Work-relatedness determination criteria

An injury or illness must be considered work-related when an event or exposure in the work environment either caused or contributed to the condition or significantly aggravated a pre-existing condition.

• Under 1904.5(a) the regulation establishes a geographic presumption: injuries and illnesses resulting from events or exposures that occur in the work environment are presumed work-related unless a specific exception applies.

• Practical tip: When an incident occurs on employer premises or during work activities, start by assuming work-relatedness and then check the exceptions in 1904.5(b)(2).

The "work environment" includes the employer's establishment and other locations where one or more employees are working or are present as a condition of their employment, and also includes equipment and materials used during work.

• See the definition in 1904.5(b)(1).

• Practical examples: a factory floor, a customer site where an employee is performing job duties, a company vehicle while on duty, and the tools or chemicals used in a job task are all part of the work environment for recordkeeping purposes.

You do not have to record a case that occurs in the work environment if it falls into one of the enumerated exceptions in 1904.5(b)(2).

• Key exceptions include: being present as a member of the general public rather than an employee; symptoms that surface at work but were caused solely by a non-work exposure outside work; injury from voluntary wellness or recreational activities; eating or preparing food for personal consumption; personal tasks outside assigned hours; personal grooming, self-medication, or intentionally self-inflicted injuries; motor vehicle accidents while commuting on company parking lots or access roads; common cold or flu; and mental illness unless the employee provides a qualified HCP opinion that it is work-related.

• Always evaluate facts carefully—these exceptions are specific and not meant to be applied automatically without investigation.

No, choking on a sandwich while at the employer's establishment is not considered work-related and is not recordable under that exception.

• The regulation specifically exempts injuries "solely the result of an employee eating, drinking, or preparing food or drink for personal consumption" in 1904.5(b)(2)(iv).

• Note the important contrast: if the food caused illness because it was contaminated by workplace contaminants (for example, food tainted with lead) or if the employer supplied contaminated food, then the case would be work-related and recordable per 1904.5(a).

When it's unclear where the precipitating event or exposure occurred, the employer must evaluate the employee's work duties and work environment to determine if a work event caused, contributed to, or significantly aggravated the condition.

• See the guidance in 1904.5(b)(3).

• Practical steps: gather facts about the employee's recent activities, exposures on and off the job, medical information, timing of symptom onset, and whether a workplace exposure is a plausible causal factor. Document the investigation and the rationale for the recordability decision.

A preexisting condition is "significantly aggravated" when a workplace event or exposure results in death, loss of consciousness, days away from work or restricted work or job transfer, or medical treatment when none was previously needed or a change in treatment is required.

• See the specific criteria in 1904.5(b)(4) and its subparts: death 1904.5(b)(4)(i), loss of consciousness 1904.5(b)(4)(ii), days away or restricted work 1904.5(b)(4)(iii), and medical treatment or change in medical treatment 1904.5(b)(4)(iv).

• In practice: if an employee had a stable preexisting condition but a workplace incident caused them to need new or different medical treatment or miss work, that is a significant aggravation and should be recorded.

A preexisting condition is one that resulted solely from a non-work-related event or exposure that occurred outside the work environment.

• See the definition in 1904.5(b)(5).

• Practical note: if work contributed to or aggravated the condition (beyond what would have happened outside of work), then it may be recordable under the significant aggravation criteria in 1904.5(b)(4). Document your analysis showing whether the condition was solely from a non-work event or whether work played a causal role.

Injuries and illnesses that occur while an employee is on travel status are work-related if the employee was engaged in work activities "in the interest of the employer" at the time, such as traveling to customer contacts, performing job tasks, or employer-directed entertaining.

• See the rule in 1904.5(b)(6).

• OSHA has applied this rule to complex travel scenarios—for example, in the Work-related motor vehicle fatality interpretation where the Agency analyzed overnight stops and whether the travel remained in the employer's interest; review that letter for practical examples.

When a traveling employee checks into a hotel, motel, or other temporary residence and establishes a "home away from home," they are considered to have left the work environment for that period, and injuries during ordinary commuting between the temporary residence and the worksite are not considered work-related.

• See the explanation in 1904.5(b)(6)(i).

• OSHA applied this concept in the Work-related motor vehicle fatality interpretation, analyzing whether overnight stays and side trips take an employee out of the work-related travel status. Document whether the employee had a temporary residence and whether the incident occurred while performing work activities or during non-work commuting.

No, injuries that occur while the employee is on a personal detour from a reasonably direct route of travel are not considered work-related under 1904.5(b)(6)(ii).

• Practical examples: stopping off-route to visit a friend, run a personal errand, or take a sightseeing side trip would typically be personal detours.

• If the stop is at the employer's direction or is necessary to perform work, it would not be a personal detour and could remain work-related—document the purpose of the deviation.

An injury or illness that occurs while an employee is performing paid work at home is work-related if the injury is directly related to the performance of work rather than to the general home environment.

• See the rule and examples in 1904.5(b)(7).

• Examples: dropping a box of work documents and injuring a foot is work-related; a sewing-machine needle puncture that becomes infected while doing paid garment work at home is work-related. By contrast, tripping over a family pet while hurrying to answer a personal call or electrocution from faulty home wiring are not considered work-related. Document the causal link between the injury and the work task performed at home.

No, employers cannot automatically treat cold/flu-like symptoms as non-recordable; they must investigate and make a good-faith determination, and only cases that are actually the common cold or flu fall under the exception.

