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Injuries at a required company picnic

Summary An employer asked whether a worker's injury during sports at a company picnic belonged on its injury log. OSHA said required attendance made the off-site event work-related under its then-current guidelines, even though sports participation itself was optional; an injury meeting the recordability criteria had to be logged. OSHA archives the letter and warns that it may no longer reflect current policy.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1992-01-23
Date issued
January 23, 1992
Status
Archived by the agency
OSHA labels this an archive document and warns that it may no longer represent OSHA policy.
Status last verified October 9, 2026
Topics
Workplace Safety OSHA 1904 Recordkeeping Work Relatedness
Source
View the official document

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OSHA labels this an archive document and warns that it may no longer represent OSHA policy. It may no longer reflect the agency's current position. Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

January 23, 1992

Ms. Jeanette Rauba
Safety Administration Assistant
AT&T Bell Laboratories
[Recipient address omitted]
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.

Sincerely,
STEPHEN A. NEWELL
Acting Director
Office of Statistics

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