OSHA Restricted Work vs Light Duty for Employers

OSHA restricted work vs light duty confuses supervisors because clinics write informal limits. Industrial MD maps those notes to routine functions, 300 log columns, and a same shift clarification script.

OSHA restricted work vs light duty is a wording problem that shows up on almost every industrial work-status form. Clinic notes often say "light duty." OSHA 1904.7 records restricted work or job transfer when a work-related injury or illness keeps the employee from a routine job function or from working the full scheduled shift, except on the day the injury or illness began.

Those are not the same sentence. Light duty is informal workplace language. Restricted work is an OSHA recordkeeping term with a definition. Treating them as synonyms is how a modified-duty assignment and a 300 log column drift apart.

OSHA Restricted Work vs Light Duty Starts With Routine Functions

OSHA's 1904.7 general recording criteria explain restricted work. Restricted work occurs when, as a result of a work-related injury or illness, the employer keeps the employee from one or more routine job functions or from the full workday the employee would otherwise have been scheduled to work, or a licensed health care professional recommends the same. Routine functions are work activities the employee regularly performs at least once per week.

A recommended restriction is not automatically a restricted-work case. The employer still compares the restriction to that employee's routine functions. If the worker can still perform every weekly function and work the full scheduled shift, the case may not be a restricted-work case even if the clinic wrote "light duty."

OSHA also tells employers what to do with vague "light duty" or "take it easy" notes: ask whether the employee can perform all routine functions and work the full assigned shift. If you cannot get that clarification, OSHA's rule directs employers to record the case as restricted work.

OSHA lost time definition covers the related mistake of collapsing days away, restricted work, and job transfer into one "LTI" label.

Why Clinic "Light Duty" Language Creates Recordkeeping Noise

Occupational clinics, urgent care, and emergency departments are not writing OSHA 300 log entries. They are describing activity limits. "No lifting over 10 pounds," "no ladder work," and "desk duty" may or may not restrict a routine function, depending on the job.

A warehouse selector who cannot lift 10 pounds has likely lost a routine function. An office-based dispatcher with the same note may not have. The job demands file is what makes the OSHA analysis possible. Without it, supervisors either over-record every light-duty slip or under-record because "the worker still came in."

A clinic visit alone does not make a case recordable. Diagnostic procedures such as X-rays, MRIs, and blood tests are not medical treatment by themselves under OSHA 1904.7. A case may still be recordable because of medical treatment, prescription medication at prescription strength, restricted work, job transfer, days away, significant diagnosis, or another OSHA criterion. Employers remain responsible for final OSHA recordability determinations.

OSHA recordkeeping support helps keep the clinical note, the job-demands comparison, and the log decision in one review instead of three inboxes.

Restricted Work, Job Transfer, and Days Away Are Different Columns

OSHA records restricted work and job transfer in the same 300 log box, and records days away in a separate box. A worker who stays on site but cannot perform a weekly task is not the same case as a worker who misses calendar days.

Partial-shift work after the day of injury is generally counted as a day of job transfer or restriction. Producing fewer units while still performing all routine functions is not restricted work by itself. A transfer to another job for part of the day, after the day of injury, is treated as a job-transfer case.

Count calendar days, including weekends and holidays the worker could not have worked because of the injury or illness. Do not treat "the worker showed up Monday" as proof that a Friday injury created no restricted-work or days-away question if a licensed provider said the worker should not have worked, or should have performed only restricted work, over the weekend.

Return-to-work programs are the operational side of this: matching real restrictions to temporary tasks without pretending every light-duty label is an OSHA conclusion.

