Calendar Days vs Workdays in OSHA Recordkeeping
OSHA counts calendar days, not workdays: every day the employee could not work or was restricted counts, weekends and holidays included.
The short answer
OSHA counts calendar days, not workdays: every day the employee could not work or was restricted counts, weekends and holidays included. Start the count on the day after the injury, and stop at 180 if you choose.
The calendar-day rule surprises teams with rotating shifts and weekends.
The rule in plain English
OSHA incidence rates scale case counts to 200,000 hours, which is 100 full-time workers at 40 hours a week for 50 weeks. TRIR (also called TCIR) = total recordable cases (300A columns G + H + I + J) × 200,000 ÷ total hours worked. DART = (cases in columns H + I) × 200,000 ÷ total hours worked. The 300A itself asks for the annual average number of employees and the total hours worked by all employees covered by the log (29 CFR 1904.32(b)(2)). For comparison, the BLS private-industry averages for 2024 were a TRIR of 2.3 and a DART rate of 1.4.
OSHA day-counting rules
From 29 CFR 1904.7(b)(3) and (b)(4):
- Start counting the day after the injury or illness began.
- Count calendar days, including weekends, holidays, and other days off the employee could not have worked because of the injury.
- If a provider recommends days away and the employee works anyway, record the recommended days.
- If a provider clears the employee to return and they stay home, stop counting on the date of the clearance.
- An injury on a Friday before a weekend off is a days-away case only if a provider says the employee should not have worked those days.
- A partial shift counts as a restricted day, except on the day of injury.
- You may stop counting at 180 days; entering 180 is enough.
- If the employee leaves for reasons unrelated to the injury, you may stop counting; if they leave because of it, estimate the total.
- A case that runs into the next year stays on the log of the year it occurred, with an estimate updated later.
How it plays out on site
Use calendar days for days-away, restricted-work, and transfer counts, starting after the incident day. The denominator does as much work as the numerator. One wrong hours figure moves every rate, and the same hours also go on the 300A and into the ITA submission. The fix is to document the method once (which payroll report, which exclusions, which estimates) and use the same hours for the 300A, the ITA, and every rate.
HR usually holds the headcount, leave, and restriction paperwork that recordkeeping depends on, so the handoff to safety matters as much as the rule.
The common mistake
Teams pull payroll workdays and undercount cases. Keep a day-count worksheet driven by calendar dates, separate from payroll's absence codes.
Hours worked and average employees appear on the posted 300A and in the ITA submission, so a figure that is wrong for the rate is also wrong on two regulatory documents.
Edge cases
- Plant shutdowns and holidays still need careful handling.
- Hours worked means hours actually worked. Vacation, holiday, and sick leave are paid but not worked.
Worked example
An employee on a four-day, 10-hour schedule is hurt on a Thursday and cleared to return the following Thursday. Payroll shows 3 missed workdays; OSHA counts Friday through Wednesday, 6 calendar days, because the employee could not have worked any of them.
Checklist
- Start with the day after the injury.
- Count every calendar day away or restricted.
- Include days off the employee could not have worked.
- Cap at 180 days if the case runs long.
What to keep in the case file:
- The payroll report used for hours worked, with the date it was pulled
- Adjustments: paid leave removed, supervised temporary workers added
- The pay periods and headcounts behind the annual average employees figure
- The rate calculation with the case counts it used
Where 300log helps
300log totals each establishment's columns as cases are recorded and keeps average employees and hours worked with the 300A, so the rate, the posted summary, and the ITA submission all use the same numbers.
For a quick answer without an account, use the free rate calculator.
Frequently asked questions
What counts toward DART?
Cases with days away from work (column H) plus cases with job transfer or restriction (column I). It counts cases, not days.
Is there an official severity rate?
No. OSHA and BLS publish no official severity rate. Some teams track a day count rate, (days away + days restricted) × 200,000 ÷ hours, from an archived OSHA worksheet, but it has no BLS benchmark.
Does hours worked include salaried staff?
Yes, if they are covered by the log. Use actual hours where you have them and a reasonable, documented estimate for exempt staff.
What is the formula for TRIR?
TRIR = total recordable cases × 200,000 ÷ total hours worked. The case count is the sum of 300A columns G, H, I, and J.
Sources
Primary regulation and agency guidance this article relies on.
- [1]29 CFR 1904.7: General recording criteriaOccupational Safety and Health Administration · osha.gov(opens in a new tab)
- [2]29 CFR 1904.32: Annual summary certification and postingOccupational Safety and Health Administration · osha.gov(opens in a new tab)
- [3]29 CFR 1904.33: Retention and updatingOccupational Safety and Health Administration · osha.gov(opens in a new tab)
Written and reviewed by the 300log Editorial Team. Guidance, not legal advice: confirm edge cases with OSHA or counsel.