OSHA interpretation letter clarifies when work restrictions must be recorded (US)

In an interpretation letter dated November 21, 2016, the Occupational Safety and Health Administration (OSHA) discussed a specific issue regarding whether a work-related laceration must be recorded as a restricted work case. However, restrictions on work that are not intended to protect the employee, but rather the quality or purity of a product, are not considered to be recordable as a restricted work case.

Work-related injuries and illnesses that result in restricted work when an employer prevents an employee from performing at least one routine function of his or her job or from working a full workday, or a physician or other licensed health care professional recommends that the employee not perform at least one routine function or not work the full workday. Restricted work cases that involve restrictions required to prevent the exacerbation of, or recuperation from, the work-related injury or illness must be recorded as a restricted work case under OSHA’s recordkeeping regulations.

In the scenario described by the inquiring entity, an employee suffered a work-related laceration, but was physically capable of performing all routine job functions. The employee was prevented from performing normal job duties in close proximity to the biological production area to prevent potential contamination of the output of the processes in the production area. Because the restriction was implemented to ensure quality control and prevent contamination of the product and not as a means to prevent the exacerbation of, or recuperation from the work-related injury or illness, the case is not considered to involve restricted work activity. Thus, the incident is not recordable as a work restricted case.

 

Sources:

OSHA, interpretation letter, “Determining if a work-related injury or illness resulted in restricted work activity/Job Transfer,” November 21, 2016