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Logging off-premises and on-call worker injuries

Summary A telephone industry group asked when off-premises and on-call injuries counted as work related for OSHA logs. OSHA said the worker's activity, rather than pay status, mattered and distinguished ordinary commutes from travel while on call. OSHA archives the letter and warns it may no longer state current policy.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1996-04-18-3
Date issued
April 18, 1996
Status
Archived by the agency
OSHA labels this an archive document and warns that it may no longer represent OSHA policy. The page also carries a 2000 notice that OSHA's work-at-home issues were under review.
Status last verified October 9, 2026

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The current status of this document is unclear
OSHA labels this an archive document and warns that it may no longer represent OSHA policy. The page also carries a 2000 notice that OSHA's work-at-home issues were under review. 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 Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
About this page: The full text below is the official document from Occupational Safety and Health Administration (OSHA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

THE ISSUES RELATED TO OSHA AND WORK AT HOME ARE PRESENTLY UNDER REVIEW. SEE ASSISTANT SECRETARY JEFFRESS' JANUARY 28, 2000 TESTIMONY REGARDING OSHA COVERAGE OF WORKING AT HOME.

April 18, 1996

Christopher Strand
Director of Education
and Safety Training
Minnesota Telephone Association, Inc.
[Recipient address omitted]
Dear Mr. Strand:

Thank you for your letter dated March 5, requesting several OSHA injury and illness recordkeeping interpretations. Whenever possible, I will reference the Recordkeeping Guidelines for Occupational Injuries and Illnesses by citing the appropriate page and Q&A numbers.

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). These criteria must be applied to the scenarios outlined in your letter. If the employee was injured while performing duties in the interest of the company, the injury would be considered work related. If the employee was injured while performing normal living conditions, (e.g. eating), the injury would not be considered work related. Pay status is not a factor to be considered for OSHA recordability. Work relationship off the employer's premises is determined by the activity the employee is performing.

Injuries incurred during normal commutes to and from work are not considered recordable (page 36, C-19). However, for employees who are "on call", travel to and from work is not considered the normal commute and any injury occurring during such travel would be considered work related. This applies to employees responding and traveling to emergency situations.

I hope you find this information useful. If you have any further questions, please contact us at Area Code (202) 219-6463.

Sincerely,
Bob Whitmore
Chief
Division of Recordkeeping Requirements

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