Date: February 9, 2026
Source: U.S. Department of Labor / OSHA Trade Release
Rechargeable lithium-ion batteries are everywhere in today’s workplaces – powering tools, equipment, and personal devices. But these batteries also pose real safety risks, including fire, explosion, and chemical exposure if they fail or are mishandled.
To help employers and safety professionals properly track and record these incidents, the Occupational Safety and Health Administration (OSHA) has issued a Letter of Interpretation clarifying how injuries involving lithium-ion batteries should be recorded on OSHA injury and illness logs (Forms 300, 301, and 300-A).
Key Points You Should Know
🔹 Record if Work-Related:
If an injury involving a personal or workplace lithium-ion battery meets one or more of OSHA’s general recording criteria under 29 CFR 1904.7, it must be recorded on the appropriate OSHA logs.
🔹 Battery-Related Hazards:
OSHA highlights that lithium-ion batteries can create hazards throughout their lifecycle — from manufacturing and use to emergency response, disposal, and recycling. These hazards can include fires, explosions, and exposure to harmful chemicals.
🔹 Safety Controls to Consider:
Employers should evaluate their workplaces for battery-related risks and consider steps such as:
• Implementing hazard controls in design and production
• Ensuring proper ventilation in battery-storage or charging areas
• Storing batteries in cool, dry, designated locations
• Using approved recycling or disposal processes
• Providing safety showers and eyewash stations when handling battery materials
🔹 What a Letter of Interpretation Means:
This letter doesn’t create new legal requirements — instead, it explains how OSHA’s existing standards apply in specific situations. These interpretations are valuable tools to help you stay compliant and accurate in recordkeeping.
Why Accurate Recording Matters
Maintaining accurate OSHA logs isn’t just about regulatory compliance — it’s a foundation of an effective safety program. Recording incidents involving lithium-ion batteries helps you:
✔ Identify trends and hidden hazards
✔ Inform training and preventive measures
✔ Support data-driven decisions that protect workers
Practical Safety Steps for Your Workplace
As part of your safety management system, add the following to your next review cycle:
- Audit work areas where lithium-ion batteries are used or stored
– Look for heat, sparks, or other ignition sources - Review injury logs to ensure all battery-related injuries are captured accurately
- Update hazard communication and training to include battery risks
- Ensure emergency response plans account for battery-related fires or exposures
If you need help tailoring your recording procedures or want a walkthrough of OSHA’s criteria, JLN Safety can assist – we help you translate requirements into real-world safety practices.
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