Purpose and general provisions

Yes. Under 1960.66(b), Federal agency injury and illness recording and reporting requirements must comply with 29 CFR part 1904, subparts C, D, E, and G, except as modified by this subpart.

• The subpart explicitly incorporates 29 CFR part 1904 requirements for determining which injuries and illnesses are recordable and how entries are made.
• A key modification is that the Federal definition of “establishment” in 1960.2(h) continues to apply to Federal agencies.

The Federal definition of “establishment” in 1960.2(h) applies to Federal agencies.

• Although 1960.66(b) directs agencies to follow 29 CFR part 1904 requirements, it preserves the separate Federal definition of establishment at 1960.2(h), which agencies must use when determining recording and reporting boundaries.

Agencies must use MIS-collected information to identify unsafe or unhealthful working conditions and to set program priorities.

• 1960.66(c) requires each agency to utilize its management information system to identify problem areas and establish priorities for corrective action.
• Use the data for evaluation and to drive necessary corrective actions, consistent with the subpart’s purpose of compiling occupational safety and health statistics.

Yes; agencies may use more detailed or supplemental recordkeeping forms, provided they do not interfere with the agency’s ability to provide the information required by 29 CFR part 1904.

• 1960.66(d) says agencies are allowed to use forms with more detailed breakdowns than Department of Labor forms, but the agency’s recording and reporting requirements must be the same as 29 CFR part 1904 for determining which injuries and illnesses are entered and how.
• In practice, this means any supplemental details are acceptable so long as the required 1904 data elements remain complete and exportable for review or submission.

Records that must be kept secret by statute or Executive Order for national defense or foreign policy must be kept on separate forms and not submitted to the Department of Labor.

• 1960.66(e) directs that such records should be recorded on separate forms and may be used by the agency for internal evaluation but shall not be submitted to DOL.
• Maintain clear separation, and ensure internal evaluations still support program improvements while protecting classified or restricted information.

No. Recording or reporting an event does not constitute an admission of fault, employer/employee relationship, OSHA rule violation, or eligibility for workers' compensation.

• The note to 1960.66 explicitly states that recording or reporting does not admit fault, establish legal relationships, or indicate a rule violation or entitlement to benefits.
• Agencies should treat recordkeeping as a non‑adversarial administrative requirement focused on safety data collection and program improvement.

No—these requirements do not diminish or change an agency’s responsibilities to report or record injuries and illnesses as required by the Office of Workers' Compensation Programs under FECA.

• 1960.66(f) expressly states that this part does not diminish the agency’s obligations under FECA (5 U.S.C. 8101 et seq.).
• Continue to meet both OSHA recordkeeping and OWCP/FECA reporting obligations independently.

Federal agencies must retain and provide access to employee exposure and medical records in accordance with 29 CFR 1910.1020.

• 1960.66(f) explicitly incorporates the retention and access requirements of 1910.1020.
• Follow the timelines, access rights, and confidentiality provisions in 1910.1020 when handling exposure and medical records.

Yes—agencies (and employers generally) may use software-generated equivalent forms if they meet the equivalence requirements in 29 CFR 1904 (e.g., 1904.29) and can produce equivalent forms and access as required.

• OSHA’s Software-generated OSHA recordkeeping forms Letter of Interpretation (Apr. 29, 2025) explains that forms produced by software can substitute for OSHA Forms 300 and 300A if they meet the equivalence criteria in 1904.29 (same information, readability, and completion using the same instructions) and the system can produce equivalent forms for access requests.
• Ensure the electronic system can produce the required outputs and that records are available to employees, former employees, their representatives, and government representatives per 1904.35 and 1904.40.

Employees, former employees, their representatives, and authorized government representatives must be allowed access to OSHA records, including equivalent electronic forms, consistent with the access provisions of 29 CFR part 1904.

• The Software-generated forms Letter of Interpretation (Apr. 29, 2025) reminds employers that equivalent forms must be available for inspection and copying as described in 1904.40 and provided to employees and their representatives under 1904.35.
• Maintain the ability to produce readable, understandable versions of the required forms on request, whether stored electronically or on paper.

Travel‑related injuries are recordable when they occur in the work environment and are caused or contributed to by work activities, but specific exceptions apply when the employee has established a “home away from home.”

• OSHA’s Work-related motor vehicle fatality Letter of Interpretation (June 12, 2024) explains that 29 CFR 1904.5 presumes work-relatedness for injuries occurring in the work environment unless an exception applies.
• Per 1904.5(b)(6), injuries while on travel status are work-related if engaged in employer business, but if the employee checks into a hotel and establishes a “home away from home,” injuries while commuting between the temporary residence and the job are generally not recordable.
• Use the facts—purpose of travel, whether the employee established a temporary residence, and what activity they were performing—to determine recordability.

No—heated paraffin wax used alone to treat a work-related injury is considered first aid and is not recordable.

• OSHA’s Paraffin wax Letter of Interpretation (Oct. 22, 2024) explains that hot therapy, including heated paraffin wax used alone to relieve pain or stiffness, falls within the definition of first aid in 29 CFR part 1904 and therefore is not recordable under 1904.7.
• If paraffin wax is used in combination with other treatments that meet the general recording criteria (e.g., prescription medication, physical therapy, restricted work, or days away), the case may become recordable.