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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 http://www.osha.gov.
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.
STEPHEN A. NEWELL
Office of Statistics