Routine Job Functions and Restricted Work: OSHA Recordkeeping Examples
Routine functions are the work activities an employee regularly performs at least once per week (29 CFR 1904.7(b)(4)(ii)).
The short answer
Routine functions are the work activities an employee regularly performs at least once per week (29 CFR 1904.7(b)(4)(ii)). A restriction that blocks any of them, or cuts the full workday, makes the case recordable as restricted work.
Restricted work decisions often fail because the team has no current job function baseline.
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).
How it plays out on site
Routine functions are work activities the employee regularly performs at least once per week. 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.
Analysts see the data after it is entered, so reconciling the log against source documents is where you add the most value.
The common mistake
Teams compare restrictions to a generic job title instead of actual duties.
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.
Edge cases
- Temporary changes in assignments can make the routine function analysis fact-sensitive.
- A recommendation counts even if the employee declines it: prescription medication that is prescribed but never filled still makes the case recordable.
Worked example
A maintenance tech is restricted from climbing ladders for two weeks. Their supervisor confirms that ladder work happens on most shifts, so it is a routine function and the case is restricted work. A restriction from annual boiler inspection, done once a year, would not be.
Checklist
- List the tasks the employee does at least weekly.
- Compare each restriction with that list.
- Record restricted work if any routine task is blocked.
- Keep the job analysis or supervisor's list with the case.
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
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.
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)).
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]OSHA detailed guidance for the injury and illness recordkeeping ruleOccupational 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.