Return to Work Policy

| OSHA

Written by: William Tomlin

The unthinkable has happened – one of your employee’s was injured in a job related accident.  He was taken to local clinic, spent three days away from work, and has now been cleared to return to work with certain restrictions.  What will you do?

You as the safety director most likely would have conducted an immediate accident investigation  to seek the root cause of the incident, and to determine  what conditions, procedures, or possibly employee negligence lead the accident to occur. If conditions at the site of the injury lead to the accident, you would have evaluated the work station, reviewed the lifting procedures and looked for any other safety hazards.

You then recorded the injury on your OSHA 300 log as a case involving both lost time away from work and restricted work activity, as well as having entered the number of days recommended by the physician or other licensed health care professional on the log.

OSHA states, “Workplaces with active safety and health leadership have fewer injuries, are often rated “better places to work,” and have more satisfied, more productive employees. These employees return to work more quickly after an injury or illness and produce higher-quality products and services”.

According to the Society for Human Resource Management, “Employers should design a policy that speaks to the organization’s commitment to encourage employees to return back to work quickly after an injury. They can explain to employees the negative consequences of being out of work such as the reduction or loss in wages”.

An ‘return to work’ program includes temporary light, limited, and modified duty assignments. Temporary light duty typically involves excusing an employee from performing certain tasks that he or she would normally perform. Limited duty may reduce the number of hours that someone normally works in a day. Modified duty may eliminate some tasks and replace them with others that are more suitable for the employee’s physical limitations in the employee’s normal position.

The best approach for developing a return to work program is to conduct a review, similar to that of a job safety analysis (JSA) for each job title. The analysis would determine the physical requirements necessary to do the job. It should document how much weight must be lifted, how far that weight must be carried, and the range of hand, arm and body motions needed to complete the task associated with the job title. When the injured worker is cleared to return to work, he or she should have the list of limitations from the physician. The safety director would then determine if the injured employee’s limitation(s) can be done in that job class.

An alternative for employers to consider is creating a bank of limited duty positions (e.g., positions involving administrative duties) on which to draw from when an employee is returning to work with limitations. A simple way to create such a bank of duties is to ask employees currently in the position what they would do if they had more time. Managers and supervisors should participate in creating the job bank of light duties. Duties should be meaningful and add value to the organization. Assigning duties that are viewed as punishment could cause employees to not report injuries so as to avoid these types of tasks.

A light-duty bank can include the following assignments:

  • Administrative work (e.g., filing, handling mail, answering phones, data entry, shredding)
  • Safety-related tasks (e.g., safety inspection such as checking fire extinguishers, updating safety data sheets, extension cord inspections )
  • Ordering and stocking supplies (e.g., first aid, office supplies)
  • Shipping and packaging duties
  • Providing training to others, if qualified
  • Completing any needed training to comply with OSHA program or for professional development

Employers should communicate the organization’s light duty program to their new-hire during the orientation process. Creating a light duty program is part of the Total Worker Health program developed under the CDC guidelines.

Still uncertain about conducting a JSA, or simply have questions on how to implement a safety and health management system? Contact USF SafetyFlorida today! In addition to helping employers identify and correct specific hazards, USF SafetyFlorida provides FREE onsite assistance in developing and implementing effective workplace safety and health management systems that emphasize the prevention of worker injuries and illnesses. Call now to schedule you FREE and confidential Consultation at 1-866-273-1105 or www.usfsafetyflorida.com.