Job13

OSHA interpretation · 1993-08-03

Recording restricted work activity on the OSHA 200 Log.

OSHA’s standing caveat

Interpretation letters explain existing requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. Enforcement guidance may be affected by later changes to OSHA rules, and a letter addresses the facts it was given — not necessarily yours.

August 3, 1993 Mr. E. R. Dhayer Exxon Company, U.S.A. Post Office Box 4692 Houston, Texas 77210-4692 Dear Mr. Dhayer: Thank you for your letter dated July 2, requesting an interpretation regarding recording restricted work activity on the OSHA 200. Your letter was forwarded to my office from the Houston Area Office. My Division of Recordkeeping Requirements is responsible for the administration of the OSHA injury and illness recordkeeping system nationwide. The concept of restricted work is based on three criteria as follows: 1. The employee was assigned to another job on a temporary basis, or 2. the employee worked at a permanent job less than full time, or 3. the employee worked at his or her permanently assigned job but could not perform all the duties normally connected with it. An employee's normal job duties has been interpreted to mean anything the employee would be expected to do throughout the calendar year. In the scenario described in your letter, the chauffeur is expected to carry bags weighing more then 20 pounds (and did so using his right arm). The physician restricted the employee from lifting anything more than 20 pounds with his right arm. The employee, therefore could not perform all the duties normally connected with his job, and days of restricted work activity should be counted. I hope you find this information useful. If you have further questions please contact my staff at Area Code (202) 219-6463. Sincerely, Stephen A. Newell Director Office of Statistics

Reproduced verbatim from osha.gov. US Government work, public domain (17 U.S.C. § 105).

Other letters on the same sections

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