Most people assume "work-related" means an employer has to prove the job caused an injury. Under OSHA work relatedness rules, it's the opposite. The presumption favours recording the case, and the employer must find a specific, named exception to rule it out. Get that backwards and you'll either over-record ordinary life or under-record things you're legally required to log. This piece walks through the presumption in 1904.5, then all nine exceptions in 1904.5(b)(2), with the exact trigger and a worked example for each.
What is the OSHA work-relatedness presumption?
Section 1904.5(a) sets the default: an injury or illness is presumed work-related if an event or exposure in the work environment either caused it, contributed to it, or significantly aggravated a pre-existing condition. That's a low bar. It doesn't require the job to be the main cause, or even a large one — "contributed to" is enough.
"Work environment" is defined broadly too. It's any place, or any equipment or materials in that place, that the employer's business operations bring the employee into. Not just the factory floor. A client's site, a delivery van, a hotel room on a business trip — all of it counts if the job put the employee there.
So the starting question isn't "did work cause this?" It's "did something happen in the work environment?" If yes, you record it, unless one of the nine exceptions in 1904.5(b)(2) applies. Those exceptions are the only way out. There's no tenth, unwritten "seems personal to me" category, however tempting that feels at 4pm on a Friday.
The nine work-relatedness exceptions, one by one
Each exception below has to fully apply — most use the word "solely" — to take a case off the log. If work played any contributing role alongside the excluded reason, the exception doesn't apply and the presumption wins.
| # | Exception | One-line description |
|---|---|---|
| 1 | 1904.5(b)(2)(i) | Employee was on-site as a member of the general public, not as an employee |
| 2 | 1904.5(b)(2)(ii) | Symptoms show up at work but come solely from a non-work event outside the work environment |
| 3 | 1904.5(b)(2)(iii) | Injury results solely from voluntary participation in a wellness, fitness, or recreational activity |
| 4 | 1904.5(b)(2)(iv) | Injury results solely from eating, drinking, or preparing food for personal consumption |
| 5 | 1904.5(b)(2)(v) | Injury results solely from personal tasks outside assigned working hours |
| 6 | 1904.5(b)(2)(vi) | Personal grooming, self-medication for a non-work condition, or intentionally self-inflicted injury |
| 7 | 1904.5(b)(2)(vii) | Motor vehicle accident on the company parking lot or access road while commuting |
| 8 | 1904.5(b)(2)(viii) | Illness is the common cold or flu |
| 9 | 1904.5(b)(2)(ix) | Illness is a mental illness, unless a licensed provider's opinion says otherwise |
All nine work-relatedness exceptions under 1904.5(b)(2), in the order OSHA lists them, each stated as its trigger.
1. Present as a member of the general public
If someone is at your facility but not acting as your employee — visiting as a customer, attending an open house, dropping off a family member — an injury they suffer isn't work-related to them, because they weren't there in an employee capacity. This one is about the employee's role at the time of the incident, not the location.
Example: A retail employee comes into the store on their day off to buy something for personal use and slips on a wet floor. At that moment they're a customer, not staff, so it's not recordable. If a different, on-duty employee had slipped on the same wet patch while restocking shelves, that case would be recordable — same floor, different role.
2. Symptoms surface at work but originate elsewhere
This covers a non-work injury or illness that happens to become symptomatic while someone is at work. The event causing it has to have occurred entirely outside the work environment, and work can't have contributed at all.
Example: An employee twists their knee playing weekend football, feels fine Monday, and the knee locks up and swells while they're walking across the office on Tuesday. The triggering event happened off-site, off the clock, with no connection to work, so it's not recordable. Compare that with an employee who reinjures a bad knee taking the stairs two at a time on a work errand — now work has contributed, and the presumption is back in play.
3. Voluntary wellness, fitness, or recreational activities
Injuries from voluntary participation in a wellness programme, medical exam, flu shot, exercise class, or recreational activity like racquetball or a company softball game are excluded. The key word is voluntary — if attendance is required, or there are real consequences for skipping it, this exception doesn't apply.
