Public Street Motor Vehicle Accidents and OSHA Recording

Record work-related vehicle crashes on public roads if they meet a criterion; report them to OSHA only if they happen in a construction work zone. The public street exception is a reporting exception, not a recording exception.

Vehicle incidents can be recordable even when severe reporting exceptions apply.

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.

Record work-related vehicle injuries when OSHA recording criteria are met. 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.

Field teams work away from a fixed site, so the key is linking every employee to an establishment and knowing who makes the call when something happens on the road.

Teams confuse public street reporting exceptions with log exceptions.

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.

• Construction work zones are treated differently for severe injury reporting.
• 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)).

A service driver is hospitalized overnight after a crash on the interstate between customer calls. It is not reported to OSHA, because it happened on a public highway outside a work zone, but it is recorded on the log as a days-away case.

1. Confirm the employee was working, not commuting.
2. Check the location: public road or construction work zone.
3. Report only if it happened in a work zone and was severe.
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.

• How to Record Work-From-Home Injuries on OSHA Logs
• Work-Relatedness Under OSHA 1904.5: A Practical Decision Path
• Preexisting Conditions and OSHA Recordability: When Work Significantly Aggravates an Injury
• Correcting the OSHA 300A After Posting: When to Update the Annual Summary