OSHA Recordkeeping for Restricted and Transferred Duty Days

A Tuesday-afternoon question from the safety side

A coordinator at a mid-sized distribution operation gets a short email from the safety manager, who is closing out the year's injury log. It reads: "Your spreadsheet says the forklift-strain case was on light duty from the 3rd through the 29th. My log shows fewer restricted days. Which one is right?" The coordinator opens the return-to-work file and finds the physician's restriction note, an offer letter, and a calendar of what looks like continuous modified work. What she cannot find is a record of the three days the worker stayed home when the assigned task turned out to exceed the lifting limit, or the day the restriction was renewed late.

Two documents describe the same injury, and they have drifted. One belongs to the return-to-work program. The other is a federal recordkeeping form that the employer certifies. When they disagree, someone has to explain the gap to an auditor, an insurer, or an inspector, and the explanation usually starts with "we think."

This article walks through how osha recordkeeping restricted duty days actually work: what the log asks, why a transitional assignment changes a case's classification, where the counting rules live, and how to keep your RTW file and your injury log telling the same story. It is general information, not legal advice.

How OSHA recordkeeping restricted duty days differ from your RTW file

The OSHA 300 log and the RTW case file answer different questions. The log is a classification record: was this a recordable case, and what was the most serious outcome? The RTW file is an operational record: what did the physician restrict, what work was offered, what did the worker accept, and on which dates did the worker actually perform it.

The RTW file works in dates and tasks; the log works in categories and day counts. A day count is only as good as the dated record behind it, so establish restricted days in the RTW file first and populate the log from it.

The governing rules sit in 29 CFR Part 1904, which OSHA publishes, with the current text available on the eCFR site. The section on determining whether a case involves days away, restricted work, or job transfer (generally cited as 29 CFR 1904.7) is the one to keep open when you reconcile. We describe how it is structured here and send you to the text for the specifics, because the counting details are exactly where a paraphrase can mislead.

What the log asks: the job transfer or restriction column

For osha recordkeeping restricted duty days, the OSHA 300 log classifies each recordable case by its most serious outcome. The log has separate places to record cases involving days away from work and cases involving job transfer or restriction, along with the number of days in each category. A case where the worker never missed a shift but was placed on modified work is not "nothing happened." It is a case in the job transfer or restriction category.

Two practical points follow.

First, the classification is driven by what happened to the worker's work, not by what the paperwork was called. A task labeled "light duty," "transitional assignment," "temporary reassignment," or "modified duty" in your RTW file may all fall under the same recordkeeping idea. What matters is whether the employer kept the worker from performing routine job functions or from working a full workday because of the injury.

Second, a case can change categories. A worker who starts on restricted duty and later stays home, or the reverse, may move a case between columns. Your file should show the sequence, not just the final status.

The log records classification and day counts. The dated, physician-supported record of what the worker was actually restricted from, and what the worker actually did, lives in the RTW file. Treat the RTW file as the source and the log as the summary.

Why a transitional assignment becomes a DART case

DART stands for days away, restricted, or transferred. It is the grouping OSHA and BLS use for cases that involved any of those outcomes. A successful transitional duty assignment, the very thing a good RTW program is trying to create, puts a case into the DART group instead of the days-away group.

That is a classification consequence, not a penalty on the program. It does mean the log and the RTW program are linked: every restriction note that leads to modified work is also a recordkeeping event.

For scale, BLS reports that over 2023–2024, overexertion, repetitive-motion, and bodily-condition DART cases totaled 946,290, the highest of any cause, followed by contact incidents at 860,050 (BLS, January 2026 release). These are national totals across private industry, and they say nothing about any single employer's rate. For comparison against your own numbers, use the approach in our guide to BLS and OSHA benchmarking for RTW programs, which covers how to read published rates against your own log.

Counting days: what to confirm in 29 CFR 1904

Counting is where most errors occur, and it is where we deliberately state no numbers. The regulation sets rules on how days are counted, when counting starts, whether weekends and scheduled days off are included, and whether there is an upper limit on how many days a single case can accumulate. Read those details from the regulation and OSHA's published interpretations, not from a blog post.

What we can say is where the counting questions tend to arise in practice:

• The start of the count. Which day is the first day counted, and does the day of injury count? Confirm in the regulation.
• Days the worker was not scheduled. Whether days off that would have been non-work days anyway are counted is a rule question, not a judgment call.
• A restriction that is renewed or extended. When a physician extends restrictions, the record needs the new dates and the source note. A gap between notes is a counting problem as well as a documentation problem.
• A cap on counted days. The regulation addresses whether counting continues indefinitely or stops at a limit. Confirm the current limit and how it interacts with open cases at year end.

When you are unsure how a specific case counts, ask OSHA, your state plan if you are in a state-plan jurisdiction, or qualified counsel. The tracking approach below is designed to make that conversation fast because the dates are already clean.

Keeping the RTW file and the log in sync

The drift in the opening scenario had three ordinary causes: the RTW file recorded planned dates instead of worked dates, the restriction renewal was entered late, and nobody wrote down the days the assignment failed.

The fix is a record built on actual events:

1. Record approved dates only. Enter the physician's restriction window as it is written, with the note attached. Do not let a planned or hoped-for end date stand in for an approved one. Our article on approved-dates-only tracking explains why this matters for both reimbursement files and injury logs.
2. Log each day's reality. For each date in the window, record whether modified work was performed, whether the worker stayed home, and why. A day that was offered but not worked is still information.
3. Flag expiry in advance. A restriction that lapses without a renewal creates an undocumented stretch. Use a recurring check for approaching expirations, as described in restriction expiry and maximum-duration flags.
4. Reconcile at a fixed cadence. Compare the RTW file to the log on a schedule, not only at year end. A monthly pass catches a missing note while the physician's office still remembers the visit.
5. Keep an audit trail. Each change to dates or categories should show who changed it and when. When a carrier or regulator asks why a number moved, the history is the answer; see our guide to the RTW audit trail for carrier audits.

Medical privacy applies throughout. Under the ADA, employee medical information, however obtained, must be kept confidential, stored separately from personnel files, and accessible only to authorized personnel (Job Accommodation Network). The injury log is not a place to paste diagnosis detail, and the RTW file is not a document to leave in a shared drive.

When several cases are open at once

One restricted worker is a calendar entry. Several, each with a different physician and restriction window, is a data-management problem. If you are in that position, managing concurrent RTW cases covers the structure that keeps each case's dates separate and visible.

For a lightweight way to apply the routine above, the Transitional Duty Case Tracking Workbook is a workbook for tracking up to 20 concurrent return-to-work cases in one place. It organizes the case record; it does not make recordkeeping determinations, and it does not replace the regulation, your physician's restrictions, or your counsel.

TransitionalDuty is still pre-launch. The platform we are building is meant to keep restriction dates, offers, and day-by-day outcomes in one structured record so that this reconciliation starts from clean data. It is an operational documentation tool: the physician decides restrictions, the employer makes its recordkeeping determinations, and OSHA interprets its own rules.

Next step

Pick one open restricted-duty case and compare its RTW dates to your log. If they disagree by even a day, you have found the weak point in your process. Accurate osha recordkeeping restricted duty days start with the dated record. Subscribe to the newsletter below for more procedural guides on keeping return-to-work records audit-ready, and use the workbook above if you want a ready structure for the dated record.