Example: An employee twists an ankle sliding into second base at the company softball game. Participation was optional, nobody's pay or standing depended on showing up, so it's excluded under this exception. We've worked through the mechanics of this exact scenario in the company softball game injury.
4. Eating, drinking, or preparing food for personal consumption
Choking on lunch, cutting a finger slicing an apple in the breakroom, or getting food poisoning from something you brought from home or bought from the cafeteria — all excluded, as long as the injury or illness results solely from the eating, drinking, or food prep itself, not from a workplace hazard mixed in.
Example: An employee gets food poisoning from breakroom leftovers with no workplace contamination involved. That's excluded. But if the illness traces back to a contaminated ice machine the employer maintains, work has contributed, and the case comes back onto the log. See food poisoning from the breakroom.
5. Personal tasks outside assigned working hours
If an employee is on the employer's property doing something entirely personal, and it happens outside their assigned working hours, an injury from that activity is excluded. This is narrower than it sounds — "outside assigned working hours" is doing a lot of work in that sentence.
Example: An employee stays late after their shift ends to use the company gym for a personal workout and pulls a muscle. That's outside assigned hours and unrelated to their job, so it's excluded. If the same muscle pull happened during a mandatory post-shift safety drill, it wouldn't qualify — that's still within assigned duties, whatever the clock says.
6. Grooming, self-medication, and self-inflicted injuries
Personal grooming (fixing your hair, clipping a nail), self-medicating for a condition that isn't work-related, and intentionally self-inflicted injuries are all excluded. The self-medication piece only applies to non-work conditions — treating a work-related injury yourself doesn't strip its work-relatedness.
Example: An employee takes their own over-the-counter allergy medication for seasonal hay fever and has an adverse reaction at their desk. The hay fever isn't work-related, so the reaction to self-treating it isn't either. Excluded.
7. Does the OSHA parking lot rule cover every car accident at work?
No, and this is the exception people misread most. 1904.5(b)(2)(vii) excludes a motor vehicle accident on the company parking lot or access road only when the employee is commuting to or from work. It does not cover every vehicle incident that happens to occur in the lot.
Example — the case Job13 gets asked about constantly: an employee finishes their shift, walks to their car in the company lot, and is struck by another vehicle. That's excluded — a classic commuting scenario. Now change one fact: an employee drives a company vehicle across that same lot to load a delivery for a customer, and gets into an accident doing it. That's not commuting — it's a work task on work premises, so the case is recordable. Same lot, same asphalt, opposite outcomes, because purpose is what the exception turns on, not location. See the full comparison at employee hurt in the parking lot.
8. Is a cold caught at work recordable? The common cold and flu exception
The common cold and the flu are excluded outright, even if an employee can trace the infection to a sick coworker at their desk. But this exception is narrow by name — it's the common cold and flu only. Contagious diseases like tuberculosis, brucellosis, hepatitis A, or plague are considered work-related if contracted at work, with no equivalent exclusion. Confusing "any illness caught from a coworker" with "the common cold exception" is a frequent, costly misread. See the full walkthrough at cold caught at work.
9. Mental illness has its own extra condition
Mental illness is presumed not work-related, which flips the usual direction of the presumption. It only becomes recordable if the employee voluntarily provides the employer with an opinion from a physician or other licensed health care professional with appropriate training and experience, stating that the illness is work-related. Without that opinion in hand, an employer has no recording obligation, and it can't compel the employee to produce one.
Example: An employee tells their manager that workplace stress caused a diagnosed anxiety disorder, but never brings in a supporting opinion from a licensed provider. As things stand, there's no recording obligation. If that employee later hands HR a letter from their psychiatrist attributing the diagnosis to specific workplace conditions, the case becomes recordable from that point, because the extra condition has now been met.
A worked comparison: two people, one parking lot
Take the parking lot example further, because it's the clearest way to see the presumption at work. Employee A clocks out, walks to their car, and gets hit by a delivery truck backing up in the company lot. Under exception (vii), that's excluded — a motor vehicle accident while commuting, on company property. Employee B, still on the clock, drives a forklift across the same lot to move pallets between two loading bays and collides with a parked car. No commuting involved — B was performing a work task. The presumption applies, none of the nine exceptions fit, and it's recordable.
