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 - 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 1910.95 and 1904 regarding physicians and audiologists roles in determining work-relatedness of worker hearing loss. - 08/29/2007
1904 - Clarification of Recordkeeping's work-related exception. - 07/22/2003
1904 - Clarification on how the formula is used by OSHA to calculate incident rates - 08/23/2016
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 the use of a cold compression device is considered medical treatment. - 12/21/2017
1904 - Determination of the date of an injury or illness for OSHA recordkeeping purposes. - 11/30/2004
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 the employees experienced an injury or illness due to an exposure. - 09/14/2017
1904 - Determining recordkeeping for work-relatedness of accident occurring during off-site event. - 02/24/2009
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 - Evaluation of seven scenarios for work-relatedness and recordkeeping requirements. - 01/15/2004
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 - Inspection Guidance for Inpatient Healthcare Settings - [OSH Act of 1970 - Section 5(a)(1)] - 06/25/2015
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 - 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 - 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 - Results of an MRI do not negate the recordability of a physician's recommendation. - 03/19/2003
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 - 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)