Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at

January 23, 1992

Ms. Jeanette Rauba
Safety Administration Assistant
AT&T Bell Laboratories
600 Mountain Avenue
Murray Hill, New Jersey 07974-0636

Dear Ms. Rauba:

Thank you for your letter of January 3, requesting a recordkeeping interpretation on injuries occurring to employees engaged in activities at a company picnic.

This situation is best addressed by question C-13 on page 35 of the Recordkeeping Guidelines for Occupational Injuries and Illnesses, 1986. If the employee is required to participate in an off-premises activity, any resulting injury or illness is presumed work related for OSHA recordkeeping purposes.

In your letter you specify that the employees are required to attend the picnic, but are not required to participate in the sports activities. Though it is not required, it may reasonably be assumed that participation in sports activities will occur at a picnic. Because the employees are required to attend the picnic, work relationship is established, and any resulting injury meeting the recordability criteria must be recorded.

If you have any further questions, please contact my staff at Area Code (202) 523-1463.


Acting Director
Office of Statistics