Under OSHA’s recordkeeping rules, the term for what most people call “lost time” is days away from work: a work-related injury or illness that keeps an employee from working at all for one or more calendar days after the incident. That is the OSHA lost time definition in plain terms. A licensed healthcare professional’s recommendation usually drives the call, and once a provider says the employee should stay home, the case gets recorded on the OSHA 300 Log regardless of whether the employee would rather come in.1Occupational Safety and Health Administration. Recordkeeping – Detailed Guidance for OSHA’s Injury and Illness Recordkeeping Rule
What Qualifies as a Lost Time Case
A case is “days away from work” when a work-related injury or illness leaves the employee unable to perform any of their routine job functions, or unable to come to work at all. The employer controls the conditions of work, so the medical recommendation governs — not the employee’s preference. If the employee wants to work but the provider says no, it’s a lost time case.1Occupational Safety and Health Administration. Recordkeeping – Detailed Guidance for OSHA’s Injury and Illness Recordkeeping Rule
The reverse is also true. If the provider clears the employee to return but they stay home anyway, you record only the days the provider recommended. Extra days the employee chose to take don’t count.
One threshold sits in front of all of this: the injury or illness must be work-related. OSHA presumes work-relatedness for anything occurring in the work environment unless a specific exception applies, such as voluntary wellness or recreational activities, personal eating and drinking (unless the employer supplied contaminated food), personal tasks outside assigned hours, or a pre-existing condition that a workplace event did not significantly aggravate.2Occupational Safety and Health Administration. 29 CFR 1904.5 – Determination of Work-Relatedness The word “significantly” in the aggravation rule does real work, and borderline calls should involve the treating provider’s assessment.
How To Count the Days
This is where employers slip up most often. OSHA requires you to count calendar days, not scheduled workdays. Weekends, holidays, and vacation days all count, as long as the employee would have been unable to work due to the injury or illness on those days.3eCFR. 29 CFR Part 1904 – Recording and Reporting Occupational Injuries and Illnesses
Start counting the day after the injury or the day the illness began. The day of the incident itself is never counted.3eCFR. 29 CFR Part 1904 – Recording and Reporting Occupational Injuries and Illnesses So if a worker fractures a wrist on a Tuesday and returns the following Monday, Wednesday is day one and the total is six calendar days away, not three workdays.
The count caps at 180 calendar days. Once a case reaches 180 days, you enter 180 on the log and stop counting. The cap also applies to the combined total of days away and restricted-work days.3eCFR. 29 CFR Part 1904 – Recording and Reporting Occupational Injuries and Illnesses
When an Employee Leaves the Company
If the employee leaves for a reason unrelated to the injury — retirement, a plant closing, a different job — you can stop counting at that point.4Occupational Safety and Health Administration. 29 CFR 1904.7 – General Recording Criteria The word to watch is “unrelated.” If the employee leaves because the injury prevents them from doing the job, the days keep accumulating until they would have recovered or until you hit the 180-day cap.
Updating the Count
You don’t record a final number and forget the case. During the five-year retention period, you must update entries on the 300 Log to reflect changes, including an increasing day count. If the original description or classification changes, line out the old entry and record the new information.5Occupational Safety and Health Administration. 29 CFR 1904.33 – Retention and Updating
Lost Time vs. Restricted Work
Days away from work means the employee cannot work at all. Restricted work or job transfer is a separate category: the employee comes back but cannot do everything they normally would. Mixing these up is one of the most common recording mistakes.
Restricted work applies when the employee works fewer hours than a full shift, or cannot perform at least one routine function — something they normally do at least once per week. A job transfer means moving the employee to a different position, temporarily or permanently, to work around their limitations.4Occupational Safety and Health Administration. 29 CFR 1904.7 – General Recording Criteria
A single case can involve both. A worker might miss two full weeks (days away) and then return on modified duty for another month (restricted work). When that happens, check the column for days away, leave the restricted-work column unchecked, and enter the correct day count in both the days-away and restricted-days columns.6OSHA. Brief Tutorial on Completing the OSHA Recordkeeping Forms The more severe outcome — days away — takes priority for classification.
One detail catches people off guard. A partial day of work counts as a day of restricted work, not a day away, except on the day the injury itself occurred. That first-day partial shift is neither restricted work nor a day away.
Recording Lost Time on the OSHA 300 Log
For a days-away case, place a check in column H on the 300 Log to mark the case type, then enter the total number of calendar days away in column K. You must complete this entry within seven calendar days of learning that the case is recordable.6OSHA. Brief Tutorial on Completing the OSHA Recordkeeping Forms The seven-day clock starts when you receive the information, not when the injury happens.
Privacy Concern Cases
For certain sensitive injuries, you write “Privacy Case” on the log instead of the employee’s name. OSHA limits this to six categories:1Occupational Safety and Health Administration. Recordkeeping – Detailed Guidance for OSHA’s Injury and Illness Recordkeeping Rule
- Injuries to intimate body parts or the reproductive system
- Injuries resulting from sexual assault
- Mental illnesses
- HIV infection, hepatitis, or tuberculosis
- Needlestick injuries or cuts from objects contaminated with another person’s blood or infectious material
- Any case where the employee voluntarily asks that their name be left off the log
Outside those six categories, you cannot withhold the employee’s name, even if they ask. The case still gets fully recorded; only the name is omitted.
Why Accurate Counts Matter
OSHA treats recordkeeping failures the same way it treats other safety violations, and each missing or inaccurate entry can be cited separately. For penalties proposed after January 15, 2025, a serious or other-than-serious violation runs up to $16,550, a willful or repeated violation up to $165,514 (with an $11,823 minimum for willful), and failure to abate up to $16,550 per day the violation continues.7Occupational Safety and Health Administration. US Department of Labor Announces Adjusted OSHA Civil Penalty Amounts8Occupational Safety and Health Administration. 29 CFR 1903.15 – Proposed Penalties An employer with 15 unrecorded cases isn’t facing one citation; they could face 15. Willful underreporting to improve safety metrics is investigated aggressively and penalized at the higher tier. These figures adjust again in January 2026.
Counting workdays instead of calendar days, classifying a restricted case as days away, forgetting to update a count that keeps growing — each is a small error that produces a recordable violation. The rules are mechanical, and that is the point: get the count right, and the log takes care of itself.