Federal

Work restrictions list

January 6, 2026federal-laws

Work Restrictions List: How to Document Medical Restrictions and Stay Compliant (SwiftSDS)

When an employee brings in a doctor’s note or mentions limits after an injury, HR usually wants the same thing: a clear work restrictions list that makes it easy to assign safe duties, document decisions, and reduce legal risk. This guide explains what a work restrictions list should include, how to handle medical restrictions under federal requirements like the ADA and FMLA, and how to turn restrictions into a practical, compliant plan.

For broader federal context, see SwiftSDS’s employment legislation list.

What a “work restrictions list” is (and why it matters)

A work restrictions list is a written summary of job-related limitations an employee must follow—typically provided by a healthcare provider or generated internally from that provider’s guidance. It should translate medical information into functional limits, such as:

  • Maximum lifting/carrying weight
  • No overhead reaching
  • Limited standing/walking time
  • No driving or no forklift operation
  • Reduced schedule or required breaks

A well-built restrictions list helps you:

  • Prevent aggravation of injuries and reduce workers’ comp exposure
  • Identify whether temporary light duty is feasible
  • Support compliance with disability accommodation duties
  • Create consistent documentation if employment decisions are later challenged

Work restrictions also intersect with basic workplace rights and protections; SwiftSDS summarizes these in 5 rights of workers.

Key federal laws that affect medical restrictions at work

Americans with Disabilities Act (ADA): interactive process and reasonable accommodation

Under the ADA (Title I), employers with 15+ employees must provide reasonable accommodations to qualified individuals with a disability unless doing so creates an undue hardship. Medical restrictions often trigger the need for an interactive process—a collaborative dialogue to identify workable accommodations.

Practical compliance points:

  • Focus on functional limitations and ability to perform essential functions.
  • Request job-related and consistent-with-business-necessity medical information (avoid overly broad requests).
  • Document the interactive process and accommodation decisions.

SwiftSDS resources that can help you operationalize this:

Family and Medical Leave Act (FMLA): leave may be the accommodation—or run alongside it

The FMLA provides eligible employees up to 12 weeks of job-protected leave for a serious health condition (among other reasons). Medical restrictions may indicate an employee can’t work at all, can only work part time, or needs intermittent leave.

Actionable compliance points:

  • Treat restrictions notes as potential notice of an FMLA-qualifying condition.
  • Use the correct certification and tracking process.
  • Remember: ADA accommodations and FMLA leave can overlap.

If your workforce includes non-employees, clarify coverage before assuming FMLA applies; see are contractors eligible for fmla.

Anti-discrimination laws: consistency and equal opportunity

Restrictions decisions can create discrimination risk if applied inconsistently (for example, offering light duty only to certain groups). Federal EEO principles under laws enforced by the EEOC (like Title VII and the ADA) require consistent, nondiscriminatory decision-making. SwiftSDS discusses the broader goal and framework in as it pertains to employment opportunity the eeo strives to and provides a deeper dive in banned discrimination.

Wage and hour considerations (FLSA): restrictions can affect timekeeping and pay

Work restrictions may change schedules, require extra breaks, or reduce duties. That raises practical FLSA issues such as ensuring nonexempt employees are paid for all hours worked and that you track time accurately.

Make sure your required postings are current, including the federal DOL notice Employee Rights Under the Fair Labor Standards Act (and the Spanish version Derechos de los Trabajadores Bajo la Ley de Normas Justas de Trabajo (FLSA) if applicable).

What to include in a compliant work restrictions list (actionable checklist)

A usable work restrictions list should be specific, job-relevant, and time-bound. Use this structure:

1) Employee and provider details (minimum necessary)

  • Employee name/ID (avoid including diagnosis in general HR files)
  • Provider name and contact (if verification is needed)
  • Date issued and effective dates
  • Re-evaluation date or expected end date

Best practice: Keep medical documentation in a confidential medical file, separate from the personnel file (common ADA/HR standard).

