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.

1904.5 - 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
1904.5 - Clarification of 1910.95 and 1904 regarding physicians and audiologists roles in determining work-relatedness of worker hearing loss. - 08/29/2007
1904.5 - Clarification of a pre-existing injury or illness and recordable events - 02/28/2014
1904.5 - Clarification of assigned working hours when recording work-related injuires/illnesses. - 02/16/2010
1904.5 - Clarification of preexisting injury/illness and recordkeeping - 10/06/2009
1904.5 - Clarification of several recordkeeping scenarios regarding days away from work, restricted work activity, and work-relatedness. - 08/26/2008
1904.5 - Clarification of the term self-inflicted as used in the Recordkeeping standard - 03/31/2009
1904.5 - Clarification of the terms most authoritative and pre-existing conditions as used for recordkeeping purposes. - 02/25/2011
1904.5 - Clarification on determining if an injury or illness is work-related and the recordability of the administration of oxygen. - 11/19/2002
1904.5 - Clarification on recordkeeping exemption for illness resulting from consuming food in the workplace. - 04/22/2010
1904.5 - Clarification on the work-related exemption involving personal tasks outside the assigned working hours - 11/06/2015
1904.5 - Clarifying the Recordability Criteria of Several Examples Addressing the Issues of Determining Work-relatedness and Covered Employees - 06/06/2012
1904.5 - Determination of work-relatedness on a construction site. - 05/12/2006
1904.5 - Determining if an employee’s death would be work-related when involved in a motor vehicle accident - 06/12/2024
1904.5 - 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
1904.5 - Determining if injuries and illnesses are work-related when employees participate in off-site voluntary charitable activity. - 10/05/2020
1904.5 - Determining if injuries or illnesses are work-related as a result of an act of violence - 05/17/2023
1904.5 - Determining if injuries or illnesses are work-related when involved in a motor vehicle accident - 01/04/2022
1904.5 - Determining if the work-related injury or illness would apply to the work-related exception 1904.5(b)(2)(ii) - 08/23/2016
1904.5 - Determining the recordability of an illness when an employee uses a rescue inhaler following an exposure in the work place. - 03/17/2021
1904.5 - Determining whether an injury or illness is work-related and recordable - 10/19/2015
1904.5 - Determining whether injuries in the company parking lot during paid company break are work-related. - 10/29/2007
1904.5 - Determining whether to record an employee’s injury that involved both work-related and non-work-related incidents. - 03/17/2021
1904.5 - Determining work-related injuries for accidents that occur on a public road or highway - 08/23/2016
1904.5 - Determining work-relatedness for injuries while on travel status - 10/20/2014
1904.5 - Determining work-relatedness for pre-existing condition. - 08/18/2014
1904.5 - Determining work-relatedness for recordkeeping of injury resulting from horseplay. - 02/09/2009
1904.5 - 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
1904.5 - Evaluation of seven scenarios for work-relatedness and recordkeeping requirements. - 01/15/2004
1904.5 - 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
1904.5 - Recording an injury when employer is provided with different medical opinions. - 04/03/2007
1904.5 - Recording criteria for cases involving occupational hearing loss when employees use hearing protection - 04/29/2016
1904.5 - 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
1904.5 - 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
1904.5 - Whether to record two cases of employee injuries sustained in company parking lot during employees commute to work. - 07/14/2008
1904.5(b) - Clarification of the applicability of the recording criteria for cases occurring while traveling to from an airport for work-related travel. - 02/12/2015
1904.5(b) - Clarification regarding the applicability of the recording criteria for an injury occurring while commuting to from work - 04/13/2015
1904.5(b) - Recordkeeping regulation contained in 29 CFR Part 1904 - Recording and Reporting Occupational Injuries and Illnesses - 02/01/2012
1904.5(b)(1) - Determining if a fatality would be considered work-related - 05/04/2009
1904.5(b)(1) - Determining recordkeeping for work-relatedness of accident occurring during off-site event. - 02/24/2009
1904.5(b)(2) - Clarification of Recordkeeping's work-related exception. - 07/22/2003
1904.5(b)(2) - Determining work-relatedness for injury that occurred in company parking lot - 11/15/2010
1904.5(b)(2)(ii) - Clarification of the terms most authoritative and pre-existing conditions as used for recordkeeping purposes. - 02/25/2011
1904.5(b)(2)(ii) - 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
1904.5(b)(2)(v) - Clarification of "assigned working hours" for determining recordability of injuries that occur during breaks in the normal work schedule. - 03/10/2005
1904.5(b)(2)(v) - Determining whether the injury would apply to the work-related exception personal task and outside the assigned working hours - 07/29/2019
1904.5(b)(2)(vi) - Determining if the injury or illness would apply to the work-related exception - 03/21/2016
1904.5(b)(2)(viii) - Clarification on the work-related exception in 1904.5(b)(2)(viii) for the common cold or flu - 11/15/2023
1904.5(b)(3) - Determining if an injury is considered a new recordkeeping case based on a recurrence of previously recorded symptoms. - 12/21/2005
1904.5(b)(3) - Evaluating the work-relationship of an injury or illness - 09/12/2016
1904.5(b)(6) - Recordability of a fatal traffic accident in a foreign project location. - 08/26/2004

OSH Act - Section 5(a)(1)