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March 24, 1994

Paul C. Decker, CSP
Ciba-Geigy Corporation
Post Office Box 100
Suffern, New York 10901-0100

Dear Mr. Decker:

Thank you for your letter dated February 25, outlining your understanding of OSHA recordkeeping requirements in regards to injuries and illnesses which occur in company parking lots. I feel that the requirements as outlined in your letter need further clarification. In my response I will refer to the Recordkeeping Guidelines for Occupational Injuries and Illnesses by citing the appropriate page and Q&A numbers.

For OSHA injury and illness recordkeeping purposes, commuting to and from work and parking lots are two separate issues. Company parking facilities are generally not considered part of the employer's premises for OSHA recordkeeping purposes. Injuries or illnesses which occur to employees on these parking lots are not presumed to be work related, and are not recordable unless the employee was engaged in some work related activity or present as a condition of employment (page 33, Q&A C-3). The parking lot is defined as the area on which cars can be parked, and does not include surrounding sidewalks.

An employee's normal commute from home to office and return is not considered to be work related (page 36, Q&A C-19). Therefore, any injury or illness occurring during this trip would not be recordable. The normal commute entails only one round trip per day. Injuries and illnesses resulting from other trips to and from work (e.g., to work overtime, etc.) would be considered work related.

I hope you find this information useful. If you have any further questions or comments, please contact us at Area Code (202) 219-6463.

Sincerely,



Bob Whitmore
Chief
Division of Recordkeeping Requirements