OSHA Clarifies Recordkeeping Rules for Injuries Involving Personal Lithium-Ion Batteries

On January 20, 2026, the U.S. Occupational Safety and Health Administration (OSHA) issued a formal interpretation addressing whether injuries caused by personal rechargeable lithium-ion batteries brought into the workplace must be recorded on the OSHA 300 Log. There are several key takeaways listed below:

Work-relatedness Standard Applies: OSHA reaffirmed that an injury is considered work-related and recordable if an event or exposurein the work environment caused or contributed to the injury, even if the activity was personal in nature.

Personal Batteries Do Not Exempt Recordkeeping: Injuries from a fire sparked by an employee carrying personal lithium-ion batteries (e.g., used in e-cigarettes), even if unrelated to job duties, do not qualify for any of the regulatory exceptions under 29 CFR 1904.5(b).

Employer Control or Fault Not a Factor: OSHA clarified that an employer’s lack of control over the personal item or lack of fault does not negate work-relatedness for recordkeeping purposes.

Exceptions Are Narrowly Interpreted: The agency emphasized that only the specific exceptions listed in the regulation (e.g., unrelated personal tasks outside working hours) apply and none fit this scenario.

This interpretation underscores OSHA’s position that the location and causal connection to the workplace are the principal factors in determining recordability, not whether an item involved in an injury originated from personal use. Employers should review their recordkeeping practices to ensure injuries tied to onsite events are captured accurately on OSHA logs.

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