Counting Days Away From Work and Restricted Work

Once a case is recordable for days away from work or for restricted work or job transfer, the log asks for one more number: how many calendar days. Paragraph (b)(3) of 29 CFR 1904.7 sets the rule for counting them, and paragraph (b)(4)(xi) carries the same rule over to restricted work and job transfer.

Counting starts the day after

The day the injury happened or the illness began is never itself one of the counted days. Paragraph (b)(3)(i) asks the question directly and answers it the same way: counting begins the next calendar day, not the day of the event itself. An injury on a Monday starts its day count on Tuesday, whatever time the injury happened on Monday.

Days off still count if the employee couldn't have worked anyway

The count isn't limited to days the employee was scheduled to work. Paragraph (b)(3)(iv) is explicit: "You must count the number of calendar days the employee was unable to work as a result of the injury or illness, regardless of whether or not the employee was scheduled to work on those day(s)." It goes on: "Weekend days, holidays, vacation days or other days off are included in the total number of days recorded if the employee would not have been able to work on those days because of a work-related injury or illness." A three-day weekend in the middle of a recovery adds three days to the total, the same as any weekday would.

The 180-day cap

A long recovery doesn't need an exact count forever. OSHA's recordkeeping forms package puts the stopping point this way: "You may stop counting days of restricted work activity or days away from work once the total of either or the combination of both reaches 180 days." Once the running total — days away alone, restricted days alone, or the two added together — reaches 180, no further tracking is required for that case.

Restricted work and job transfer count the same way

A case with a job transfer or a work restriction uses the identical counting rule, not a separate one. Paragraph (b)(4)(xi) says so directly: "You count days of job transfer or restriction in the same way you count days away from work, using § 1904.7(b)(3)(i) to (viii), above." The day-after start, the days-off-still-count rule and the 180-day cap all carry over unchanged; only the column the days get entered under changes.

Worked example

Picture one made-up case, on a log with no other entries, in a shop that logged 40,000 hours for the year. The injury happens on a Monday. Counting starts the next day, and the physician's order for this employee runs exactly 30 calendar days straight, including the four weekends inside that stretch, since the employee wasn't going to work those days regardless.

How that 30-day order is written changes which column the case sits in, even though the day count itself doesn't change. If the physician keeps the employee completely off work for the 30 days, it's a days-away case: 1 case in column H, 0 in column I. Fed into the TRIR calculator, that gives a total recordable case rate of 5.00, a DART rate of 5.00, and — since column H alone carries the case — a days-away case rate of 5.00.

If the physician instead sends the employee back on light duty for the same 30 days, kept off one routine task the job normally requires, it's a restricted-work case instead: 0 in column H, 1 in column I. The total recordable case rate and the DART rate on the DART rate calculator come out exactly the same, 5.00 and 5.00, because DART already adds columns H and I together and the case count hasn't changed. What moves is the days-away case rate alone, which drops to 0.00, since no case is left in column H to carry it.

The lesson holds beyond this one example: TRIR counts cases, not days, so a day count on its own never changes it. DART counts columns H and I together, so moving a case between those two columns never changes it either. Only a rate that isolates one column — like the days-away case rate here — moves when a case does. If you're not sure a case is recordable in the first place, work it through what counts as a recordable injury or the recordability checker before you start counting its days.