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Restricted duties for workers trained across production lines

Summary An employer asked whether an injured worker had restricted work if a medical limit affected a job the worker was trained for but was not currently doing. OSHA said a cross-trained job was part of normal duties, so the restriction counted under the former recordkeeping system.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1993-06-14-1
Date issued
June 14, 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OSHA labels this an archive document and warns that it may no longer represent current policy.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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OSHA labels this an archive document and warns that it may no longer represent current policy. It may no longer reflect the agency's current position. Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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 14, 1993

Ms. Nancy Liaboe
Abbott Laboratories
[Recipient address omitted]
Dear Ms. Liaboe:

Thank you for your facsimile requesting an interpretation on recording restricted work activity on the OSHA 200 Log. 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.

If an employee is cross-trained to perform many jobs on different production lines, any one of those jobs is considered his or her normal duties. Therefore, if the employee is injured and is given a medical restriction which would impact one job on a production line that he or she is currently not working, the case would involve days of restricted work activity.

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

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