Tracking Work Restrictions and Lost Time: A Practical Guide for Occupational Health

Tracking work restrictions and lost time is the part of injury recordkeeping that quietly goes wrong. The paperwork itself is easy; getting the outcome right on day one and keeping it right for the next five years is not — a case shifts under you. A nurse who started out home for a week comes back on a 15-pound lifting limit, and now the case has both days away and restricted days that have to be counted, capped, and logged correctly.

Restrictions aren't a footnote. Over the 2023–2024 reference period, private-industry DART cases split roughly 61.5% days-away versus 38.5% restriction-or-transfer only, and the median restriction case ran longer — 15 days versus 8 for days-away, per the BLS Survey of Occupational Injuries and Illnesses. If you're only sharp on lost time, you're mishandling nearly 40% of your recordable severity cases.

Here's the workflow that keeps you clean: classify the outcome, count the days the right way, log it, summarize it, and benchmark it.

What actually counts as a work restriction

This is the single most misread rule in the whole subpart. Restricted work exists when either the employer keeps the employee from performing one or more routine job functions or from working the full workday, or a physician or other licensed health-care professional recommends the employee not perform one or more routine functions (29 CFR 1904.7(b)(4)(i)).

The word doing the work is routine. A routine function is any work activity the employee regularly performs at least once a week (1904.7(b)(4)(ii)). So a "no lifting over 20 lbs" note, a light-duty reassignment, or "desk only, no patient transfers" is restricted work if it touches something they'd normally do weekly. Managers love to call it "just modified duty." On the 300 Log, it's a restriction, and it counts.

How to count the days: the lost time calculation

Restricted and job-transfer days are counted the same way as days away from work (1904.7(b)(4)(xi)) — same method, separate columns. Getting the lost time calculation right comes down to three rules people trip over:

• Start the day after. Counting begins on the day after the injury or onset, not the day it happened (1904.7(b)(3)(i)).
• Count calendar days. Include weekends, holidays, and days the person wasn't scheduled to work — regardless of the schedule (1904.7(b)(3)(iv)). A three-shift-a-week aide restricted for two weeks still gets 14 days, not 6.
• You may cap at 180. You can stop counting once the combined days away plus restricted/transfer days for a single case reaches 180 calendar days (1904.7(b)(3)(vii)).

One edge case worth pre-deciding: if the employee leaves for a reason unrelated to the injury — retirement, another job, a plant closing — you may stop counting. If they leave because of the injury, you must estimate the total days they would have been out and enter that number (OSHA Recordkeeping FAQ 7-21).

How restrictions feed the 300 Log

Pull the outcome columns straight from the current OSHA 300 form. Columns H, I, and J are single checkboxes where you mark the case's most serious outcome — H for days away, I for job transfer or restriction, J for other recordable cases. Both restricted-work and job-transfer cases go in the same box, Column I (1904.7(b)(4)(x)). Check exactly one outcome box per case.

The day counts live in two separate columns: Column K (days away from work) and Column L (days on job transfer or restriction). So a case that began with a day away and then moved to restricted duty is classified as a days-away case — you check Column H only, because that's the most severe outcome — but you still record the numbers in both K and L. The three forms then work together: the 300 Log tracks every case, the 300A rolls them into an annual summary, and the 301 captures the incident detail.

The DART rate, and why occ-health watches it

DART — Days Away, Restricted, or Transferred — is the rate that isolates your severity cases. The formula is the standard OSHA incidence rate: (DART cases × 200,000) ÷ hours worked (OSHA interpretation, 2016-08-23). The 200,000 is the hours 100 full-time employees log in a year (100 × 40 × 50), so the result reads as cases per 100 FTEs.

The numerator is only cases with an entry in Column H or I — not Column J. That's the point of tracking it apart from TRIR: DART strips out the recordables that had no impact on the person's ability to work and shows you the lost-productivity cases. If your restriction classifications are sloppy, your DART is wrong, and it's the number the whole organization gets judged on.

Keeping records accurate for five years

You retain the 300 Log, the privacy case list, the 300A, and the 301 forms for five years after the end of the calendar year they cover (29 CFR 1904.33). During that window you must update the stored 300 Log when a case's classification or day count changes — line out the original entry and enter the corrected information (1904.33). You don't have to re-do the 300A or 301.

This is where restricted duty tracking bites: a case starts as days-away, converts to restricted, then gets capped — three possible edits to one line over months. Whatever system you use, it has to preserve the change history, not just overwrite it — a shared spreadsheet rarely does.

Two dates to keep: post the 300A in the workplace from February 1 through April 30 (OSHA forms page), and if you're a covered establishment, submit electronically through the Injury Tracking Application by March 2 — OSHA doesn't accept mailed or emailed data. Establishments with 20–249 employees in designated higher-hazard industries submit 300A data; those with 100+ employees in Appendix B industries submit detailed 300 and 301 case data too.

Getting this wrong is expensive. For 2026, recordkeeping and posting violations run up to $16,550 per violation, and willful or repeat violations up to $165,514, unchanged from 2025 (OSHA penalty memo, 2026-05-21).

FAQ

Is light duty a recordable restriction? If it keeps the employee from a routine function they'd normally do at least weekly, yes — that's restricted work under 1904.7(b)(4), classified in Column I, with days counted like days away and recorded in Column L.

Do weekends count toward restricted days? Yes. Count calendar days including weekends, holidays, and unscheduled days (1904.7(b)(3)(iv)).

A case changed from days-away to restricted after I filed. Do I fix it? Yes — you must update the stored 300 Log within the five-year window, lining out the old entry and entering the new classification (1904.33).

Confirm your obligations against your own situation — 22 states plus some territories run OSHA-approved State Plans that may impose additional or stricter recordkeeping and reporting rules. If your day-counting and classification changes still live in a shared spreadsheet, that's the first thing worth fixing before your next 300A goes up.