A Restricted Work vs Light Duty Decision Table

Use this table when a work-status note arrives. It is an employer documentation aid, not a substitute for case-specific OSHA review.

| What the note says | First employer question | Often points toward | | --- | --- | --- | | "Light duty" with no task limits | Can the worker do every function performed at least weekly, and the full shift? | If yes to both, may not be restricted work; if no or unknown, treat as restricted-work review | | No lifting, no climbing, no gripping | Is that activity a routine function for this job? | Restricted work if it blocks a weekly function after the day of injury | | "Desk duty" or "office only" | Was the worker transferred off the regular job for part of a later day? | Job transfer / restricted work review | | Stay home | Are calendar days away involved after the day of injury? | Days away column, not only light duty | | Restrictions for the day of injury only | Did limits apply only that calendar day? | OSHA does not require recording restriction limited to the day of injury |

Keep the comparison written. "We thought light duty was fine" is not a 300 log analysis.

Modified duty examples and return-to-work functional restrictions help operations teams convert a clear restriction into a temporary task without inventing work the site cannot supervise.

How Medical Direction Clarifies Vague Restrictions

Medical direction can ask the treating provider the two OSHA questions in operational language: can this employee perform each routine function of the regular job, and can they work the full scheduled shift? That callback is often faster than waiting for a second visit.

Medical direction does not make the OSHA recordability decision. It helps the employer obtain a note that can be compared to job demands. If two providers disagree, OSHA allows the employer to decide which recommendation is more authoritative and record based on that recommendation.

Send the clinic a short job-demands summary with the worker. A restriction written against "construction laborer" is weaker than a restriction written against documented lifts, carries, ladder frequency, and shift length. When readiness is the question, Industrial MD fitness-for-duty evaluations sit beside the restriction review.

Supervisor Script When the Note Says Light Duty

When a supervisor receives a light-duty slip, a short script keeps the file usable:

1. Capture the exact restriction text, provider name, and date.
2. Do not assign tasks that conflict with stated limits while the review is open.
3. Send the note and the job-demands description to the named OSHA and return-to-work owners the same shift.
4. Ask medical direction to clarify routine-function and full-shift questions if the note is vague.
5. Document the restricted-work analysis separately from the workers' compensation claim status.
6. Update the assignment if the provider later releases or tightens limits.

Supervisors should not tell a worker that "light duty means this is not OSHA." That sentence is not in the standard, and it creates a record the employer later has to unwind. Send the note to the named OSHA and modified duty owners the same shift.

Holiday Weekends and Partial-Shift Traps

Labor Day week is a common trap: injury Friday, holiday Monday, worker back Tuesday with a "light duty" note that never answered the weekend. OSHA's day-counting rules look at calendar days the employee could not work because of the injury or illness, and at provider recommendations covering days the worker was not scheduled.

If a provider indicated the worker should not have worked, or should have performed only restricted work, during the holiday, the log analysis should include that period. If no such recommendation exists, do not invent days away. Document what the provider actually said.

This article is informational and does not replace licensed medical care, legal advice, OSHA compliance counsel, or professional review. Employers remain responsible for final OSHA recordability, employment, workers' compensation, and legal decisions.

If your work-status notes keep saying light duty without a 300 log analysis, talk with Industrial MD about OSHA restricted work vs light duty reviews.

FAQ

What is OSHA restricted work vs light duty? Light duty is informal clinic or workplace language. OSHA restricted work is a 1904.7 recordkeeping term that looks at whether the worker can perform routine job functions and the full scheduled shift after the day of injury.

Is every light-duty assignment an OSHA restricted-work case? No. Compare the restriction to that employee's weekly job functions and scheduled shift. A vague light-duty note still needs clarification; if you cannot obtain it, OSHA directs employers to record restricted work.

Do restrictions on the day of injury count? OSHA does not require recording restricted work or job transfer that applies only to the day the injury occurred or the illness began.

How do job transfer and restricted work differ on the 300 log? They share the same log box. A transfer to another job for part of a later day is recorded as job transfer. Both still need a day count.

Who decides whether light duty is restricted work? The employer. Medical direction and clinic notes supply facts. Employers remain responsible for final OSHA recordability determinations.