| On September 3, 2008, a letter of interpretation was posted on the OSHA Website concerning injuries to employees in company parking lots. Over the years, the "portal to portal" battle has generally not required an injury be recorded if the employee was injured away from the property while en route to the job.
The request for interpretation involved two incidents where employees were injured when they fell to the ground while climbing out of their personal vehicles which had been parked upon arrival in the company parking lot.
Keith Goddard, director of the OSHA Directorate of Evaluation and Analysis advised the incidents are not exempt from the record-keeping rule (29CFR1904) and noted such incidents should be included on the OSHA Record-Keeping Log 300.
He stated: "OSHA has made It clear that injuries and illnesses that occur during an employee's normal commute to and from work are not considered work-related, and, therefore should not be recorded." However, for purposes of Part 1904, the employee's commute from home to work ends once he or she is at the work environment." Courtesy of "OSHA UP TO DATE" National Safety Council, Vol. 37, No. 11/November 2008
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A New OSHA Record-keeping mandate: