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April 18, 1996

Christopher Strand
Director of Education
and Safety Training
Minnesota Telephone Association, Inc.
1650 Minnesota
World Trade Center
30 East Seventh Street St.
Paul, Minnesota 55101-4901

Dear Mr. Strand:

Thank you for your letter dated March 5, requesting several OSHA injury and illness recordkeeping interpretations. Whenever possible, I will reference the Recordkeeping Guidelines for Occupational Injuries and Illnesses by citing the appropriate page and Q&A numbers.

Injuries and illnesses that result from an event or exposure off the employer's premises are work related if the worker was engaged in work related activities or was present as a condition of his or her employment (page 35, Section 2). These criteria must be applied to the scenarios outlined in your letter. If the employee was injured while performing duties in the interest of the company, the injury would be considered work related. If the employee was injured while performing normal living conditions, (e.g. eating), the injury would not be considered work related. Pay status is not a factor to be considered for OSHA recordability. Work relationship off the employer's premises is determined by the activity the employee is performing.

Injuries incurred during normal commutes to and from work are not considered recordable (page 36, C-19). However, for employees who are "on call", travel to and from work is not considered the normal commute and any injury occurring during such travel would be considered work related. This applies to employees responding and traveling to emergency situations.

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

Sincerely,



Bob Whitmore
Chief
Division of Recordkeeping Requirements