Common OSHA 29 CFR 1904.7 Recording Mistakes: Days Away and Restricted Work
For trade subcontractors and general contractors, logging jobsite incidents correctly on the OSHA 300 Log is a critical compliance duty. Under 29 CFR 1904.7, an injury or illness meets the general recording criteria if it results in death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, loss of consciousness, or a significant diagnosed injury or illness. When managing trade crews, field managers often make compliance errors by misinterpreting calendar days, job restrictions, or physician recommendations. Here are the most common recording pitfalls contractors face under these rules.
Mistake 1: Counting Only Scheduled Workdays Instead of Calendar Days
A frequent error contractors make when logging lost work time is counting only scheduled work shifts. Under federal rules, you must record the actual number of calendar days an employee cannot work because of the injury or illness. This tally must include:
- Scheduled workdays missed by the crew member
- Weekend days
- Holidays and planned plant or site shutdowns
- Pre-planned vacation days and regular days off
If an employee suffers a work-related injury on a Friday and is not scheduled over the weekend, the case is recorded with days away only if a physician or other licensed health care professional determines that the worker should not have worked during that weekend. Otherwise, weekend days and holidays must always be tallied if the worker was medically unable to perform work during that time.
Mistake 2: Counting the Day of the Incident or Double-Counting Year-End Cases
When an injury occurs on site, employers often mistakenly count the day of the incident toward days away from work. The rule explicitly states that you do not count the day the injury occurred or the illness began; the count begins on the day after the incident. Similarly, partial shifts worked on the day of the incident do not count as restricted work.
Another common mistake occurs when an injury happens in one year but lost days continue into the next calendar year. Contractors should never record the injury on logs for both years. The case must be recorded only once, on the log for the year in which the event happened. When preparing the annual summary, the employer estimates the expected days away and then updates the initial log entry once the final count is established.
Mistake 3: Failing to Cap Extended Day Counts at 180 Days
When a severe injury results in lengthy absences, contractors sometimes continue tracking days indefinitely. Under OSHA 29 CFR 1904.7 general recording criteria, employers are allowed to cap the total count at 180 calendar days. You do not need to track lost time beyond 180 calendar days of days away, job transfer, or work restriction. Entering 180 in the designated log column meets federal requirements.
Additionally, if an employee leaves the company or retires for a reason completely unrelated to the incident, such as standard retirement or a site shutdown, you can stop the day count immediately. However, if the worker leaves because of the injury or illness itself, you must estimate the full expected days away or restriction up to the cap.
Mistake 4: Misapplying the Routine Functions Test for Restricted Work
Contractors often struggle to classify restricted work correctly. Restricted duty occurs when an employer prevents an employee from performing routine functions, or when a healthcare professional recommends those limits. OSHA defines routine functions specifically as work activities an employee regularly performs at least once per week.
An assignment is not considered restricted work simply because an injured worker experiences lower productivity. If a framer or installer performs every routine function of the trade and completes the entire assigned work shift, lower output alone does not trigger a restricted work record. Conversely, if an employee works only a partial shift due to an injury after the date of the incident, that day must be recorded as a day of restriction or job transfer.
Mistake 5: Misinterpreting Vague Physician Notes and Non-Compliant Workers
Field supervisors often receive unclear notes recommending that an employee take it easy or perform light duty. If a note is vague, the contractor may ask the medical professional whether the employee is capable of executing all routine job functions and completing the regular shift. If the healthcare professional confirms the worker can do both, the case is not restricted. If the provider answers no, or if the contractor is unable to obtain clarification, the case must be entered as restricted work.
Furthermore, if a medical professional recommends restricted duty or days away, but the worker chooses to perform routine duties anyway, the contractor is still obligated to record the case on the log based on the medical recommendation. When multiple medical opinions conflict, the employer may determine which recommendation is the most authoritative and log the incident accordingly.
Mistake 6: Overlooking Permanent Job Modifications and Fatality Deadlines
When an employer permanently transfers an injured worker to a new role that eliminates the restricted tasks, the daily count of job transfer or restriction can stop once that modification becomes permanent. However, the employer must count at least one day of restriction or transfer before closing out the count. Proper coordination with your broader contractor recordkeeping procedures ensures these ongoing modifications remain fully documented.
Finally, fatal workplace incidents involve strict dual obligations. A work-related death requires a check mark on the log in the fatality column, and employers must also report the fatality directly to OSHA within eight (8) hours under § 1904.39. Keeping your team aligned with standard OSHA 300 Log recordkeeping requirements prevents severe penalties during project audits.
Sources
Electronic Code of Federal Regulations: 29 CFR 1904.7 General Recording Criteria
Published November 9, 2026. No affiliate links on this page. Facts come from the sources linked above; check them for updates.