Recordability

Is a work-from-home injury OSHA recordable? Telework and the home-office rule (1904.5(b)(7))

Yes — a telework injury can land on your OSHA 300 Log, even though OSHA will never inspect the home office it happened in. The deciding line is 1904.5(b)(7): was the worker performing work for pay, and did the work itself cause the injury rather than the general home environment? Here's how to run that test.

LS
LogStead Team
OSHA Recordkeeping
10 min read

A remote employee closes their laptop, stands up from the kitchen-table desk they have used for three years, and slips on a rug. Torn ligament, surgery, six weeks off. Another remote employee lifts a full box of case files onto a shelf in the spare bedroom they call the home office and wrenches their back badly enough to need prescription pain medication and a week of restricted duty. Same setting — someone's house. Same employer. Only one of these goes on the OSHA 300 Log.

Work-from-home did not create a new recordkeeping loophole, and it did not create a new recordkeeping regime either. The same 29 CFR Part 1904 framework you use for the shop floor governs the home office. What changes is one narrow, frequently-misread question: when an injury happens inside an employee's own home, how do you decide whether it is work-related? OSHA answered that in 2001 with a purpose-built subsection — 1904.5(b)(7) — and the answer has not moved since. This post walks through that rule, the examples OSHA itself uses, and the follow-on questions telework raises: which establishment the case belongs to, and whether a remote worker even has a "commute."

The short answer, and the thing employers get wrong

Yes, a work-from-home injury can be recordable. OSHA has been explicit about this since home-based work went mainstream. The agency's 2000 directive on home-based worksites (CPL 2-0.125) draws a bright line that trips people up: OSHA will not inspect home offices and does not hold employers liable for the safety conditions of an employee's home. But in the very same breath the directive says employers who are required to keep injury and illness records "will continue to be responsible for keeping such records, regardless of whether the injuries occur in the factory, in a home office, or elsewhere, as long as they are work-related and meet the recordability criteria of 29 CFR Part 1904."

Read those two ideas together, because the gap between them is where mistakes live. No inspector will ever walk your employee's spare bedroom. That does not mean an injury there is off the log. Recording an injury is not an admission that you controlled the hazard — it is a data entry about a work-related case. The "OSHA won't come to my house" instinct is correct and completely irrelevant to whether you owe a log entry.

Two separate questions

"Can OSHA inspect the home office?" and "Do I have to record an injury that happened there?" have different answers. The first is no. The second is: yes, if the case is work-related and meets a recording criterion. Don't let the first answer talk you out of the second.

The home-office test: 1904.5(b)(7)

Recordability always runs through the same three-step decision tree: did an injury or illness occur, is it work-related, and does it meet a general recording criterion. For most cases, Step 2 — work-relatedness — leans on OSHA's geographic presumption: if the injury happened in the work environment, it is presumed work-related unless a specific exemption applies. A home is not the employer's work environment in the ordinary sense, so OSHA wrote a separate rule for it instead of relying on geography.

That rule is 29 CFR 1904.5(b)(7). It sets a two-part test. An injury or illness that occurs while an employee is working at home, including in a home office, is work-related when both of these are true:

  1. The injury or illness occurs while the employee is performing work for pay or compensation in the home, and
  2. The injury or illness is directly related to the performance of work rather than to the general home environment or setting.

Both prongs have to hold. Working from home at the time is not enough on its own — the injury also has to flow from the work, not from the house. OSHA illustrates the line with four examples baked right into the regulation:

  • An employee drops a box of work documents and injures a foot — work-related. The task was work, and the work caused the injury.
  • An employee's fingernail is punctured by a needle from a sewing machine used to perform garment work at home, it becomes infected, and it needs medical treatment — work-related. Same logic: the work tool doing the work caused it.
  • An employee trips over the family dog while rushing to answer a work phone callnot work-related. The phone call was work; the dog is the general home environment. The injury flowed from the home, not the job.
  • An employee working at home is electrocuted because of faulty home wiringnot work-related. The wiring is a condition of the house, not of the work.

Line those up and the pattern is clear. Prong 2 is doing the heavy lifting. In the two recordable examples, the instrument of the injury is the work itself — the box of files, the garment needle. In the two non-recordable examples, the injury comes from a hazard of the dwelling that would exist whether or not anyone was working — a pet underfoot, bad wiring. The employee was arguably "performing work" (answering a work call, sitting at a work computer) in the non-recordable cases too. They fail because of prong 2, not prong 1.

The deciding question

Ask: did the work hurt them, or did the house hurt them? A dropped box of files is the work. A slippery rug, a loose stair, a family pet, faulty wiring — those are the home environment, and an injury from them is not work-related even if the employee was on the clock.

Running the two scenarios from the top

Return to the two employees who opened this post.

The one who slipped on the rug getting up from their desk: not recordable. They were on the clock, so prong 1 is arguably met — but prong 2 fails. A rug is the general home environment. It would have been there, and just as slippery, on a Sunday afternoon. The work did not cause the fall; the floor did. This is the same reasoning that makes the tripped-over-dog case non-recordable.

