Is It Recordable?
Scenario Q144

Offsite Lunch: is it recordable?

Verdict: Not recordable
Published 2021-03-14

Question

An employee is off the worksite for lunch and has an incident that results in medical treatment beyond first aid. Is it recordable?

Answer

NO*. The case is not work-related because the employee was not within the work environment and he was not present as a condition of employment or engaged in a work activity.

OSHA e-correspondence

*OSHA has not provided a clear letter of interpretation on this subject and so the answer is based on the limited response found in OSHA e-correspondence that is provided with the following caveat: "Note: Unless the search results indicate that the source for the Q & A is the recordkeeping rule (29 CFR 1904), the Q & As presented do not themselves impose enforceable recordkeeping or reporting obligations, since such obligations are imposed only by the regulation." The answer is subject to change pending additional clarification provided by OSHA in the future.

Illustration for the scenario: Offsite Lunch

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Illustration for the scenario: Offsite Lunch
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This is guidance based on 29 CFR Part 1904 and OSHA letters of interpretation. Facts and details may be altered or fictional. As specified by OSHA, the employer is responsible for the final recordability determination.