Light Duty

Question:
An employee claims wrist pain due to assembly work at an automotive plant. She is seen at an occ health clinic where a doctor prescribes over-the-counter naproxen and returns the employee to work with “light duty” until a follow up evaluation two weeks later. Back at work, the employee is out of her normal job rotation on an assembly line and is now auditing the company’s SDS, which is a completely foreign task for her. Is it recordable?

Answer:
YES. The term “light duty” is misunderstood by some. Instead of prescribing specific work restrictions, some doctors will prescribe light duty. The employee expressed pain due to her work on the assembly line, so that she won’t be willing to go back because of the pain and because of the light duty prescription from the doctor. What we do know is, the employee did not return to her normal, routine work functions and she was placed in a job that she does not normally do, in what seems to be accommodation efforts. The accommodation kept the employee and the company from losing time. This meets the restricted work criteria for OSHA.

1904.7(b)(1)

How do I decide if a case meets one or more of the general recording criteria? A work-related injury or illness must be recorded if it results in one or more of the following:

​1904.7(b)(1)(iii)

Restricted work or transfer to another job. See § 1904.7(b)(4).

1904.7(b)(4)

How do I record a work-related injury or illness that results in restricted work or job transfer? When an injury or illness involves restricted work or job transfer but does not involve death or days away from work, you must record the injury or illness on the OSHA 300 Log by placing a check mark in the space for job transfer or restriction and an entry of the number of restricted or transferred days in the restricted workdays column.

​1904.7(b)(4)(i)

How do I decide if the injury or illness resulted in restricted work? Restricted work occurs when, as the result of a work-related injury or illness:

​1904.7(b)(4)(i)(A)

You keep the employee from performing one or more of the routine functions of his or her job, or from working the full workday that he or she would otherwise have been scheduled to work; or

​1904.7(b)(4)(i)(B)

A physician or other licensed health care professional recommends that the employee not perform one or more of the routine functions of his or her job, or not work the full workday that he or she would otherwise have been scheduled to work.

​1904.7(b)(4)(ii)

What is meant by "routine functions"? For recordkeeping purposes, an employee's routine functions are those work activities the employee regularly performs at least once per week.