Occupational Safety and Health Administration regulations require employers to record work related injuries and illnesses on the OSHA 300 log. On January 20, 2026, OSHA issued an interpretation letter in response to questions over whether an employee injured at work as a result of a malfunction of personal lithium ion batteries suffered a recordable work injury.

The letter addresses a situation where a workplace fire was started by the employee’s rechargeable e-cigarette batteries, resulting in burns to him. OSHA concluded that the incident is recordable because it does not fall under any regulatory exception to the recording mandate in 29 C.F.R. §1904.5 (e.g., a personal medical emergency unrelated to work such as a heart attack). Absent such exception, if the injury occurred based on an event or exposure in the workplace, it is considered work-related. The employer’s lack of control over the hazard or lack of fault relating to the injury does not affect this analysis.

Absent the ability to claim a specific regulatory exemption, employers should record workplace injuries and illnesses even if the root cause of the incident relates to personal rather than occupational factors.

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