- Standard Number:
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.
March 24, 1994
Paul C. Decker, CSP
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.
Division of Recordkeeping Requirements