Standard Interpretations

OSHA requirements are set by statute, standards, and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. Each letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information.

1904 - 29 CFR Part 1904 OSHA Recordkeeping Regulation applies only within the jurisdictional boundaries of the United States and certain locations listed in OSHAct Sec. 4(a). - 09/01/2005
1904 - All prescription medications, including preventive antibiotics, should be considered medical treatment and are recordable. - 03/10/2005
1904 - Baseline audiogram revision due to persistent STS or improved thresholds; revision must be made for each ear separately. - 05/08/2003
1904 - Car Dealership Accident - 08/23/2012
1904 - Clarification of "assigned working hours" for determining recordability of injuries that occur during breaks in the normal work schedule. - 03/10/2005
1904 - Clarification of 1904.31 regarding who is responsible for recording injuries and illnesses when supervision is shared by a prime contractor and subcontractors. - 04/25/2017
1904 - Clarification of 1910.95 and 1904 regarding physicians and audiologists roles in determining work-relatedness of worker hearing loss. - 08/29/2007
1904 - Clarification of a pre-existing injury or illness and recordable events - 02/28/2014
1904 - Clarification of assigned working hours when recording work-related injuires/illnesses. - 02/16/2010
1904 - Clarification of Multiple Business Establishments and Covered Employees - 02/28/2014
1904 - Clarification of Multiple Business Establishments and Covered Employees - 08/10/2011
1904 - Clarification of preexisting injury/illness and recordkeeping - 10/06/2009
1904 - Clarification of Recordkeeping's work-related exception. - 07/22/2003
1904 - Clarification of several recordkeeping scenarios regarding days away from work, restricted work activity, and work-relatedness. - 08/26/2008
1904 - Clarification of several recordkeeping scenarios regarding the use of prescription medication in treating a work-related case. - 02/06/2007
1904 - Clarification of soft tissue massage - 05/23/2019
1904 - Clarification of the applicability of the recording criteria for cases occurring while traveling to from an airport for work-related travel. - 02/12/2015
1904 - Clarification of the new reporting requirements contained in 1904.39. - 12/16/2014
1904 - Clarification of the reporting requirements contained in 1904.39, regarding specific types of eye and tooth injuries. - 04/07/2015
1904 - Clarification of the term "contemporaneous" as used in recordkeeping FAQ 7-10a. - 05/15/2007
1904 - Clarification of the term abnormal condition as used in the Recordkeeping standard - 01/25/2010
1904 - Clarification of the term self-inflicted as used in the Recordkeeping standard - 03/31/2009
1904 - Clarification of the terms most authoritative and pre-existing conditions as used for recordkeeping purposes. - 02/25/2011
1904 - Clarification on administering oxygen as a precautionary measure and as medical treatment - 07/28/2009
1904 - Clarification on determining if an injury or illness is work-related and the recordability of the administration of oxygen. - 11/19/2002
1904 - Clarification on how the formula is used by OSHA to calculate incident rates - 08/23/2016
1904 - Clarification on how to count calendar days resulting in days away from work - 04/03/2019
1904 - Clarification on most authoritative when multiple medical opinions are provided. - 09/24/2010
1904 - Clarification on pre-existing conditions and recordable incidents - 05/05/2010
1904 - Clarification on prescription medications and recordkeeping requirements - 10/06/2009
1904 - Clarification on recordability when trigger point injections are used for medical treatment and for diagnostic procedures - 04/18/2011
1904 - Clarification on recording days away from work for follow-up visits to doctor while on restricted-duty job and recovery time to stabilize preexisting condition. - 11/30/2005
1904 - Clarification on recordkeeping exemption for illness resulting from consuming food in the workplace. - 04/22/2010
1904 - Clarification on the recording of injuries involving broken or chipped teeth - 11/12/2015
1904 - Clarification on the use of a cold compression device is considered medical treatment. - 12/21/2017
1904 - Clarification on the use of a cold therapy only setting on a therapeutic device is first-aid - 08/09/2018
1904 - Clarification on the use of a rigid boot as a precautionary measure - 11/28/2017
1904 - Clarification on the use of cold therapy. - 11/14/2018
1904 - Clarification on the use of preventative exercise as an intervention strategy - 09/09/2016
1904 - Clarification on the work-related exception in 1904.5(b)(2)(viii) for the common cold or flu - 11/15/2023
1904 - Clarification on the work-related exemption involving personal tasks outside the assigned working hours - 11/06/2015
1904 - Clarification on when administering oxygen would result in a recordable injury - 05/08/2009
