Business travel injury and location of injury log entry

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

June 4, 1996

Edward R. Dhayer
Safety Specialist
Operations Support Division
Exxon Company, U.S.A.
[Recipient address omitted]
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.

Sincerely,
Bob Whitmore
Chief
Division of Recordkeeping Requirements