returns to work and then the same injury flares up and takes them away again, that's a separate resumption of the same case (not a new one) — pick the count back up rather than restarting it, and note the additional days, still capped at 180 total for that case.
The 180-day figure isn't a target and it isn't a typical outcome — the overwhelming majority of days-away cases resolve in a small fraction of that window. It exists as a backstop for genuinely severe cases: major fractures, spinal injuries, extended surgical recovery. If you're anywhere near it, the case is serious enough that you should already be tracking it closely, and it's worth checking OSHA's Letters of Interpretation for any case-specific nuance, since long-duration cases are where employers most often write in with edge-case questions.
What if the doctor recommends days off but the employee works anyway?
This one surprises people. If a physician or other licensed health care professional recommends the employee stay off work, but the employee shows up anyway — against that recommendation, maybe out of a sense of duty or because they don't want to lose the day's pay — the case is still recorded as a days-away case. You count the days the employee would have been away, based on the professional's recommendation, not the days they actually stayed home. The employer's recordkeeping obligation follows the medical recommendation, not the employee's choice to override it. This is a narrow but real scenario, and it's one where guessing gets employers into trouble, because the intuitive answer — "they worked, so no days away" — is wrong.
Where teams get this wrong
A few mistakes show up again and again when the count is done by hand or in a spreadsheet:
- Counting the day of the injury. Covered above, and still the single most common error. If your count includes the injury day, subtract one.
- Stopping the count too early. Some recordkeepers stop updating the log once the case is initially entered, rather than revisiting it once the employee's actual return date is known. The days-away figure should reflect the real outcome, not an early estimate.
- Not resuming the count correctly after a relapse. An employee returns to work, then the same injury flares up and they're sent home again. That's a continuation of the same case, and the days need to be added to the existing tally (up to the 180-day cap), not treated as a fresh, separate case with its own count.
- Confusing calendar days with workdays. Skipping weekends or days the employee wasn't rostered to work understates the total. The rule doesn't care about the schedule; it cares about the calendar.
- Mixing up days away with restricted work. These are two different criteria with two different columns on the 300 Log. An employee on modified duty at the workplace is a restricted-work case, not a days-away case, even if their normal tasks are unrecognisable for a few weeks.
One EHS manager we spoke with put it this way: "The math itself is simple. What gets people is that it doesn't match how anyone naturally thinks about time off work — nobody counts a Saturday against a recovery period unless a rule specifically tells them to."
Recordkeeping citation activity around days-away and restricted-work entries has stayed a focus area for OSHA in recent years, and manual counting errors are a recurring theme in inspection findings — not because the rule is complicated, but because it's unintuitive if you've never sat down and read it closely. See our note on rising OSHA recordkeeping citations for more on where enforcement attention has been concentrated.
Get the count right without doing it by hand
The counting method above is mechanical once you know it, but it's still easy to make a one-day error that throws off your Form 300A summary and your TRIR and DART rates at year end. Job13 applies the day-of-injury exclusion and the 180-day cap automatically, keeps days-away and restricted-work counts separate on the log, and flags anything that needs a human decision as "needs review" instead of guessing. Run a case through the free check at /recordable to see it applied to your own numbers, and see worked recordability scenarios for more examples like the one above.
Frequently asked questions
Does the day of the injury count as a day away from work?
No. The day the injury or illness occurred is never counted, even if the employee left before their shift ended or was unable to do any more work that day. Counting starts the calendar day after the injury.
Do weekends and holidays count toward the OSHA days-away total?
Yes. Once the days-away period starts, every calendar day within it counts, including weekends, holidays, and any day the employee wasn't scheduled to work. The count follows the calendar, not the work schedule.
What happens once a days-away case reaches 180 days?
You can stop counting at 180 calendar days and record that figure on the 300 Log, even if the employee remains away from work longer. The 180-day figure is a cap, not a typical outcome, and applies per case.
Is days away from work the same as restricted work?
No. Days away from work under 1904.7(b)(3) means the employee couldn't work at all. Restricted work under 1904.7(b)(4) means the employee is at work but on modified duty. They're tracked as separate day counts on the 300 Log, and a single case can involve both, one after the other.
If a doctor says stay home but the employee comes to work anyway, is it still a days-away case?
Yes. The case is recorded based on the physician's or other licensed health care professional's recommendation, not on whether the employee actually followed it. Count the days the employee would have been away under that recommendation.
This article explains general OSHA recordkeeping concepts under 29 CFR Part 1904 for informational purposes and is not legal advice. For guidance on a specific case, consult a qualified safety professional or refer directly to OSHA's recordkeeping resources and the full text of Part 1904.
