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Permanent job changes and restricted-workday counts

Summary An employer asked when to stop counting restricted days on the former injury log. OSHA said a permanent modified assignment ended the count once the worker could perform all duties of the new job, while a temporary restriction remained countable.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1993-06-07-1
Date issued
June 7, 1993
Status
Archived by the agency
OSHA labels this an archive document and warns that it may no longer represent current policy.
Status last verified October 9, 2026

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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

June 7, 1993

Ms. Neta Hogestad
Longmont Foods
[Recipient address omitted]
Dear Ms. Hogestad:

Thank you for your facsimile dated April 26, requesting an interpretation on recording restricted work activity on the OSHA Log. As found on page 48 of the enclosed Recordkeeping Guidelines for Occupational Injuries and Illnesses, restricted work activity occurs when the employee is physically or mentally unable to perform all or any part of his or her normal assignment during all or any part of the normal workday or shift.

As found in Q&A B-9, on page 49 of the Guidelines, if long-term restrictions result in the permanent assignment to a modified job, the count of days of restricted work activity ceases once the transfer or modification is made permanent. When the modification or transfer is made, the employee must be able to perform all the duties of the new job at that point in time.

I hope you find this information useful. If you have any further questions, please contact my staff at Area Code (202) 219-6463.

Sincerely,
Stephen A. Newell
Director
Office of Statistics

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