Parking Lot Injuries and OSHA Recordability

A company-controlled parking lot is part of the work environment, so a slip or fall there is generally work-related. The one exception is a motor vehicle accident in the lot or on a company access road while the employee is commuting.

Parking lot cases are deceptively fact-sensitive.

An injury or illness is work-related if an event or exposure in the work environment caused or contributed to it, or significantly aggravated a pre-existing condition (29 CFR 1904.5). It is presumed for anything that happens in the work environment unless one of nine exceptions applies: the person was there as a member of the public; symptoms surfaced at work but came solely from a non-work event; voluntary wellness, fitness, or recreation; eating or drinking for personal consumption; personal tasks outside assigned working hours; personal grooming, self-medication for a non-work condition, or a self-inflicted injury; a motor vehicle accident in a company parking lot or access road while commuting; the common cold or flu; and mental illness, unless the employee voluntarily provides a qualified professional's opinion that it is work-related.

Ask whether the area is part of the work environment and whether an exception applies. Deciding work-relatedness after severity is the most common ordering mistake, and it pushes borderline cases onto the log, or off it, for the wrong reason. The fix is to settle where the employee was, what they were doing, and at whose direction before anyone discusses treatment or severity.

As the safety manager you usually own the decision itself, so the most useful habit is writing down the fact each call rests on at the time you make it.

Teams treat every fall near the building as either automatically work-related or automatically personal.

Work-relatedness is the first gate: a case that fails it never reaches the recording criteria, the 300A totals, or the rates. A case that passes still needs a recording criterion before it goes on the log.

• A commute exception can apply even on employer property in some situations.
• When it is not obvious whether the event happened at work or away from it, evaluate the employee's duties and environment to decide whether work caused, contributed to, or significantly aggravated the condition (1904.5(b)(3)).

Two employees are hurt in the company lot on an icy morning. One slips walking from their car and fractures a wrist: work-related and recordable. The other is injured when another car slides into theirs as they park: a motor vehicle accident while commuting, so it is excepted.

1. Confirm who controls the lot.
2. Identify the activity: walking, driving, or a personal task.
3. Apply the vehicle-accident exception if it fits.
4. Record the case if a criterion is met.

What to keep in the case file:

• What the employee was doing, where, and at whose direction
• Whether the location is part of the work environment
• Which exception you considered and the facts that support or rule it out
• For aggravation cases, the condition before the event and what changed after it

300log keeps the facts that decide work-relatedness (where the event happened, what the employee was doing just before, and what happened) in each case's 301 fields, right next to the log entry they support.

For a quick answer without an account, use the free recordability checker.

• Company Event Injuries and OSHA Recordkeeping
• Wellness Program Injuries and OSHA Recordkeeping
• Eating and Drinking Injuries at Work: OSHA Recordkeeping Exceptions
• OSHA 300 Injury Description Examples That Are Clear Without Oversharing