- Standard Number:
OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.
July 12, 1995
Mr. Casey A. Conway Sr.
Advisor, Health and Safety
76 Products Company
1202 West 5th Street
Post Office Box 7600
Los Angeles, California 90017
Dear Mr. Casey:
Thank you for your letter dated May 23, requesting an interpretation regarding the proper recording of an injury case on the OSHA Log and Summary of Injuries and Illnesses. Injuries and illnesses that result from an event or exposure off the employer's premises are work related if the worker was (1) engaged in work related activities or was (2) present as a condition of his or her employment (page 35, Section 2 of the Recordkeeping Guidelines for Occupational Injuries and Illnesses). Furthermore, an employee's normal commute from home to office is not considered to be work related (page 36, Q&A C-19). A normal commute is considered to be one round trip per day. These criteria must be applied to the scenario outlined in your letter. The situation in your letter should be viewed as part of the employee's normal commute (the bicycle trip home being the second leg of the commute) and therefore not work related. Any travel between the employee's residence and CPR class would have been considered work related. This case should not be recorded on the Log.
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