Restricted work under OSHA is not a vague label for being careful after an injury. It is a defined recordkeeping outcome: a work-related injury or illness is recordable if it results in a recommendation that the employee not perform one or more routine job functions, or not work the full workday they would otherwise have been scheduled to work. A worker can be on site, useful and cheerful—and still have a restricted-work case.
The practical definition of restricted work
29 CFR 1904.7 asks two questions. Did the employee keep working but get told not to perform one or more routine job functions? Or did the employee get told not to work the full scheduled workday? “Routine” means an activity regularly performed at least once a week. The restriction can come from a clinician or from the employer, provided it is based on the injury or illness.
| Situation | Likely result | Reason |
|---|---|---|
| Worker skips a routine lifting task for three shifts on clinician instruction | Restricted work | A normal weekly task is prohibited |
| Worker leaves two hours early because of a work injury | Restricted work | Cannot work the full scheduled day |
| Worker chooses to avoid overtime but completes all routine duties | Not automatically restricted | Voluntary preference is not a medical restriction |
| Employer assigns a different job because of injury limits | Job transfer/restricted work | The normal role cannot be performed |
Check the actual instruction and usual job duties; “light duty” alone is not an OSHA category.
Normal work is more specific than a job title
Take a line mechanic whose title is “technician”. One week she climbs ladders, uses a torque wrench and moves 25-pound parts; the next she spends a day completing training. A restriction against lifting and climbing matters because those are routine functions, even if the day she returns happens to involve desk work. Conversely, assigning a temporary administrative task does not by itself prove restriction unless it replaces normal work because of the injury.
Write a short normal-duty baseline when the case begins. “Normally drives a forklift for most shifts, loads pallets twice weekly and can lift 40 pounds” is far more useful than “warehouse operative”. It stops the decision changing with whoever happens to be on duty.
Count calendar days, not scheduled shifts
The day of injury does not count. Start with the next calendar day and count every calendar day—weekends, holidays and days the employee was not scheduled to work—until the restriction ends. OSHA caps days away and days of restriction/job transfer at 180 each. Our 180-day guide walks through the separate counts.
For example, a worker injured on Friday is restricted from normal lifting through the following Thursday. Count Saturday as day one, not the next Monday. If the clinician provides an estimated end date but lifts the restriction earlier, correct the count. If the worker has not returned to normal tasks when the annual log is completed, estimate the count, then update it once the outcome is known.
A realistic light-duty example
Andre strains his shoulder while stacking cases. Urgent care permits him to work but says “no lifting above 15 pounds for seven days”. Andre’s ordinary job includes lifting cases every day. His supervisor assigns him to count empty pallets and check labels. This is a restricted-work case from the day after injury: he cannot perform a routine function because of the condition. It makes no difference that the temporary task is productive or that Andre has not lost any pay.
Now change the instruction to “resume activity as tolerated” with no job limitation. The supervisor, being cautious, tells Andre to avoid lifting for a day. That can still be restricted work if the employer imposed the limit because of the injury. Where there is doubt, record who made the instruction, why and what activity was withheld. A well-meaning accommodation should not disappear from the record simply because nobody called it a restriction.
Restrictions versus days away and medical treatment
These are separate paths to the same recordable result. A single case may involve medical treatment beyond first aid, then restrictions, then days away. On the 300 Log, classify the most serious outcome in the required order; keep day counts accurate for any days away and restriction/transfer. The work restriction is enough on its own after work-relatedness and new-case status are established.
Do not use the phrase “modified duty” as a conclusion. Ask what changed: a task, a number of hours, a location or a shift? Job13’s free check turns those facts into a cited Part 1904 path and signals when one fact is still missing.
Pitfalls worth catching early
- Counting only shifts worked. The rule counts calendar days after the injury.
- Assuming an employee must lose wages or be sent home. Neither is required.
- Ignoring restrictions that last part of one shift. A partial day can count.
- Treating a restriction unrelated to the injury as recordable. The causal link still matters.
- Letting an estimated return date become the final count without a follow-up.
Decide the restriction before planning the accommodation
Supervisors often want to solve the staffing problem quickly, which is sensible, but it can muddle the record. Take the clinician’s limits or employer instruction, compare them with routine functions, classify the case, then design the temporary assignment. A creative accommodation may be good for the worker and good for operations; it does not remove a restriction that already exists. Keep the temporary task description and normal job description together so the next reviewer can see why the result was recorded.
Frequently asked questions
Does light duty always mean a recordable OSHA case?
Not as a label alone. It is recordable when the injury-related assignment means the worker cannot perform one or more routine job functions or cannot work a full scheduled day. Compare the restriction with actual routine duties.
Does the day of injury count as a restricted-work day?
No. Begin counting on the day after the injury or illness. Count consecutive calendar days, including weekends and holidays, until normal work resumes or the 180-day cap applies.
Can an employer-imposed restriction count without a doctor’s note?
Yes. A restriction imposed by the employer because of a work-related injury or illness can count. Preserve the reason, date and duties affected so the connection is clear.
What is the difference between restricted work and job transfer?
Restricted work limits the employee in their regular job; job transfer assigns them another job because they cannot perform all routine functions. Both trigger recordability and use the same restriction/transfer day-count column on the OSHA 300 Log.
