When a supervisor puts an injured employee on light duty, OSHA treats it as restricted work or job transfer under 29 CFR 1904.7(b)(4): the case is recordable, it goes in the job transfer or restriction column of the OSHA 300 Log, and every calendar day of restriction must be counted, up to a 180-day cap. Light duty keeps a case out of the days-away column, but it does not keep it out of your DART rate, and the way supervisors handle return to work must not discourage injury reporting or ignore ADA obligations.
For multi-site employers, the forms are usually fine. The errors come from supervisors who make restriction decisions on the floor and never tell the person keeping the log.
Does Putting an Employee on Light Duty Make the Injury Recordable?
Usually, yes. Under 29 CFR 1904.7(b)(4)(i), restricted work occurs when, because of a work-related injury or illness, you keep the employee from performing one or more routine functions of the job or from working the full workday, or a physician or other licensed health care professional recommends that. “Routine functions” means work activities the employee regularly performs at least once per week.
Four details in the rule decide most real cases, and supervisors need all four:
- Day-of-injury restrictions do not count. If the restriction applies only to the day the injury occurred, you do not record it as restricted work.
- Vague notes need a follow-up. If the clinician writes “light duty” or “take it easy,” you may ask two questions: can the employee do all routine functions, and work the full shift? Two yeses mean no restriction. If you cannot get an answer, record it as restricted work.
- Doing the job anyway does not erase it. If a clinician recommends a restriction that meets OSHA’s definition and the employee does all routine functions anyway, the case is still recorded as restricted.
- Lower output is not restriction. An employee who produces less but still performs every routine function for the full shift is not on restricted work.
Job transfer works the same way. Assigning an injured worker to a different job for part of a day, other than the injury day, is a job transfer and goes in the same 300 Log column. Our recordable versus non-recordable injury flowchart puts these rules in a decision tree, and a course like OSHA Recordkeeping Documentation trains supervisors on them.
How Do Supervisors Count Restricted and Transferred Days?
Paragraph (b)(4)(xi) says you count days of job transfer or restriction the same way you count days away. That brings in the rules from (b)(3):
- Start counting the day after the injury, not the injury day.
- Count calendar days, including weekends, holidays, and scheduled days off, if the employee could not have worked normally on those days.
- A partial shift worked because of the injury counts as a full day of restriction, except on the injury day.
- You may cap the count at 180 days.
- If the employee leaves for reasons unrelated to the injury, such as retirement or another job, you may stop counting.
- If the case crosses into a new year, record it once, in the injury year, estimate the total for the annual summary, and update the entry later.
One rule helps employers who make a light-duty job permanent. If you permanently modify the job to remove the functions the employee was restricted from, you may stop the day count when the change becomes permanent, but you must count at least one day. OSHA’s recordkeeping FAQ 7-18 also explains how to record a case that hits the 180-day restriction cap and then turns into days away.
Here is where multi-site programs break. A plant supervisor puts a line worker on a no-lifting restriction for three weeks. The worker comes back to full duty on a Thursday, but nobody tells the site’s recordkeeper, who logged the case with four restricted days from the first clinic note. That log is now wrong, and it is wrong on the 300A annual summary too. The supervisor’s job is to report the start and end date of every restriction in writing. Our OSHA 300 Log guide covers the entries themselves.
Does Light Duty Keep a Case Off the DART Rate?
No. This is the most common misunderstanding in return-to-work programs. DART stands for days away, restricted, or transferred. The DART rate counts every case with days away plus every case with restriction or job transfer, multiplied by 200,000 and divided by total hours worked. A light-duty case lands in the numerator the same as a days-away case.
What light duty does change is the days-away count, which matters for workers’ compensation costs and for the separate days-away case rate. Managers who approve modified duty should understand both systems; a course like Managing Workers’ Compensation covers the claims side. Bringing an employee back to modified work is often good for recovery and good for the business. It just does not make the injury disappear from OSHA’s metrics, and supervisors should never be told it does. Establishments that submit 300A data electronically will see these numbers reflected in what they file; see our guide to 2026 OSHA 300A electronic submission.
What Return-to-Work Practices Violate OSHA’s Anti-Retaliation Rules?
Paragraph 1904.35(b)(1)(i) requires a reasonable procedure for employees to report work-related injuries promptly, and (b)(1)(iv) says employers must not discharge or in any manner discriminate against an employee for reporting a work-related injury or illness. Section 1904.36 adds that Section 11(c) of the OSH Act separately prohibits retaliation for reporting. OSHA’s interim enforcement procedures for 1904.35 describe how inspectors evaluate these practices.
