- Standard Number:
OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.
June 15, 1995
Diane Whittier, Manager
Occupational Safety & Health Programs
Westinghouse Electric Corporation
Westinghouse Building Gateway Center
Pittsburgh, Pennsylvania 15222
Dear Ms. Whittier:
Thank you for your letter dated April 25, requesting an interpretation regarding the proper recording of a case on the OSHA Log and Summary of Occupational Injuries and Illnesses. The concept of restricted work is based on three criteria as follows:
1. The employee was assigned to another job on a temporary basis, or
2. the employee worked at a permanent job less than full time, or
3. the employee worked at his or her permanently assigned job but could not perform all the duties normally connected with it.
Historically, the phrase, "employee's normal job duties" has been interpreted to include any tasks that the employee performs or may be expected to perform throughout the calendar year.
An occupational injury which results in a restriction which keeps an employee from entering a contaminated area (which that employee would have been expected to enter if not for the injury) meets criteria 3 and must be recorded on the OSHA Log as a case involving restricted work activity. Q&A B-7 on page 30 of the Guidelines deals exclusively with exposures. The scenario described in your letter involves an employee who has experienced an occupational injury (small cut on finger).
I hope you find this information useful. If you have any further questions, please contact us at Area Code (202) 219-6463.
Sincerely,
Bob Whitmore
Chief
Division of Recordkeeping Requirements