OSHA Recordkeeping for Warehouses: DART, Days Away, and ITA Risks

Warehousing (NAICS 4931) is on both ITA appendices: 20+ employees means a 300A submission, and 100+ adds 300 and 301 case data. Seasonal and temporary employees count toward those thresholds, and restricted work is where most warehouse logs go wrong.

Warehouses often combine restricted-work questions, multi-shift schedules, and designated-industry filing exposure.

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.

Track injuries by establishment, and classify days-away, restricted-work, and transfer cases consistently. 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.

Whatever you use should make these easy to keep and retrieve:

• 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

1. Map shifts and establishments.
2. Track restrictions and day counts.
3. Check filing coverage.
4. Reconcile before year end.

Warehouse safety managers deal with volume (many small cases, shift changes, seasonal staff), so consistency beats cleverness.

Keep these in mind when you compare approaches:

• Teams count only scheduled workdays or ignore temporary light-duty changes.
• Seasonal peaks can affect hours worked, employee counts, and ITA thresholds.
• A restriction that applies only to the day of injury does not make the case recordable as restricted work.

For a single site with a few cases a year, OSHA's fillable PDFs and a disciplined folder can be enough. The case for software grows with the number of establishments, the number of people who touch a case, and whether you submit to the ITA, because those are the points where versions drift and deadlines stack up.

A 3PL warehouse has 85 permanent employees and adds 40 seasonal hires in November. At its peak of 125 it crosses 100, so it submits case data as well as the 300A. Its monthly review focuses on restrictions: a “no lifting over 25 lb” note for a picker who lifts 40 lb cartons daily is restricted work, even though the picker stayed on the floor.

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.

• Days Away, Restricted Work, and Transfer Cases: How DART Classifications Work
• Ergonomic Injuries and Restricted Work on the OSHA 300 Log
• Counting Days Away From Work on the OSHA 300 Log
• Where to Post the OSHA 300A Summary