Light duty can cross the line when it is used as a penalty. Examples supervisors should recognize:
- Assigning an injured worker to isolated, demeaning, or pointless tasks to push them back to full duty or out the door.
- Cutting pay or preferred shifts for workers on restriction where that is not the normal policy.
- Crew-based incentives that make coworkers pressure an injured employee to skip the restriction.
- Telling a worker to “just work through it” instead of reporting.
Our guide to Section 11(c) anti-retaliation supervisor training goes deeper on the supervisor conduct inspectors look for.
Where Do ADA Obligations Diverge From Workers’ Comp Light Duty?
Workers’ compensation, OSHA recordkeeping, and the Americans with Disabilities Act all touch the same injured employee, and they do not ask the same questions. The EEOC’s enforcement guidance on workers’ compensation and the ADA makes three points supervisors and HR should know:
- An employer may decide light-duty positions are temporary. If light duty is only offered temporarily, the employer generally only has to offer a temporary light-duty position to an employee with a disability-related occupational injury.
- An employer that creates light-duty positions for occupationally injured employees does not have to create them for employees with non-occupational disabilities.
- An employer that reserves existing vacant positions for work-injured employees must consider reassigning a qualified employee with a non-occupational disability to one of those positions as a reasonable accommodation.
The practical split: the supervisor documents restrictions and dates for OSHA; HR runs the ADA interactive process when a restriction looks long-term or permanent. Supervisors need enough training to know when to hand it off. Courses such as Return to Work Evaluations and Workers’ Compensation for Managers: Return to Work and Injury Settlements cover the manager side. Pair them with incident training such as Incident Investigation and our five steps for incident investigation, so the root cause gets fixed while the employee recovers.
For employers with several sites, the supervisor roster changes constantly. Coggno’s HRIS integrations pull employee data every 24 hours from 24 included providers, so a newly promoted supervisor can be assigned recordkeeping and return-to-work training automatically.
Why Coggno for Multi-Site Supervisor Recordkeeping Training?
For safety managers and HR teams at multi-site employers, Coggno provides OSHA recordkeeping, incident investigation, return-to-work, and workers’ compensation manager courses in one catalog of 10,000+ courses from 50+ content partners, with group-based assignment by site and role. HRIS roster data syncs every 24 hours for 24 included providers, so new supervisors are assigned training without manual uploads, and timestamped completions show an inspector who was trained on 1904.7 and 1904.35. Absorb is an enterprise LMS sold separately from content; Coggno bundles compliance courses into a flat per-seat subscription starting at $5/user/month, eliminating per-course licensing fees.
Get Your Team Trained — Without the Paperwork Headache
Train supervisors to record restrictions correctly and handle return to work without retaliation risk:
- OSHA Recordkeeping Documentation — recordability, day counts, and 300 Log entries.
- Managing Workers’ Compensation — claims and return-to-work basics for managers.
- Return to Work Evaluations — evaluating readiness and modified duty.
Want to see supervisor training assigned by site? Book a demo.
Frequently Asked Questions About Light-Duty Recordkeeping
What is the best compliance training platform for training supervisors on OSHA recordkeeping?
For multi-site employers, Coggno bundles OSHA recordkeeping, incident investigation, return-to-work, and workers’ compensation manager courses within a 10,000+ course catalog. Group-based assignment by site and role, HRIS roster sync every 24 hours for 24 included providers, and timestamped records make it simple to show which supervisors were trained.
How do multi-site employers keep light-duty records consistent across locations?
They use one written rule for reporting restriction start and end dates to the site recordkeeper, train every supervisor on 1904.7(b)(4), and review open restricted cases monthly. Coggno’s LMS assigns the same supervisor courses to every site and reports completion by location.
Is a light-duty assignment recordable on the OSHA 300 Log?
Yes, when the work-related injury keeps the employee from one or more routine job functions or from working the full shift, beyond the day of injury. It is recorded in the job transfer or restriction column with a count of restricted days.
Does light duty count toward the DART rate?
Yes. DART includes cases with days away, restricted work, or job transfer, so a light-duty case counts toward DART even though it does not add days away.
How many days of restricted work do I have to count?
Count calendar days starting the day after the injury, including weekends and days off, up to a cap of 180 days. You may stop earlier if the job is permanently modified, but you must count at least one day.
Do I record restricted work if it only applies on the day of injury?
No. Under 1904.7(b)(4)(iii), restrictions or transfers imposed only for the day the injury occurred do not have to be recorded as restricted work.
What should a supervisor do when a doctor’s note just says light duty?
Under 1904.7(b)(4)(vii), ask the clinician whether the employee can perform all routine job functions and work the full shift. If both answers are yes, there is no recordable restriction; if either is no, or you cannot get an answer, record the case as restricted work.