Standard Interpretations - Table of Contents
• Standard Number: 1904.5(b)(2)

November 15, 2010

Mr. Kenneth M. Colonna
RSC Equipment Rental
6929 East Greenway Parkway, Suite 200
Scottsdale, Arizona 85254

Dear Mr. Colonna:

Thank you for your September 1, 2010 letter to the Occupational Safety and Health Administration (OSHA) regarding the recordkeeping regulation contained in 29 CFR Part 1904 - Recording and Reporting Occupational Injuries and Illnesses. In an effort to provide the public with prompt and accurate responses, we developed and continue to refine a set of Frequently Asked Questions (FAQ), in addition to maintaining a log of Letters of Interpretation (LOI) on the OSHA Recordkeeping web site.

Your letter states an employee was returning to work from his lunch break with two co-workers. After parking in the parking lot, which is open to RSC employees and customers, the employee placed his foot on the running board of his co-worker's truck, caught his heel on the running board and fell breaking his ankle.

Question: Does the incident meet the criteria of occurring in the workplace and thus is a recordable event?

Response: We presume from your letter that the parking lot in question is your company's parking lot. Work-related exposures include most of the employees' activities on the employers' premises as well as situations off premises where employees are engaged in job tasks or are there as a condition of employment. For recordkeeping purposes, company parking lots are part of the employer's premises, and therefore part of the establishment. (See OSHA's Frequently Asked Questions (FAQ) 5-10.

Under Section 1904.5(b)(2)(v), an injury or illness is not