- 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 https://www.osha.gov.
June 4, 1996
Edward R. Dhayer
Operations Support Division
Exxon Company, U.S.A.
Post Office Box 4692
Houston, Texas 77210-4692
Dear Mr. Dhayer:
Thank you for your letter dated April 16, requesting an interpretation regarding the recordability of an injury which occurred to one of your employees. Whenever possible, I will refer to the Recordkeeping Guidelines of Occupational Injuries and Illnesses by stating the appropriate page and Q&A numbers.
If work related, the case described in your letter is a recordable injury based on the use of prescription medication beyond a single dose which is deemed to be medical treatment. As described in your letter, the injury occurred at the front door of a public building. For establishments located within public buildings, the employer's premises is defined as the space owned or leased by the employer within the building. The front door of the public building is considered public property and the case described in your letter should be evaluated as one which occurred off the employer's premises. 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). Employees who are traveling on company business are considered to be engaged in work related activities all of the time they spend in the interest of the company, including travel between office and customer locations (Q&A C-19, page 36). The injury described in your letter is therefore considered work related and should be recorded in column 6.
If an employee who normally reports to one location is injured or becomes ill at another of the employer's establishments, his/her case must be recorded at the establishment where the event or exposure occurred (page 20, Question A-10). However, as in the scenario described in your letter, when an employee is injured during travel between establishments, the case should be recorded on the employee's normal work location log.
I hope you find this information useful. If you have any other questions, please contact us at Area Code (202) 219-6463.
Division of Recordkeeping Requirements