OSHA & regulation7 min read

Five OSHA recordkeeping mistakes that show up in every audit

The OSHA recordkeeping mistakes that turn up in audits are not exotic. They are five places where the wording of 29 CFR 1904 differs from the way a reasonable person reads it, and the intuitive answer is the wrong one. Each has a citation you can check in a minute and a fix you can make this week. Part 1904 is US federal law; the Canadian divergences are at the end.

1. Is "light duty" restricted work?

Almost always, yes. § 1904.7(b)(4)(i) defines restricted work two ways: you keep the employee from performing one or more routine functions of their job, or from working the full workday they would otherwise have been scheduled to work. A physician or other licensed health care professional recommending either does the same.

Routine functions are defined tightly. § 1904.7(b)(4)(ii): "an employee's routine functions are those work activities the employee regularly performs at least once per week." Not daily. Once per week.