• The exception is stated in 1904.5(b)(2)(viii). OSHA's interpretation in Work-related illness recordkeeping exceptions (Nov. 15, 2023) explains employers must investigate illnesses with cold/flu-like symptoms to rule out workplace causes and not simply assume the exception applies.

• Practical steps: review exposure history, timing of symptoms, medical findings, and whether workplace exposures could cause similar symptoms; document the inquiry and basis for the recordability decision.

A mental illness is not considered work-related unless the employee voluntarily provides the employer with an opinion from a qualified health care professional stating the mental illness is work-related.

• See the exception in 1904.5(b)(2)(ix).

• Practical note: the required opinion must come from a physician or other licensed health care professional with appropriate training and experience (for example, a psychiatrist or psychologist) who explicitly links the mental illness to work. Employers should document receipt of the professional opinion when recording such a case.

Yes, an injury caused by an act of violence that occurs in the work environment is generally presumed work-related unless a specific 1904.5(b)(2) exception applies.

• OSHA explains this approach and examples in the Work-relatedness of violent injury interpretation (May 17, 2023) and the general presumption in 1904.5(a).

• Practical guidance: OSHA applies a geographic presumption—if the violent act occurred while the worker was present as a condition of employment (e.g., driving for work), the injury is typically work-related even if the violent act was unforeseeable. Employers should document the incident facts and evaluate any applicable exceptions.

OSHA determined that travel-related fatalities may still be work-related depending on whether the employee was engaged in activities in the employer's interest and whether the "home away from home" or personal detour exceptions applied.

• See the detailed analysis in the Work-related motor vehicle fatality interpretation (June 12, 2024) and the general criteria in 1904.5(b)(6).

• Practical takeaway: document where the employee checked into temporary residences, whether stops were on-route or detours, whether activities were for the employer's interest, and apply the 1904.5(b)(6)(i) and 1904.5(b)(6)(ii) rules to the facts.

If the only treatment provided is first aid, ART, or exercises/stretching and the case does not meet any other recording criterion (days away, restricted work, medical treatment beyond first aid, loss of consciousness, or significant diagnosis), it generally is not recordable.

• OSHA's enforcement guidance on this topic is in the Recordability of musculoskeletal injuries memorandum (May 2, 2024), which explains that first aid and similar conservative therapies alone typically do not make a case recordable.

• Important caveat: recording criteria operate independently—if the case results in restricted duty, days away from work, medical treatment beyond first aid, or a significant diagnosis by a medical professional, the case is recordable even if only first aid or ART was used initially.

The application of heated paraffin wax alone is considered "hot therapy" and therefore is first aid, not medical treatment, so a case treated only with paraffin wax is not recordable.

• OSHA's interpretation on this issue is in Paraffin wax as medical treatment (Oct. 22, 2024), and the recordkeeping definitions appear in Part 1904 (see 1904).

• Note: if paraffin wax is used together with other treatments that meet the general recording criteria (for example prescription drugs, physical therapy, or other medical treatment beyond first aid), the combined care would make the case recordable.

Yes—software-generated forms may be used if they are equivalent to OSHA Forms 300, 300A, and 301 as required by 29 CFR 1904.29 and can meet access and readability requirements.

• OSHA's interpretation on electronic or equivalent forms is in Software-generated OSHA recordkeeping forms (Apr. 29, 2025). Employers must meet the equivalency criteria in 29 CFR 1904.29 (as discussed in that letter) and ensure the system can produce the required forms for employee access and government inspection.

• Practical steps: verify the software outputs contain the same information and are as readable as the OSHA forms, maintain the records in a retrievable format, and be prepared to provide copies to employees and OSHA representatives when requested.

OSHA stated it will not enforce the COVID-19 Healthcare ETS recordkeeping and reporting requirements in 29 CFR 1910.502 at this time, but employers must still comply with Part 1904 recordkeeping requirements.

• See OSHA's enforcement memorandum titled COVID-19 recordkeeping enforcement stay (Feb. 5, 2025), and note that OSHA will continue to enforce recordkeeping obligations under 29 CFR part 1904.

• Practical implication: do not rely on the ETS-specific COVID logs in 1910.502; instead follow the general Part 1904 rules for recording work-related illnesses unless OSHA updates enforcement policy.

Certain employers must electronically submit Form 300A data each year: establishments with 250+ employees (subject to Part 1904) and establishments with 20–249 employees in designated higher-hazard industries, as outlined in OSHA guidance and enforcement memos.

• See OSHA's enforcement guidance in Electronic injury record submission enforcement (Apr. 16, 2024) and the broad rule in 29 CFR part 1904.

• Practical note: Form 300A data for the previous calendar year must be submitted electronically by March 2 each year for covered establishments; OSHA may pursue enforcement for failures to submit as detailed in that memorandum.

Yes, employers may use NHANES-based age-correction tables other than Appendix F if certain conditions are met, including using a single dataset consistently and having a certified audiologist or physician decide to age-correct.

• OSHA's position is in the NHANES age-correction table use interpretation (Feb. 9, 2024) and the noise standard reference is discussed in that letter.

• Requirements include: applying one complete NHANES-derived table set consistently for all workers, having the decision and table selection made by a qualified provider (certified audiologist, otolaryngologist, or physician), and keeping the published reference with audiometric records.