140 current letters · 2002–2026
What OSHA has actually decided about recordkeeping
The regulation states the rule. These letters are OSHA's own answers to specific questions people asked it — whether paraffin wax is medical treatment, whether a case is recordable when the employee declines treatment. Every letter here cites 29 CFR Part 1904 and is reproduced in full.
How to read these — and what they are not
A Letter of Interpretation is OSHA answering a specific question on specific facts. In OSHA’s own standing words, they “explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations.”
So a letter is persuasive authority about how OSHA reads the rule — not a substitute for the rule, and not automatically transferable to facts that differ from the ones the letter addressed. Later letters can supersede earlier ones; they are listed newest first.
Job13 never lets a letter change a determination. The recordability check decides on the regulation alone and shows the relevant letters alongside, as authority to read — never as the reason for the answer.
Search the corpus
Every Part 1904 interpretation
Filter by topic or by the section the letter interprets. Letters from before the 2002 rewrite are available under the checkbox.
140 interpretations — showing 40
- 2026-03-31§ 1904§ 1904.5(b)(2)(viii)
Updated Enforcement Policy for Recording and Reporting of COVID-19 Cases
- 2026-01-20§ 1904§ 1904.5(a)§ 1904.5(b)(1)
Recordability of workplace injuries resulting from personal rechargeable lithium-ion batteries.
- 2025-07-28§ 1904§ 1904.7
Red Light Therapy Wraps
- 2025-04-29§ 1904§ 1904.29§ 1904.32
Software used to generate Equivalent OSHA Forms 300 and 300A
- 2024-10-22§ 1904§ 1904.7
Is the use of paraffin wax as a form of topical heat application considered medical treatment beyond first aid for OSHA recordkeeping purposes
- 2024-06-12§ 1904§ 1904.39§ 1904.5
Determining if an employee’s death would be work-related when involved in a motor vehicle accident
- 2024-05-02§ 1904§ 1904.4§ 1904.7
Enforcement Guidance Under OSHA's Recordkeeping Regulation When First Aid, Active Release Techniques (ART), and Exercise/Stretching Are Used to Treat Musculoskeletal Injuries and Illnesses
- 2024-04-16§ 1904.41§ 1904.41(a)(1)
Update to Enforcement Procedures for Failure to Submit Electronic Illness and Injury Records under 29 CFR 1904.41(a)(1) and (a)(2)
- 2024-02-09§ 1904.10
Use of age-correction tables in OSHA's Noise standard
- 2023-11-15§ 1904§ 1904.5(b)(2)(viii)
Clarification on the work-related exception in 1904.5(b)(2)(viii) for the common cold or flu
- 2023-05-17§ 1904§ 1904.5
Determining if injuries or illnesses are work-related as a result of an act of violence
- 2022-01-04§ 1904§ 1904.5
Determining if injuries or illnesses are work-related when involved in a motor vehicle accident
- 2021-03-17§ 1904§ 1904.5
Determining if Injuries and Illnesses are work-related when employees commute from home to work and from a hotel to a worksite.
- 2021-03-17§ 1904§ 1904.31
Determining who is responsible for recording an Injury or illness of police officer candidates when they attend training at a police academy.
- 2021-03-17§ 1904§ 1904.5
Determining whether to record an employee’s injury that involved both work-related and non-work-related incidents.
- 2021-03-17§ 1904§ 1904.5§ 1904.7
Determining the recordability of an illness when an employee uses a rescue inhaler following an exposure in the work place.
- 2021-01-08§ 1904§ 1904.39
Reporting two related reportable events.
- 2020-10-05§ 1904§ 1904.5
Determining if injuries and illnesses are work-related when employees participate in off-site voluntary charitable activity.
- 2019-10-09§ 1904§ 1904.7(b)(5)(ii)
Use of Zipstitich and Clozex to close a wound is medical treatment beyond first-aid.
- 2019-07-29§ 1904§ 1904.5(b)(2)(v)
Determining whether the injury would apply to the work-related exception personal task and outside the assigned working hours
- 2019-05-23§ 1904§ 1904.7(b)(5)(ii)
Clarification of soft tissue massage
- 2019-04-03§ 1904§ 1904.7(b)(3)
Clarification on how to count calendar days resulting in days away from work
- 2019-03-06§ 1904§ 1904.7(b)(3)
Foreign-Flag Vessels.
