Is Light Duty OSHA Recordable? How to Decide Without Guessing
Light duty is recordable restricted work only if it keeps the employee from a routine function, one they do at least weekly, or from working the full shift.
The answer up front
Light duty is recordable restricted work only if it keeps the employee from a routine function, one they do at least weekly, or from working the full shift. If the provider's note is vague, ask whether the employee can do all routine functions and work a full shift; if you cannot get an answer, record it as restricted.
Light duty is workplace slang, not an OSHA classification by itself.
The rule in plain English
A case goes on the OSHA 300 Log when three things are true: it is work-related (29 CFR 1904.5), it is a new case (29 CFR 1904.6), and it meets at least one general recording criterion (29 CFR 1904.7). The criteria are death, days away from work, restricted work or job transfer, medical treatment beyond first aid, loss of consciousness, or a significant injury or illness diagnosed by a physician or other licensed health care professional (cancer, a chronic irreversible disease, a fractured or cracked bone, or a punctured eardrum). Special rules add needlesticks, medical removal, hearing loss, and tuberculosis (29 CFR 1904.8 to 1904.11).
Applying it to real cases
Compare the restriction to routine job functions and the full scheduled workday. Recordability answers change as medical facts arrive, so a case decided on day one without notes is hard to defend in January. The fix is to decide in order (work-relatedness, new case, criteria) and to write down the treatment and work-status facts each decision rests on, including medication strength.
As the safety manager you usually own the decision itself, so the most useful habit is writing down the fact each call rests on at the time you make it.
Where teams go wrong
Teams record or exclude cases based on the phrase light duty instead of the actual restriction. Ask the two questions from 1904.7(b)(4)(vii): can the employee do all routine functions, and work the full shift?
Each recordable case adds to the 300A totals and the TRIR; days-away and restricted cases also count toward DART. For establishments with 100 or more employees in Appendix B industries, each case also becomes a row in the ITA case data.
Situations that change the answer
- Vague provider notes may need follow-up before final classification.
- OSHA's first aid list is complete. A treatment that is not on it is medical treatment for recordkeeping, no matter who provides it.
A worked example
A note says “light duty for one week.” The safety manager calls the clinic: can the employee lift the 35 lb totes they handle every day, and work a full 10-hour shift? The clinic says no to the lifting. The case is recorded as restricted work in column I, with the week's restricted days counted from the day after the injury.
A checklist you can reuse
- Ask which routine functions are restricted.
- Ask whether the full shift is allowed.
- Record as restricted if either answer is no, or if no answer comes.
- Update the day counts as the restriction changes.
What to keep in the case file:
- What the provider recommended, in writing if possible, including medication strength
- Work status notes (full duty, restrictions, or days away) with dates
- The work-relatedness basis and any exception considered
- The date you learned of the case and the date it became recordable
Where 300log helps
300log records each case's outcome, day counts, and case type in the columns the OSHA 300 Log uses, shows OSHA's definitions (such as restricted work) while you classify, and recalculates the 300A whenever a case changes.
For a quick answer without an account, use the free recordability checker.
Frequently asked questions
What if the facts change after we log the case?
Update the log. If a first-aid case later needs medical treatment, or a recordable case later results in days away, change the entry (29 CFR 1904.33(b)).
Is a clinic visit automatically recordable?
No. A visit for observation, counseling, or diagnostic tests is not medical treatment. The case is recordable only if a recording criterion is met, such as treatment beyond first aid or a work restriction.
Is prescription medication always recordable?
A recommendation to use prescription medication, or a nonprescription drug at prescription strength, is medical treatment. The exception is medication used solely for diagnosis, such as eye drops to dilate pupils.
Who decides recordability, the doctor or the employer?
The employer. Providers supply the medical facts and recommendations; the employer applies Part 1904 to those facts and records the case.
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.