When an employee gets hurt, employers must evaluate whether the injury is “work-related” for OSHA recordkeeping purposes.

In doing so, there can be a tendency to read the rules too narrowly based on a more colloquial or “common sense” understanding of “work-related” rather than according to OSHA regulations and guidance. This may result in missed entries on OSHA logs and potential penalties.

Let’s break down what’s actually required and more importantly, where companies may trip up.

What OSHA requires

Under OSHA’s recordkeeping standard, employers must record certain work-related injuries and illnesses on their OSHA 300, 300A, and 301 logs. These logs serve as a running account of workplace injuries and are relevant to both compliance and safety trend tracking.

The key question is typically: was the injury or illness “work-related”?

OSHA’s answer is broader than many employers realize. An injury or illness is work-related if an event or exposure in the work environment caused, contributed to, or significantly aggravated the condition. That word “contributed” is doing heavy lifting. Work doesn't have to be the sole or even the primary cause — it just has to be a cause.

There’s another critical piece: the geographic presumption. If an injury results from an event or exposure in the work environment, it's presumed work-related unless a specific exception applies. The burden falls on the employer to prove an exception — not on the employee to prove the connection.

A recent real-world example that caught employers off guard

Earlier this year, OSHA issued a Letter of Interpretation illustrating just how broad the work-relatedness standard is.

The scenario: An employee brought rechargeable lithium-ion batteries from home for use in a personal e-cigarette — unrelated to job duties. The batteries’ terminals were unprotected, and while the employee carried the batteries, it sparked a fire that caused an injury.

Many employers would conclude the injury wasn't work-related — the employee brought the item from home, and it had zero connection to work tasks.

OSHA disagreed. The agency concluded the injury was work-related because the employee was at the workplace during assigned hours and present as a condition of employment. That was enough. The geographic presumption applied, and no exception fit.

This interpretation reinforces two principles. First, work needs to only be a causal factor — the regulations don't require precise measurement of relative contribution. Second, the geographic presumption is powerful: if it happens at work, start with the assumption that it’s recordable.

The pre-existing condition trap

This is where employers most often go wrong. An employee has a bad back, a bum knee, or an old rotator cuff tear from a high school football injury. They get hurt at work. The employer thinks: “That’s really about their pre-existing condition, not about work.”

This reasoning feels logical, but it's usually incorrect.

There is an exception for signs or symptoms that surface at work but result solely from a non-work-related event or exposure outside the work environment. But that exception is far narrower than many employers appreciate — generally limited to situations like an employee having a narcoleptic or epileptic episode at work that causes a fall and broken arm. In those cases, the work environment didn't contribute at all.

But if an employee with a pre-existing back condition lifts something at work and aggravates it? That’s likely recordable. The work activity contributed, even if the underlying condition existed before. The presumption runs against the employer — not the employee.

Why this matters more than you think

Some employers treat OSHA logs as a minor administrative task — just paperwork. That’s a mistake. Failure to accurately record work-related injuries can result in per-instance penalties. If OSHA concludes the failure was willful — meaning the employer knew better or showed reckless disregard — penalties can exceed $160,000 per violation. Multiple missed entries add up fast. Beyond fines, there’s reputational damage, particularly for companies that hold themselves out as safety leaders.

Practical takeaways

So, what should employers do? Start with these principles:

• If an injury or illness occurs in the work environment, presume it’s work-related unless a specific exception applies. Don't assume otherwise just because the facts seem ambiguous.
• A work event or exposure can be one of several causes — it doesn't have to be the only or predominant one. If work contributed, the injury is likely recordable.
• If you believe an exception applies, document your reasoning thoroughly.
  • Gather supporting information — including medical records where appropriate.
  • Build your case before deciding to leave an injury off the log, not after OSHA comes asking.

Getting this right isn't just about avoiding penalties. It's about building a safety program grounded in honest data — and that starts with accurate recordkeeping.