1904 - Clarification on whether an exercise regime is first aid or medical treatment - 05/20/2011
1904 - Clarification regarding the applicability of the recording criteria for an injury occurring while commuting to from work - 04/13/2015
1904 - Clarification regarding the applicability of the recording criteria involving restricted work. - 02/12/2015
1904 - Clarification regarding the jurisdiction of the applicability of the recording requirements in state territorial waters. - 02/10/2015
1904 - Clarifying the Recordability Criteria of Several Examples Addressing the Issues of Determining Work-relatedness and Covered Employees - 06/06/2012
1904 - Compliance with the access provisions when using a software application containing the records - 07/27/2018
1904 - Counting restricted days for a part-time employee - 03/30/2009
1904 - Determination of a case as days away or restricted work; case must be recorded in manner reflecting what actually occurs. - 04/24/2006
1904 - Determination of the date of an injury or illness for OSHA recordkeeping purposes. - 11/30/2004
1904 - Determination of work-relatedness on a construction site. - 05/12/2006
1904 - Determine Whether the Employer is Required to Record a Work-related Injury Sustained by an Employee which was Treated by a Reduction Procedure Performed on Her Dislocated Ring Finger - 06/26/2013
1904 - Determining if a fatality would be considered work-related - 05/04/2009
1904 - Determining if a work-related injury or illness resulted in restricted work activity/Job Transfer - 11/21/2016
1904 - Determining if an employee’s death would be work-related when involved in a motor vehicle accident - 06/12/2024
1904 - Determining if an injury is considered a new recordkeeping case based on a recurrence of previously recorded symptoms. - 12/21/2005
1904 - Determining if Injuries and Illnesses are work-related when employees commute from home to work and from a hotel to a worksite. - 03/17/2021
1904 - Determining if injuries and illnesses are work-related when employees participate in off-site voluntary charitable activity. - 10/05/2020
1904 - Determining if injuries or illnesses are work-related as a result of an act of violence - 05/17/2023
1904 - Determining if injuries or illnesses are work-related when involved in a motor vehicle accident - 01/04/2022
1904 - Determining if the employees experienced an injury or illness due to an exposure. - 09/14/2017
1904 - Determining if the injury or illness would apply to the work-related exception - 03/21/2016
1904 - Determining if the work-related injury or illness would apply to the work-related exception 1904.5(b)(2)(ii) - 08/23/2016
1904 - Determining recordkeeping for work-relatedness of accident occurring during off-site event. - 02/24/2009
1904 - Determining the recordability of an illness when an employee uses a rescue inhaler following an exposure in the work place. - 03/17/2021
1904 - Determining whether Active Release Techniques (ART) constitutes first-aid or medical treatment. - 07/24/2006
1904 - Determining whether an injury or illness is work-related and recordable - 10/19/2015
1904 - Determining whether daily stretches are considered medical treatment or fist-aid. - 12/14/2015
1904 - Determining whether injuries in the company parking lot during paid company break are work-related. - 10/29/2007
1904 - Determining whether the injury would apply to the work-related exception personal task and outside the assigned working hours - 07/29/2019
1904 - Determining whether to record an employee’s injury that involved both work-related and non-work-related incidents. - 03/17/2021
1904 - Determining who is responsible for recording an Injury or illness of police officer candidates when they attend training at a police academy. - 03/17/2021
1904 - Determining who is the responsible party to record an injury or illness - 10/19/2015
1904 - Determining work-related injuries for accidents that occur on a public road or highway - 08/23/2016
1904 - Determining work-relatedness for injuries in the home when telecommuting - 03/30/2009
1904 - Determining work-relatedness for injuries while on travel status - 10/20/2014
1904 - Determining work-relatedness for injury that occurred in company parking lot - 11/15/2010
1904 - Determining work-relatedness for pre-existing condition. - 08/18/2014
1904 - Determining work-relatedness for recordkeeping of injury resulting from horseplay. - 02/09/2009
1904 - Determining work-relatedness when the work event or exposure is only one of the discernable causes; not the sole or predominant cause. - 01/13/2004
1904 - Employee and employee representative access rights to OSHA 300 Log and OSHA 300-A Summary forms. - 11/07/2003
1904 - Employer obligation to provide access to entire OSHA 300 Logs, including names of both union and non-union employees. - 09/09/2005
1904 - Evaluating the work-relationship of an injury or illness - 09/12/2016
1904 - Evaluation of seven scenarios for work-relatedness and recordkeeping requirements. - 01/15/2004
