Counting lost workdays after permanent job restrictions

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

July 2, 1992

Mr. Jerry A. Carter Specialist,
Occupational Safety and Health Services
McDonnell Douglas
[Recipient address omitted]
Dear Mr. Carter:

Thank you for your letter of June 8 requesting an interpretation for properly recording lost workdays on your OSHA Log of Injuries and Illnesses.

The situation presented in your letter is best addressed in Q & A B-9 on page 49 of the enclosed copy of the Recordkeeping Guidelines for Occupational Injuries and Illnesses. It states "...if long-term restrictions result in permanent assignments to modified jobs, the count of days of restricted work activity ceases once the transfer or modification is made permanent." (emphasis added) Permanent job modification can only stop the count of restricted work activity, not days away from work. Therefore, days away from work should continue to be counted until the employee returns to work. Once a modified job is made available and the employee returns to work, the count of lost workdays should be stopped.

Termination of employment may stop the count of lost workdays if it is unrelated to the employee's injury or illness. If the termination is in any way connected to the injury or illness, an estimate must be made of the total number of workdays that would have been lost had the employee not been terminated. (see Q & A B-11, page 49 of the Guidelines)

I hope this information will answer your question concerning OSHA injury and illness recordkeeping requirements. If you have further questions, please contact my staff at (202) 523-1463.

Sincerely,
Stephen A. Newell
Acting Director
Office of Statistics

Enclosure

[Requester letter reproduced on OSHA page; omitted here.]