OSHA has issued a letter of interpretation clarifying whether injuries resulting from the use of personal rechargeable lithium-ion batteries in the workplace should be recorded as work-related on the OSHA Forms 300, 301, and 300-A or equivalent forms.

If a work-related injury caused by a lithium-ion battery meets one or more of the general recording criteria in Section 1904.7 of the Recording and Reporting Occupational Injuries and Illnesses standard, it must be recorded on the OSHA logs.

The letter addresses recordkeeping requirements and highlights the growing need for awareness of safety risks associated with lithium-ion batteries in workplace environments. These batteries can pose safety and health risks to workers during manufacturing, usage, emergency response, disposal, and recycling. Potential risks include fires, explosions, and exposure to harmful chemicals.

Safety measures employers can take include implementing hazard controls during battery design and production; ensuring proper ventilation; storing batteries in cool, dry locations; monitoring storage areas for flammable and toxic gases; using designated recycling facilities for disposal; and providing safety showers and eyewash stations when handling battery materials.

A Letter of Interpretation is OSHA's official response to questions about how its requirements apply to specific workplace situations or hazards. They cannot create additional employer obligations. Each letter constitutes OSHA's interpretation of the requirements discussed. These letters can help stakeholders understand how to comply with Federal OSHA standards, regulations, and section 5(a)(1) of the Occupational Safety and Health Act in specific workplace situations.