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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

October 28, 1993

Ms. Donna Lite
Safety Training Administrator
Hallmark Cards, Inc.
2501 McGee, Mail Drop 314
Kansas City, Missouri 64141

Dear Ms. Lite:

Thank you for your letter dated September 20, requesting an interpretation for an OSHA injury and illness recordkeeping issue. Your letter was forwarded to my office by Ted Bach.

For OSHA injury and illness recordkeeping purposes, 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.

Furthermore, an employee's normal job duties has been interpreted to mean anything the employee would be expected to do throughout the calendar year.

The situation described in your letter (i.e. "the employee is performing all functions of his or her normal job, but at a slower pace") does not fall into the above criteria and should not be considered restricted work activity.

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


Bob Whitmore
Division of Recordkeeping Requirements