The one who wrenched their back lifting a box of case files: recordable. Prong 1 is met — they were performing paid work. Prong 2 is met — the injury came directly from a work task (moving work materials), exactly like OSHA's dropped-box example. Now you carry it through the rest of the tree. Because a physician prescribed medication (medical treatment beyond first aid) and ordered restricted duty, it clears Step 3 easily. It goes on the log, and because there were days of restricted work, you count and enter those restricted days just as you would for an on-site case.

That is the whole point of 1904.5(b)(7): once a home injury clears the work-relatedness test, nothing else about recordkeeping changes. The recording criteria, the day-count rules, the 300A totals, the privacy-case handling — all of it applies identically. Telework is a work-relatedness question, not a separate rulebook.

Where "solely from the home" cases still get exempted

The home-office test does not repeal the nine work-relatedness exemptions in 1904.5(b)(2). A remote worker who has a personal asthma attack at their desk, or who is doing personal tasks during off-hours, or who eats lunch and burns a hand microwaving personal food, falls under the same carve-outs as anyone else. In practice, though, most home cases resolve on prong 2 of 1904.5(b)(7) before you ever reach the nine exemptions, because "the general home environment or setting" already sweeps in the ordinary domestic hazards — stairs, floors, pets, wiring, furniture — that cause the bulk of at-home mishaps.

One place to slow down: aggravation of a pre-existing condition. If a work task at home significantly aggravates something the employee already had — a bad back made materially worse by lifting those case files — the case is work-related under the same aggravation rule that governs on-site cases. "The employee already had a bad back" is not, by itself, an exemption.

Which establishment does a remote worker's case belong to?

Home cases raise a question that shop-floor cases never do: which 300 Log does the entry go on? A remote employee doesn't physically report to a plant or store. OSHA's establishment rule (1904.30) handles workers who aren't tied to one fixed location — travelers, and telecommuters — by linking them to the establishment they are assigned to or report to for supervision, rather than to the spot where the injury physically occurred. So a remote sales rep supervised out of your Denver office has their recordable home injury entered on Denver's 300 Log, not on a phantom "home" log.

If you keep separate logs for each establishment, decide up front which establishment each remote worker rolls up to and keep that mapping consistent — it drives not only which log the case lands on but which location's 300A totals, and ultimately which establishment's electronic submission, the case flows into.

Don't create a 'home' establishment

An employee's house is not an establishment for recordkeeping. Link a remote worker's recordable case to the establishment that supervises them or that they report to, and record it there. Keeping that assignment stable is what keeps your per-location 300A summaries accurate.

Does a remote worker have a recordable "commute"?

The flip side of home-based work is that the classic commuting exemption still applies, and telework can blur its edges. OSHA's normal rule is that an injury during an ordinary home-to-work commute is not work-related. A March 2021 interpretation letter reaffirmed this and drew the boundary for mixed situations: travel between home and a fixed workplace is a non-recordable commute, but once a worker with no fixed workplace is traveling in the interest of the employer — say, a home-based employee driving to a client site or between job sites — they are in "travel status," and injuries in the course of that travel are generally work-related under the travel provisions of 1904.5(b)(6).

For a purely at-home worker, the practical upshot is simple: walking from the kitchen to the home office is not a "commute" in either direction, and an injury on that walk is judged by the 1904.5(b)(7) home test — did the work cause it, or did the house? A trip on the stairs on the way to log in is the house.

Getting the determination on paper

The hard part of telework recordkeeping is not the rule — it is that the injury happens where no supervisor can see it, and the facts arrive secondhand, days later, through a phone call or an email. That makes the contemporaneous determination more important, not less. When a remote employee reports an injury, capture what they were doing at the instant it happened (performing work?), what actually caused it (the work task, or a feature of the home?), and route those two facts through 1904.5(b)(7) before anything else. Document the reasoning. "Not recordable — slipped on a rug, general home environment, 1904.5(b)(7)" is the kind of one-line note that answers an auditor's question two years later without a scramble.

LogStead runs that determination for you. The recordability wizard walks the 1904.5 work-relatedness test — including the home-office prongs — and the general recording criteria in the same sequence for every case, whether it happened on your floor or in an employee's spare room, and records the reasoning behind each call so your determination is defensible long after the details fade. It links each case to the right establishment, carries the days-away and restricted-day counts into that location's 300A totals automatically, and keeps the whole trail audit-ready. You can walk a single case through the same logic right now with our free recordability checker — no account needed.

When in doubt

If a remote worker was performing paid work and a work task caused the injury, treat it as work-related and run the rest of the tree — the fact that it happened at home changes nothing downstream. Reserve "not recordable" for injuries that flow from the home itself, and write down why. A borderline case you recorded and documented is far easier to defend than one you quietly left off.

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