OSHA on parking lot injuries: Record them

            Employers must record incidents in which employees are injured in company parking lots, according to a letter of interpretation posted on OSHA’s Website Sept. 3.

            The letter, dated July 14, addresses two scenarios in which workers were injured when they fell to the ground while climbing out of their personal vehicles parked in a company lot. Keith Goddard, director of OSHA’s Directorate of Evaluation and Analysis, said in the letter that the incidents do not meet exceptions to the agency’s recordkeeping rule (29 CFR 1904), and advised employers to record the incident if it meets other criteria for recording, such as days away from work.

            “OSHA has made it clear that injuries and illnesses that occur during an employee’s normal commute to and from work are not considered work-related, and, therefore, not recordable,” the letter said. However, it went on to say, “For purposes of Part 1904, the employee’s commute from home to work ends once he or she arrives at the work environment.”


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