The U.S. Occupational Safety and Health Administration (OSHA) has issued new guidance on how work-related injuries linked to rechargeable lithium-ion batteries should be documented on OSHA Forms 300, 301, and 300-A.
The clarification comes amid increasing use of lithium-ion batteries across workplaces and their associated safety risks.
According to the letter of interpretation, any injury caused by a lithium-ion battery that meets the general recording criteria outlined in Section 1904.7 of OSHA’s Recording and Reporting Occupational Injuries and Illnesses standard must be recorded on the agency’s logs. This guidance reinforces the importance of accurate recordkeeping for workplace incidents involving energy storage devices.
Lithium-ion batteries, commonly used in personal electronics, tools, and industrial equipment, can present significant hazards. Potential risks include fires, explosions, and chemical exposure, which can occur during manufacturing, daily use, emergency response, disposal, or recycling. The letter underlines that awareness of these hazards is critical for employers aiming to maintain safe workplaces.
To mitigate risks, OSHA recommends a range of safety measures. These include implementing controls during battery design and production, ensuring proper ventilation, storing batteries in cool and dry conditions, monitoring storage areas for flammable or toxic gases, and using designated recycling facilities. Employers are also advised to provide safety showers and eyewash stations when employees handle battery materials.
A Letter of Interpretation represents OSHA’s official response to questions about how its regulations apply to specific workplace scenarios. While these letters do not create new obligations for employers, they offer an authoritative explanation of existing requirements and guidance on compliance. Stakeholders can use them to better understand federal standards, regulations, and Section 5(a)(1) of the Occupational Safety and Health Act.
The issuance of this letter follows the launch of OSHA’s opinion letter programme in June, designed to provide clearer compliance guidance for employers and workers. The initiative expands the department’s commitment to offering practical advice that addresses real-world workplace hazards.
OSHA encourages the public to access the new opinion letters portal, where past guidance can be reviewed and new requests submitted. Each submission is assessed at OSHA’s discretion, with priority given to questions that address broader workplace safety concerns.