- 2018-11-14§ 1904§ 1904.7(b)(5)(ii)
Clarification on the use of cold therapy.
- 2018-10-11§ 1904.35(b)(1)(iv)
Clarification of OSHA's Position on Workplace Safety Incentive Programs and Post-Incident Drug Testing Under 29 C.F.R. §1904.35(b)(1)(iv)
- 2018-09-13§ 1904§ 1904.7(b)(5)(ii)
The use of braces with rigid stays.
- 2018-09-13§ 1904§ 1904.7
Prescription medications, such as an Epi-Pen considered medical treatment beyond first-aid.
- 2018-08-09§ 1904§ 1904.7(b)(5)(ii)
Clarification on the use of a cold therapy only setting on a therapeutic device is first-aid
- 2018-07-27§ 1904§ 1904.29(b)(6)§ 1904.35
Compliance with the access provisions when using a software application containing the records
- 2018-01-12§ 1904§ 1904.31
Recording Injuries and Illnesses of Temporary Workers versus HIPAA Requirements
- 2017-12-21§ 1904§ 1904.7(b)(5)
Clarification on the use of a cold compression device is considered medical treatment.
- 2017-11-28§ 1904§ 1904.7(b)(7)
Clarification on the use of a rigid boot as a precautionary measure
- 2017-09-14§ 1904§ 1904.46§ 1904.7(b)(7)
Determining if the employees experienced an injury or illness due to an exposure.
- 2017-04-25§ 1904§ 1904.31
Clarification of 1904.31 regarding who is responsible for recording injuries and illnesses when supervision is shared by a prime contractor and subcontractors.
- 2017-01-11§ 1904.34
Successor Employer
- 2016-11-21§ 1904§ 1904.7(b)(4)
Determining if a work-related injury or illness resulted in restricted work activity/Job Transfer
- 2016-11-10§ 1904.35§ 1904.41
Interim Enforcement Procedures for New Recordkeeping Requirements Under 29 CFR 1904.35
- 2016-09-12§ 1904§ 1904.5(b)(3)
Evaluating the work-relationship of an injury or illness
- 2016-09-09§ 1904§ 1904.7(b)(5)
Clarification on the use of preventative exercise as an intervention strategy
- 2016-08-23§ 1904
Clarification on how the formula is used by OSHA to calculate incident rates
Where to start
The most-interpreted sections of Part 1904
Each section below links to its verbatim text; the number is how many OSHA letters cite it.
- § 1904.5 Determination of work-relatedness — 34 letters
- § 1904.7 General recording criteria — 33 letters
- § 1904.2 Partial exemption for establishments in certain industries — 29 letters
- § 1904.31 Covered employees — 10 letters
- § 1904.35 Employee involvement — 7 letters
- § 1904.4 Recording criteria — 5 letters
- § 1904.8 Recording criteria for needlestick and sharps injuries — 5 letters
- § 1904.29 Forms — 4 letters
- § 1904.39 Reporting fatalities, hospitalizations, amputations, and losses of an eye as a result of work-related incidents to OSHA — 4 letters
- § 1904.6 Determination of new cases — 4 letters
Most recent letters
- 2026-03-31 Updated Enforcement Policy for Recording and Reporting of COVID-19 Cases
- 2026-01-20 Recordability of workplace injuries resulting from personal rechargeable lithium-ion batteries.
- 2025-07-28 Red Light Therapy Wraps
- 2025-04-29 Software used to generate Equivalent OSHA Forms 300 and 300A
- 2024-10-22 Is the use of paraffin wax as a form of topical heat application considered medical treatment beyond first aid for OSHA recordkeeping purposes
- 2024-06-12 Determining if an employee’s death would be work-related when involved in a motor vehicle accident
Coverage and provenance
- 406 letters citing 29 CFR Part 1904 (140 on the current rule, the rest older or superseded), harvested 2026-07-19 from osha.gov and reproduced verbatim.
- Found by enumerating 6,007 interpretation URLs and keeping those that cite Part 1904; 5,533 cite other standards and are out of scope.
- 68 enumerated URLs no longer resolve on osha.gov and are therefore not included. We report that rather than implying the corpus is exhaustive.
- OSHA letters are US Government works in the public domain (17 U.S.C. § 105).
Not legal advice. This page republishes 29 CFR Part 1904 as published by the eCFR and explains it. The recordkeeping duty is the employer’s. Where the rule requires judgement, Job13 says so rather than guessing — run your own case through the free check.