OSHA 180-Day Cap: How to Count Long Days Away and Restricted Cases
You may stop counting at 180 calendar days: if a case's days away, restriction, or transfer total more than 180, entering 180 is enough.

What you are aiming for
You may stop counting at 180 calendar days: if a case's days away, restriction, or transfer total more than 180, entering 180 is enough. Until the case ends, enter an estimate on the log and update it when the count is known or reaches the cap.
Long injury cases can overwhelm logs when the team does not know when to stop counting.
What you need before you start
Gather these first, and keep them with the record afterward:
- 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
The rule behind the steps
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.
Step by step
- Track calendar days.
- Update the estimate as the case develops.
- Cap at 180 days.
- Keep the basis with the case.
Tip: Use OSHA day-counting rules and cap days away, restricted work, or transfer at 180 calendar days.
Where this usually goes wrong
Teams stop counting too early because payroll codes end before medical restrictions do.
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.
Analysts are measured on numbers leadership trusts, so document every input and assumption behind a rate or a total.
Special situations
- A case may need estimates and later updates before the final count is known.
- A restriction that applies only to the day of injury does not make the case recordable as restricted work.
Worked example
A worker is off for 150 days after surgery, then on restricted duty for 60 more. The combined total passes 180, so the log can show 150 days away and 30 restricted days, reaching the cap, rather than tracking the full 210.
How it affects the rest of your records
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.
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
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.
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.
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.