From the Hotline: OSHA 300 Log and Counting Days
Question: Under OSHA 300 log reporting regulations, when an employee has 365 days of work restrictions, is this capped at the 180-day count, similar to absences?
Answer: Yes, under OSHA requirements (29 C.F.R. § 1904.7(b)(3)((vii)), absences and/or days of restricted work (Column K and L on the OSHA 300 log) need to be counted to a maximum of 180 days individually or combined. For cases that involve one or more days away from work, place a check mark in column H on the OSHA Form 300 and enter the number of calendar days the employee was under work modification (light duty) or away from work under the respective column. Then note in column M whether the case involves an injury or an illness.
When counting days, be sure to count the days the employee would not have been able to work regardless of whether he or she was scheduled to work, including weekends and holidays. Do not count the day of the injury. If the day count reaches 180 calendar days in Column K or L, individually or combined, you may stop counting subsequent days.