OSHA Recordkeeping Handbook - denix

A partial day of work is recorded as a day of jobtransfer or restriction for recordkeeping purposes,except for the day on which the injury occurred orthe illness began.(vi)If the injured or ill worker produces fewergoods or services than he or she would have producedprior to the injury or illness but otherwise performsall of the activities of his or her work, is thecase considered a restricted work case?No. The case is considered restricted work only ifthe worker does not perform all of the routine functionsof his or her job or does not work the full shiftthat he or she would otherwise have worked.(vii) How do I handle vague restrictions from aphysician or other licensed health care professional,such as that the employee engage only in “lightduty” or “take it easy for a week”?If you are not clear about a physician or otherlicensed health care professional’s recommendation,you may ask that person whether theemployee can perform all of his or her routine jobfunctions and work all of his or her normallyassigned work shift. If the answer to both of thesequestions is “Yes,” then the case does not involvea work restriction and does not have to be recordedas such. If the answer to one or both of thesequestions is “No,” the case involves restricted workand must be recorded as a restricted work case. Ifyou are unable to obtain this additional informationfrom the physician or other licensed healthcare professional who recommended the restriction,record the injury or illness as a case involvingjob transfer or restricted work.(viii) What do I do if a physician or otherlicensed health care professional recommends ajob restriction meeting OSHA’s definition but theemployee does all of his or her routine job functionsanyway?You must record the injury or illness on theOSHA 300 Log as a restricted work case. If aphysician or other licensed health care professionalrecommends a job restriction, you shouldensure that the employee complies with thatrestriction. If you receive recommendationsfrom two or more physicians or other licensedhealth care providers, you may make a decisionas to which recommendation is the mostauthoritative, and record the case based uponthat recommendation.…The final rule’s concept of restricted work isbased both on the type of work activities the injuredor ill worker is able to perform and the length of timethe employee is able to perform these activities. Theterm “routine functions of the job” in paragraphs1904.7(b)(4)(i) and (b)(4)(ii) clarifies that OSHA considersan employee who is unable, because of a workrelatedinjury or illness, to perform the job activitieshe or she usually performs to be restricted in thework he or she may perform…....OSHA agrees that it makes little sense to consideran employee who is prevented by an injury or illnessfrom performing a particular job function he orshe never or rarely performed to be restricted….For example, OSHA finds that, for the purposes ofrecordkeeping, an activity that is performed onlyonce per month is not performed “regularly.” …...In the final rule, OSHA has decided that definingrestricted work as work that an employee would regularlyhave performed at least once per week isappropriate, i.e., OSHA believes that the range ofactivities captured by this interval of time will generallyreflect the range of an employee’s usual workactivities. Activities performed less frequently thanonce per week reflect more uncommon work activitiesthat are not considered routine duties for thepurposes of this rule. However, the final rule doesnot rely on the duties the employee actually performedduring the week when he or she was injuredor became ill. Thus, even if an employee did not performthe activity within the last week, but usuallyperforms the activity once a week, the activity will beincluded….The final rule’s restricted work provisions alsoclarify that work restriction must be imposed by theemployer or be recommended by a health care professionalbefore the case is recordable. Only theemployer has the ultimate authority to restrict anemployee’s work, so the definition is clear that,although a health care professional may recommendthe restriction, the employer makes the final determinationof whether or not the health care professional’srecommended restriction involves the employee’sroutine functions. Restricted work assignments mayinvolve several steps: an HCP’s recommendation, oremployer’s determination to restrict the employee’swork, the employer’s analysis of jobs to determinewhether a suitable job is available, and assignmentof the employee to that job. All such restricted workcases are recordable, even if the health care professionalallows some discretion in defining the type orduration of the restriction…....[T]he Congress has directed that the recordkeepingsystem capture data on non-minor work-relatedinjuries and illnesses and specifically on restrictedwork cases, both so that the national statistics onsuch injuries and illnesses will be complete and sothat links between the causes and contributing fac-§1904.7OSHA RECORDKEEPINGHANDBOOK57