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July 22, 2011
What Counts As Restricted Duty?

What is restricted duty? If an employee is prohibited unable to work full shift, then that employee is considered to be restricted. This prohibition may come from a medical professional or from their supervisor. Additionally, an employee is considered to be restricted if the employee is prohibited or unable to perform all routine functions of the role. Routine functions are defined as work activities regularly performed at least once per week.

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In a BLR webinar entitled "OSHA Recordkeeping: 5 Sure-Fire Ways To Ensure Compliance and Avoid Penalties," Bill Taylor, CSP, offered information on some of the scenarios you may face when you're determining whether employees are on restricted duty.

  • When an employee is only able to work partial workdays, yes, this is considered as restricted.
  • When an employee can work, but must do so at a slower pace (production slowdowns), this is not considered restricted as long as the routine functions are still completed.
  • Vague restrictions, however, can be questionable (i.e. “work as tolerated” or “work with caution”). In these cases, the employer should go back to the medical professional to find out exactly what the employee can and cannot do to determine whether the employee is restricted.

Taylor also outlined how to record restricted or days away from work:

  • Record calendar days
  • Do not count day of injury/illness
  • If employee works contrary to doctor’s orders, still count days
  • If doctor returns the employee to work but the employee stays home, stop the count

In order to override restricted duty or lost time, the more authoritative licensed health care professional must override it before the start of the employee’s next shift. This distinction may matter to employers who are required to record lost time as part of the OSHA recordkeeping standard because restricted days and lost time must be counted.

Bill Taylor, CSP, is the vice president at CTJ Safety Associates, (www.ctjsafety.com) and has over 32 years of safety experience. He is a former director of safety and health programs in both industry and municipal government, with diverse safety and health managerial experience, including a concentration in ergonomics. For over 18 years with the consulting firm ELB & Associates and its successor companies, Taylor assisted a variety of clients in manufacturing, services, construction, and the public sector by conducting simulated OSHA inspections, safety and OSHA compliance training, and developing policies and safety management systems. His specialties include safety management systems, OSHA standards training, and audits. Taylor has authored and published award-winning articles on ergonomics and training and is the author of "Effective Environmental, Health and Safety Management Using the Team Approach" (2005, John Wiley & Sons).

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