Yesterday, we talked about preventing parking lot slips, trips, and falls. Today, we explore circumstances in which parking lot slips and falls might trigger OSHA reporting requirements.
If an employee slips and falls in your parking lot on the way to work, or if an employee goes out to the parking lot for a smoke break and has a fall, are these work-related OSHA 300 log recordable incidents?
Here are two cases excerpted from an OSHA letter of interpretation that can help you answer this question.
Case 1
An employee must report to work by 8:00 a.m. The employee drove into the company parking lot at 7:30 a.m. and parked the car. The employee exited the car and proceeded to the office to report to work. The parking lot and sidewalks are privately owned by the facility and both are within the property line, but not the controlled access points (i.e., fence, guards). The employee stepped onto the sidewalk and slipped on the snow and ice. The employee suffered a back injury and missed multiple days of work. The company believes that the employee was still in the process of the commute to work since the employee had not yet checked in at the office. Since a work task was not being performed, the site personnel deemed the incident not work-related and therefore not recordable.
OSHA’s response: Company parking lots and sidewalks are part of the employer’s establishment for recordkeeping purposes. Here, the employee slipped on an icy sidewalk while walking to the office to report for work. In addition, the event or exposure that occurred does not meet any of the work-related exceptions contained in 1904.5(b)(2). The employee was on the sidewalk because of work; therefore, the case is work-related regardless of the fact that he had not actually checked in.
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Case 2
An employee reports to work. Several hours later, the employee goes outside for a “smoke break.” The employee slips on the ice and injures his back. Since the employee was not performing a task related to the employee’s work, the company has deemed this incident non-work related and therefore not recordable.
OSHA’s response: Under Section 1904.5(b)(2)(v), an injury or illness is not work-related if it is solely the result of an employee doing personal tasks (unrelated to their employment) at the establishment outside of the employee’s assigned working hours. In order for this exception to apply, the case must meet both of the stated conditions. The exception does not apply here because the injury or illness occurred within normal working hours. Therefore, your case in question is work-related, and if it meets the general recording criteria under Section 1904.7 the case must be recorded.
Prevent Slips, Trips, and Falls—Anywhere on Your Premises
No matter where on your premises an employee slips, trips, or falls, the result is the same—an accident and injury, perhaps leading to lost workdays, workers’ comp costs, and more.
Training helps prevent slips, trips, and falls and accidents caused by other workplace hazards.
To help train employees in a broad range of safety and health topics, savvy safety professionals have for years relied on the BLR® 7-Minute Safety Trainer. This essential training resource allows you to provide concise, memorable training easily and effectively in just a few minutes. Materials are ready-to-use, and each session supplies a detailed trainer’s outline as well as a handout, quiz, and quiz answers to get your points across quickly—and cost-effectively.
Effective, 7-minute sessions providing comprehensive safety training at an average cost of $1 a day. Get the details.
50 Meetings, Low Cost!
All told, this “trainer’s bible” contains 50 prewritten meetings covering almost every aspect of safety you’d want or need to train on, in a format designed to be taught in as little as 7 minutes. Major topics include:
- Confined spaces
- Electrical safety
- Fire safety and emergency response
- HazCom
- Machine guarding and lockout/tagout
- Material handling
- PPE use and care
- Housekeeping/slips, trips, and falls
- and dozens more
Just make as many copies as you need of the included handouts and quizzes, and you’re ready to train.
Equally important is that the program ships new meetings every quarter to respond to new and changed regulations. This service is included in the program price, which averages just over $1 a working day. In fact, this is one of BLR’s most popular safety programs.
If you’d like to personally evaluate 7-Minute Safety Trainer and see how it can build safety awareness, we’ll be happy to send it to you for 30 days on a no-cost, no-obligation trial basis. Just let us know, and we’ll arrange it.