1904 - Foreign-Flag Vessels. - 03/06/2019
1904 - Health impacts from shared office equipment. - 06/22/2009
1904 - How to maintain logs for employees across multiple locations. - 06/25/2015
1904 - Immunizations or inoculations (except tetanus) are recordable when given in response to a workplace injury or illness. - 06/23/2003
1904 - Is the use of paraffin wax as a form of topical heat application considered medical treatment beyond first aid for OSHA recordkeeping purposes - 10/22/2024
1904 - No Restricted Work Available - 06/23/2006
1904 - Once medical treatment beyond first aid has occurred for injury or illness the case must be recorded. - 11/15/2005
1904 - OSHA 300 Log requirements versus HIPAA privacy requirements. - 08/02/2004
1904 - OSHA's no-fault recordkeeping system requires recording work-related injuries and illnesses, regardless of the level of employer control or non-control involved. - 02/06/2002
1904 - Participation by professional sports teams in the Bureau of Labor Statistics Survey of Occupational Injuries and Illnesses; definition of independent contractor versus employee. - 06/23/2003
1904 - Permissibility of using electronic signature to satisfy the Annual Summary certification for OSHA Form 300-A. - 01/29/2009
1904 - Prescription medications, including preventive antibiotics, are considered medical treatment and are recordable. - 10/20/2014
1904 - Prescription medications, such as an Epi-Pen considered medical treatment beyond first-aid. - 09/13/2018
1904 - Recordability of a fatal traffic accident in a foreign project location. - 08/26/2004
1904 - Recording an absence as days away when PLHCP recommends the employee return to work. - 03/22/2011
1904 - Recording an injury when employer is provided with different medical opinions. - 04/03/2007
1904 - Recording an injury when physician recommends restriction but no restricted work is available. - 08/03/2006
1904 - Recording criteria for cases involving workers from a temporary help service, employee leasing service, or personnel supply service. - 06/23/2003
1904 - Recording criteria for recordkeeping cases involving occupational hearing loss. - 03/04/2004
1904 - Recording days away and/or restricted work activity when employee is able to work part of a shift. - 09/07/2010
1904 - Recording Injuries and Illnesses of Temporary Workers versus HIPAA Requirements - 01/12/2018
1904 - Recording of cases in which a health care professional issues a prescription, whether that prescription is filled or not. - 10/29/2001
1904 - Recordkeeping Regulation contained in 29 CFR Part 1904 - 05/25/2016
1904 - Recordkeeping Regulation contained in 29 CFR Part 1904 - 04/14/2016
1904 - Recordkeeping regulation contained in 29 CFR Part 1904 - Recording and Reporting Occupational Injuries and Illnesses - 02/01/2012
1904 - Recordkeeping requirements when an employer receives two or more differing medical recommendations for an injury/illness. - 05/12/2006
1904 - Reporting two related reportable events. - 01/08/2021
1904 - Restrictions from restricted work activities. - 04/25/2006
1904 - Results of an MRI do not negate the recordability of a physician's recommendation. - 03/19/2003
1904 - Software used to generate Equivalent OSHA Forms 300 and 300A - 04/29/2025
1904 - The use of braces with rigid stays. - 09/13/2018
1904 - Therapeutic exercise is considered medical treatment for recordkeeping purposes. - 05/21/2010
1904 - Updating the OSHA 300 Log to show changes in classification of previously recorded injuries/illnesses. - 11/01/2006
1904 - Use of glue to close a wound is medical treatment; prescription antibiotics/antiseptics for preventive treatment of a wound is medical treatment. - 08/26/2004
1904 - Use of kinesiology tape is not considered medical treatment beyond first aid. - 07/06/2015
1904 - Use of liquid bandages on wounds is considered first aid. - 08/08/2002
1904 - Use of Zipstitich and Clozex to close a wound is medical treatment beyond first-aid. - 10/09/2019
1904 - Whether damage to employee dentures is a recordable injury. - 04/03/2007
1904 - Whether manual joint manipulation is considered first aid or medical treatment for recordkeeping purposes - 11/16/2009
1904 - Whether to record injuries that occur to a contract employee when traveling from an offshore manned platform complex to other downfield fixed platforms. - 02/06/2007
1904 - Whether to record injuries that occur to employees who travel from an offshore manned platform complex or dock to other offshore platforms. - 02/06/2007
1904 - Whether to record two cases of employee injuries sustained in company parking lot during employees commute to work. - 07/14/2008
1904 Subpart E App A - Update to Enforcement Procedures for Failure to Submit Electronic Illness and Injury Records under 29 CFR 1904.41(a)(1) and (a)(2) - 04/16/2024
1904 Subpart E App B - Update to Enforcement Procedures for Failure to Submit Electronic Illness and Injury Records under 29 CFR 1904.41(a)(1) and (a)(2) - 04/16/2024

OSH Act - Section 5(a)(1)