2) Functional limitations (measurable whenever possible)

Include clear, objective limits such as:

  • Lifting: “No lifting over 15 lbs”
  • Push/pull: “Max 20 lbs force”
  • Standing/walking: “Stand no more than 30 minutes at a time”
  • Posture: “No kneeling/squatting,” “No ladder climbing”
  • Upper extremities: “No repetitive gripping,” “No overhead reaching”
  • Equipment: “No forklift operation,” “No commercial driving”
  • Environmental: “Avoid extreme heat,” “Avoid chemical exposure”

3) Work schedule restrictions

  • Maximum hours per day/week
  • Required breaks (frequency/duration)
  • Restrictions on overtime, nights, or rotating shifts

4) Safety-sensitive and essential function notes

  • Identify any restrictions that affect essential functions (ADA relevance)
  • Identify any restrictions that trigger safety protocols (e.g., lockout/tagout eligibility, respirator use limits)

5) Temporary adjustments and re-check plan

  • Approved temporary tasks (light duty list)
  • Who monitors compliance (supervisor/HR/EHS)
  • Return-to-work follow-up date and documentation required

How to implement medical restrictions without creating legal risk

Use a “restrictions-to-tasks” mapping step

Don’t stop at the doctor’s note. Convert restrictions into allowed tasks:

  1. List essential and non-essential job tasks
  2. Mark which tasks violate restrictions
  3. Identify alternatives (task swaps, tools, modified schedules)
  4. Confirm the employee can safely perform the modified role

This step is often where the ADA interactive process becomes concrete. If you need a structured approach, start with SwiftSDS’s ADA HR guidance and align your documentation with ADA forms for employers.

Avoid “100% healed” or “no restrictions” return-to-work policies

Blanket policies that require employees to be fully healed before returning can create ADA risk because they may screen out individuals who could work with reasonable accommodation.

Train supervisors on what they can (and can’t) ask

Supervisors should enforce restrictions and report issues, but they should not request diagnoses or debate medical judgments. Provide a standard escalation path back to HR.

Keep wage/hour and posting compliance aligned

Changes in schedule and duties can change pay practices and timekeeping. Ensure your federal posters are up to date, including the DOL Employee Rights Under the Fair Labor Standards Act notice.

Location-specific compliance: postings and state overlays

Work restrictions and return-to-work programs often interact with state rules (workers’ comp, paid leave, safety requirements, and posting obligations). Maintain the right posters for each worksite and state.

Start with Federal (United States) Posting Requirements, and if you operate in specific states, review:

Practical template: example work restrictions list (fields)

Use this as a starting layout for internal consistency:

  • Effective date: ___ / Review date: ___
  • Restrictions (check all that apply):
    • ☐ Lift/carry max: ___ lbs
    • ☐ Push/pull max: ___ lbs force
    • ☐ Stand/walk: ___ minutes per hour; max ___ hours/day
    • ☐ No ladders / no stairs / no kneeling / no squatting
    • ☐ No overhead reaching / no repetitive motion (describe) ___
    • ☐ No driving / no powered industrial trucks
    • ☐ Schedule limit: ___ hours/day; ___ days/week; no overtime
    • ☐ Other safety/environmental limits: ___
  • Permitted duties: ___
  • Not permitted duties: ___
  • Assigned temporary role/tasks: ___
  • HR/Manager monitoring plan: ___

FAQ: Work restrictions list and medical restrictions

Are we allowed to ask for details about the diagnosis?

Usually, you should limit requests to what’s job-related and consistent with business necessity (ADA standard). Focus on functional limitations and expected duration, not the underlying diagnosis, unless a specific legal process requires it.

Do we have to provide light duty when someone has medical restrictions?

Not automatically. Under the ADA, you must consider reasonable accommodations that allow the employee to perform essential functions, which can include modified duties in some cases. Whether light duty is required depends on the role, the restriction, and undue hardship. Document the interactive process using consistent tools like SwiftSDS’s ADA forms for employers.

Can we place an employee on unpaid leave if we can’t accommodate restrictions?

Potentially, but treat leave as a last step after exploring accommodations. The employee may also have rights under FMLA if eligible. Document the analysis and ensure consistency to reduce discrimination risk (see banned discrimination).

Managing a work restrictions list well is less about paperwork and more about translating medical restrictions into safe, defensible work assignments. When you connect restrictions to essential functions, document the ADA interactive process, coordinate with FMLA when needed, and maintain required postings by jurisdiction, you’ll reduce risk while supporting employees’ return to productive work.