1.4 Days away, restricted work and how to count them

1 One case, one box, chosen on the worst outcome

Every recordable case sits in exactly one of four columns on the OSHA 300 Log, and you pick the most serious outcome the case reached. A case that started as restricted duty and became days away is a days-away case. It does not appear twice.

Columns K and L hold the days — total days away, and total days of transfer or restriction. Days never enter a case-based rate. They are what the severity rate is built from, and they are also what a return-to-work program actually changes.

2 Counting days away: seven rules

1904.7(b)(3) is a sequence of small answers to small questions. Learn them once and the arithmetic stops being contentious.

• (i) Begin counting on the day after the injury occurred or the illness began. The day of the injury never counts.
• (ii) If a health care professional recommends days away and the employee comes to work anyway, record the days recommended. Encourage the employee to follow the recommendation.
• (iii) If the professional says return to work but the employee stays home, the count ends on the recommended return date.
• (iv) Count calendar days. Weekends, holidays and vacation days are included if the employee would not have been able to work on them.
• (v) and (vi) Injured before a weekend or a planned shutdown? Record it only if a health care professional indicates the employee should not have worked during that time.
• (vii) You may cap the total at 180 calendar days away and/or restricted. Entering 180 is adequate and you stop tracking.
• (viii) If the employee leaves the company for a reason unrelated to the injury — retirement, another job, a plant closing — you may stop counting. If they leave because of the injury, estimate the total and enter it.

And one that catches people at year end: (ix). A case that occurs in one year and produces days away in the next is recorded once, in the year the case occurred. If the employee is still away when you prepare the annual summary, estimate the total, use the estimate in the summary, and update the Log later when the real count is known or the 180-day cap is reached.

3 Restricted work: narrower than it sounds

1904.7(b)(4)(i) defines it: restricted work occurs when, as a result of the injury or illness, you keep the employee from performing one or more of the routine functions of the job, or from working the full workday they would otherwise have been scheduled to work — or a health care professional recommends that.

Then (b)(4)(ii) tightens it: routine functions are the work activities the employee regularly performs at least once per week. A restriction that only prevents something done twice a year is not a restricted work case. And (b)(4)(vi) closes the other side: producing fewer goods or services while still performing all routine functions and working the full shift is not restricted work.

Counting restricted days works like counting days away, through (b)(4)(xi) — with one difference: if you permanently modify the job so the restricted function is gone for good, you may stop counting on the day the change becomes permanent. You must still count at least one day.

4 Why the H-to-I move is the one to understand

Bringing an injured worker back on modified duty is good practice: people recover better at work, the days lost fall and the claim costs fall. What it does not do is change your DART rate. The case moves from column H to column I, and DART counts both.

It also does not change your TRIR, because the case was already recordable. What it changes is column K falling and column L rising — the day counts — and therefore the severity rate and the lost time case rate. Anyone who tells a customer that a return-to-work program will bring the DART down is about to be embarrassed by the 300A that customer asks to see.

5 Classifying a case in four steps

1. 1
   Did the employee die? Column G, and report to OSHA within 8 hours.
2. 2
   Any calendar days away after the day of the injury? Column H, and count the days into column K.
3. 3
   Any restriction of a routine function or transfer after the day of the injury? Column I, days into column L.
4. 4
   None of those, but a recording criterion was met — treatment beyond first aid, loss of consciousness, significant diagnosis? Column J.

Re-run the sequence whenever the case changes. A column J case that becomes a restriction three weeks later is lined out and re-entered, and 1904.33(b)(1) makes that a duty for five years, not a courtesy.

6 What good practice looks like here

Ask the treating professional two written questions on every case: can this employee perform all the routine functions of the job, and can they work a full shift? Those are the exact tests in (b)(4)(vii), and an answer in writing removes the judgment call from the recordkeeper and from the superintendent at the same time.

Second, keep a short note of the routine functions of each job — the activities performed at least once a week. It takes an afternoon to write for a whole crew and it is the difference between a defensible classification and a guess made under pressure.