In a standard interpretation letter dated January 20, 2026, OSHA addressed whether an employee who is injured at work by a fire caused by a personal rechargeable lithium-ion battery (commonly used for e-cigarettes/vapes) is recordable on the OSHA 300 log. The answer in most cases is yes. OSHA explained that the injury is presumed work-related if it occurs in the work environment during assigned working hours and none of the narrow exceptions in the recordkeeping standard apply. The fact that the battery was personal property, used for non-work activities, and used in violation of an employer’s policy does not change this conclusion.
In reaching this position, OSHA reaffirmed the fundamental principle that an injury or illness is work-related if an event or exposure in the work environment caused or contributed to it. Work-relatedness is presumed for events occurring in the work environment unless an enumerated exception in the standard applies. Here, OSHA clarified that the precipitating event was the fire in the workplace, not merely the act of carrying the personal battery. Because the employee was present at the worksite as a condition of employment during assigned work hours, the event clearly occurred in the work environment. In distinguishing this scenario from examples provided in the standard’s exceptions, OSHA stated that there is no general “personal task” exception during assigned working hours and repeated its long-held position that the nature of the activity (personal vs. work-related), the degree of employer control, preventability, or fault do not determine work-relatedness except as set forth in the limited exceptions. As an example, OSHA noted that the recordkeeping requirements apply even to cases “in which an injury or illness results from an event at work that it outside the employer’s control, such as a lightning strike, or involves activities that occur at work but that are not directly related to production, such as horseplay.”
This standard interpretation is a good reminder that OSHA’s interpretation of “work-related” is significantly broader than how many employers might otherwise be inclined to define the term. However, employers should review the exceptions when making these determinations, as certain narrow exceptions, including injuries that are solely the result of an employee doing personal tasks unrelated to their employment at the worksite when these tasks are conducted outside of the employee’s assigned working hours, may apply in limited situations. As a practical matter, employers should also document and maintain their rationale with supporting evidence whenever it determines an injury is not work-related, as willful citations can reach a maximum penalty of $165,514 per violation.