A Thursday afternoon at a distribution center
At 3:15 p.m. on a Thursday, a shift supervisor at a distribution center calls the site's safety coordinator. A picker strained her back lifting a carton. The clinic's note says she can keep working but should avoid heavy lifting for now. The supervisor has already moved her to inventory counting at a desk and a scanner station.
"It's just light duty," the supervisor says. "She's still on the clock, so nothing to log, right?"
The coordinator is not sure. Nobody lost a shift, and nobody is calling it a transfer. But the picker no longer does the lifting she normally does. The coordinator also has to work out when the clock for the 300 Log entry starts, and whether anything else about the case matters.
By the end of this article you will be able to read 1904.7(b)(4) closely enough to say whether a light-duty assignment is restricted work, and how the days are counted.
Reference material with citations, not legal advice. You decide recordability and compensability, and you file.
Is light duty OSHA recordable? What the text of 1904.7(b)(4) says
OSHA has no category called "light duty." The recordkeeping rule uses restricted work, and the test sits in 29 CFR 1904.7 (checked 2026). In plain words, restricted work occurs when, because of a work-related injury or illness, the employer or a health care professional keeps the employee from doing one or more routine functions of the job, or from working the full workday the employee would otherwise have been scheduled to work.
That has two parts, and either can be enough:
- Routine functions. The question is whether the employee is kept from tasks that are part of the regular job. The regulation defines "routine functions" by how regularly the employee performs them. Read that definition in the eCFR text of Part 1904 (checked 2026) rather than relying on a rule of thumb.
- The full workday. If the employee works fewer hours than scheduled because of the injury, that also counts. It does not matter that the employee stays on the payroll.
So the label on the assignment does not decide anything. A new desk title, a paid shift and the employee's agreement are all beside the point. The test asks what the employee is kept from doing and whether the employee works the full scheduled day.
The restriction can come from the employer's own decision or from a health care professional's recommendation. In the opening scenario, the clinic's advice to avoid heavy lifting and the supervisor's reassignment both bear on the question. Whether lifting is a routine function of that picker's job is a fact question about that job.
For the wider recordability framework that this test belongs to, see our guide to what makes an injury OSHA recordable.
What you decide, and what the rule decides
The regulation supplies the test. You apply it to the facts, and nobody outside your organization makes that call for you.
That separation matters in practice. A supervisor may describe a case as "modified duty" for scheduling reasons. A clinician may write a restriction that is vague. The person who owns recordkeeping has to read both against the rule and decide whether the employee was kept from routine functions or from the full workday. ClaimsIntake does not make that call, and neither does a nurse line or a carrier.
Some practical questions help structure the decision:
- What did the employee regularly do before the injury?
- Which of those tasks is the employee now kept from doing, and who decided that?
- Is the employee working the full scheduled day?
- Is the restriction a recommendation or a firm instruction, and from whom?
- Is the case already recordable on another ground, such as medical treatment beyond first aid?
The last question matters because restricted work is one route to recordability among several. A case can be recordable on more than one ground at once. For the line between first aid and medical treatment, see OSHA recordable vs first aid.
Counting restricted days and the 180-day cap
Once a case is recordable because of restriction, the days of restriction are counted on the 300 Log. The regulation also gives a ceiling. In 1904.7, OSHA says:
"you may "cap" the total days away at 180 calendar days" — 29 CFR 1904.7, OSHA (checked 2026)
The text in that provision addresses days away, and the capping option applies to days of restriction as well, so read it for the exact wording when you cap a case.
A case that starts in one year and carries restricted days into the next is recorded only once, in the year it occurred. OSHA states it this way: "No, you only record the injury or illness once" (29 CFR 1904.7(b)(3)(ix), checked 2026). The restricted days that run past December 31 are added to the original entry. They do not create a second case.
Two points are easy to get wrong. The details of day counting, including whether the day of injury is counted and how calendar days differ from scheduled days, are set out in the regulation. Confirm them against the eCFR text before you rely on a spreadsheet formula. Our days-away counting guide walks through the mechanics.
The recording clock is separate. Each recordable case must be entered on the OSHA 300 Log and the 301 Incident Report, which are the employer's own records for the establishment, within seven calendar days of receiving information that a recordable injury or illness has occurred (29 CFR 1904.29, checked 2026). The clock runs from information that a recordable case occurred. Because recordability is your decision, document when you reached it. That date is the "Day Zero" for the log entry.
How restricted days are totaled and carried on the form is covered in how to fill out the OSHA 300 Log.
Physical therapy, new cases and recurrences
Two questions come up often once a restricted-work case is open.
Is physical therapy OSHA recordable? Physical therapy is not a recordkeeping category by itself. The question is whether it counts as first aid or as medical treatment beyond first aid. The first-aid list in 1904.7(b)(5)(ii) is a closed list of specific treatments, and as we read it, physical therapy and chiropractic treatment are not on it. They are treated as medical treatment, which makes a case recordable on that ground alone, even with no restriction. Verify that against the eCFR text before deciding a specific case. You decide whether the therapy was provided as treatment for the work-related injury.
New case or recurrence? Part 1904 has a separate provision for deciding whether a returning problem is a new case or a continuation of one already on the log. In plain terms, a new case generally means the employee had no previously recorded injury of the same type to the same body part, or had fully recovered and a new workplace event or exposure brought the symptoms back. If neither is true, the entry is generally treated as part of the earlier case and the days are added to it. The point matters for restricted work because an employee who returns to light duty after a flare-up may be continuing the old entry rather than starting a new one. Confirm the exact text before you treat a case as new or old.
BLS puts light duty in context. Over 2023–2024, cases with days of job transfer or restriction made up 38.5% of DART cases, and the median was 15 days of transfer or restriction (BLS, 2023–2024). Restricted work is a large part of the recordable picture, so the classification deserves a written reason each time.
The workers' compensation side runs on its own rules. A compensable claim is not automatically recordable, and the reverse holds too. See workers' comp claim vs OSHA recordable.
Keeping the decision defensible
If an inspector or an insurer asks why a case was or was not recorded, the best answer is a short note made at the time. Capture:
- the job functions the employee regularly performed;
- who set the restriction, and in what words;
- the scheduled workday against the hours actually worked;
- the date you decided the case was recordable;
- the date each restricted day was counted.
That note also protects you when someone later disagrees with the call. OSHA's expectation is that the log reflects the decision rule, not whichever label was used on the floor. Records and logs must be kept for five years following the end of the calendar year the records cover (29 CFR 1904.33, checked 2026). The retention duty stays with you.
Return-to-work programs, such as designing transitional tasks and managing the employee's path back, are a different job from recordkeeping. They belong to our sister line, TransitionalDuty. This article only covers how the assignment is classified on the log.
Where tools fit
Most small teams classify these cases in email threads and a spreadsheet. A spreadsheet can hold the days and the dates. It does not hold the rule that produced them or the date you read it. A free OSHA blank form works for the log itself, but you still apply the test case by case.
The OSHA Recordability Decision Workbook is built around that decision. It walks through recordability logic and computes days-away and restricted counts from the dates you enter, so the arithmetic is consistent from case to case. You still decide recordability, and you still file. For a 20–100-employee, single-state employer, the workbooks are the right starting point.
Before you pick a tool, take two steps this week. Pull your last three light-duty cases and check each against the 1904.7(b)(4) test as written in the eCFR. Then write down, for each one, who decided and when.
Reference material with citations, not legal advice. You decide recordability and compensability, and you file.
