Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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

August 3, 1993

Mr. E. R. Dhayer
Exxon Company, U.S.A.
Post Office Box 4692
Houston, Texas 77210-4692

Dear Mr. Dhayer:

Thank you for your letter dated July 2, requesting an interpretation regarding recording restricted work activity on the OSHA 200. Your letter was forwarded to my office from the Houston Area Office. My Division of Recordkeeping Requirements is responsible for the administration of the OSHA injury and illness recordkeeping system nationwide.

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.

An employee's normal job duties has been interpreted to mean anything the employee would be expected to do throughout the calendar year. In the scenario described in your letter, the chauffeur is expected to carry bags weighing more then 20 pounds (and did so using his right arm). The physician restricted the employee from lifting anything more than 20 pounds with his right arm. The employee, therefore could not perform all the duties normally connected with his job, and days of restricted work activity should be counted.

I hope you find this information useful. If you have further questions please contact my staff at Area Code (202) 219-6463.


Stephen A. Newell Director
Office of Statistics