Counting OSHA Days When an Employee Leaves the Company
If an employee leaves for reasons unrelated to the injury, such as retirement or another job, you may stop counting days on that date.
Quick answer
If an employee leaves for reasons unrelated to the injury, such as retirement or another job, you may stop counting days on that date. If they leave because of the injury, estimate the total days away or restricted and enter that on the log.
Departures can interrupt the facts needed to close a case.
The rule in plain English
DART cases are the ones checked in column H (days away from work) or column I (job transfer or restriction) of the 300 Log. Each case is checked once, in the most serious column that applies (death, then days away, then restriction or transfer, then other), but both day counts are entered: days away in column K and restricted or transferred days in column L. Count calendar days, starting the day after the injury or illness began (29 CFR 1904.7(b)(3)). Restricted work means the employee cannot perform one or more routine functions (activities done at least once a week) or cannot work the full workday, whether you impose it or a provider recommends it (1904.7(b)(4)). You may stop counting at 180 days.
What this looks like in practice
Use OSHA guidance to estimate or cap days when the employee leaves for reasons unrelated to the injury. DART is where cases and days get confused: the rate counts cases, while the log also carries day totals that leadership often reads as the same thing. The fix is to track each case's status day by day (away, restricted, transferred, or full duty) and derive both the column and the day counts from that record.
HR leaders sit where recordkeeping meets policy: how employees report, how cases are discussed, and how discipline and incentives are designed.
The mistake to avoid
Teams simply stop counting on the termination date.
Column H and I cases drive the DART rate and the 300A totals; the day counts in K and L go on the 300A too, and into the ITA file for covered establishments.
Edge cases worth checking
- Leaving because of the injury may require a different analysis.
- Weekends, holidays, and scheduled days off count if the employee could not have worked them because of the injury.
Example
An employee on restricted duty for a hand injury takes a job with another company after 12 days. The count stops at 12. Another employee who resigns because the injury leaves them unable to do the work has an estimated total of 90 days, based on the surgeon's expected recovery time.
Step by step
- Record why the employee left.
- Stop counting or estimate.
- Document the basis.
- Update the log.
What to keep in the case file:
- Provider notes with restriction dates and what was restricted
- The employee's routine functions, from a job analysis or supervisor
- Day-by-day status: away, restricted, transferred, or full duty
- Estimates for cases still open at year end and when they were updated
Where 300log helps
300log keeps days away and restricted days on each case, carries them into the 300A totals, and lets you update the counts as a case develops, so the posted summary and the DART rate come from the same entries.
For a quick answer without an account, use the free rate calculator.
Frequently asked questions
Do you count the day of the injury?
No. Start counting days away or restricted days on the day after the injury or illness began.
Are days counted as workdays or calendar days?
Calendar days, including weekends and holidays the employee could not have worked because of the injury.
What is the maximum number of days to record?
You may cap days away, restricted work, or job transfer at 180 calendar days.
Is light duty always restricted work?
Only if the employee cannot perform one or more routine functions or cannot work a full shift. A light-duty label does not decide it by itself.
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 1904.33: Retention and updatingOccupational Safety and Health Administration · osha.gov(opens in a new tab)
- [3]OSHA detailed guidance for the injury and illness recordkeeping ruleOccupational 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.