The two injuries look almost identical from a distance: someone got hurt by a vehicle, in the same lot, on the same afternoon. What separates them is what the injured person was doing at that moment, not where they were standing. That's the pattern behind most of these nine exceptions — location alone never settles it.
One EHS manager we spoke with put it this way: "Every time someone tells me an injury happened in the parking lot, my first question isn't 'was it a car accident.' It's 'were they going home, or were they working.' That one question decides the case."
Where teams get work-relatedness wrong
- Assuming anything off the clock is automatically excluded. There's no blanket "off duty means not work-related" rule. Being off the clock only matters if it maps onto one of the nine, like the personal-tasks exception in (v).
- Stretching the parking lot exception to cover work-related driving. As shown above, (vii) is about commuting, not the parking lot as a location. A delivery run, a forklift move, or a work errand through that lot isn't commuting.
- Forgetting the mental illness exception has an extra condition attached. Unlike the other eight, exception (ix) requires an employee to hand over a qualifying medical opinion before the case can become recordable. No opinion, no obligation.
- Treating the common cold exception as covering any illness caught from a colleague. It covers exactly two illnesses by name. A norovirus outbreak or hepatitis A traced to shared workplace exposure doesn't get the same pass.
- Reaching for "seems personal" as a tenth, informal exception. If a case doesn't cleanly fit one of the nine, the default under the presumption is recordable, or — when facts are genuinely unclear — flagged for a documented judgement call, not waved through on a hunch.
That last point is where a lot of the real argument happens in practice. Recordkeeping citations have stayed a steady focus area for OSHA enforcement in recent years, and work-relatedness calls are a common place inspectors probe, precisely because teams default to excluding cases instead of recording them and checking the exceptions properly.
Why the presumption catches people off guard
Most people expect to build a case for recordability — prove work caused the injury, gather evidence, argue it through. 1904.5 runs the other way. The moment something happens in the work environment, the case starts on the log side of the ledger. The employer's job is to find the specific exception that pulls it off, not to justify putting it on. That reversal trips up experienced safety staff as often as new ones. When the facts genuinely don't map cleanly onto any of the nine, the honest answer is a documented "needs review," not a guess dressed up as confidence — that's what a defensible 300 Log looks like under the 1904.7 general recording criteria.
If you want to see this presumption run against a real case instead of a hypothetical, run it through Job13's free recordability check. It applies the presumption and all nine exceptions in order, and returns a needs-review flag instead of forcing an answer when the facts leave real judgement on the table.
Frequently asked questions
What is the OSHA work-relatedness presumption?
Under 1904.5, an injury or illness is presumed work-related if an event or exposure in the work environment caused it, contributed to it, or significantly aggravated a pre-existing condition. The presumption applies automatically — the employer has to identify a specific exception in 1904.5(b)(2) to exclude a case, rather than proving work-relatedness to include one.
Does the OSHA parking lot rule exclude every injury that happens in the lot?
No. The exception in 1904.5(b)(2)(vii) only excludes motor vehicle accidents on a company lot or access road while an employee is commuting to or from work. A work task performed in that same lot — a delivery, a forklift move, a work errand — isn't commuting, so the exception doesn't apply and the presumption stands.
Is catching a cold at work OSHA recordable?
No. The common cold and flu are named exceptions under 1904.5(b)(2)(viii), even when the source is a coworker at the same desk. But other contagious diseases contracted at work, such as tuberculosis, hepatitis A, or brucellosis, are considered work-related, with no equivalent exclusion.
Is a mental illness ever OSHA recordable?
Yes, but only under a specific condition. Mental illness is presumed not work-related unless the employee voluntarily provides an opinion from a physician or other licensed health care professional with appropriate training and experience, stating the illness is work-related. Without that opinion, there's no recording obligation.
What counts as the "work environment" under 1904.5?
Any place, or the equipment or materials in that place, that the employer's business operations bring the employee into. It isn't limited to the employer's own building — a client site, a company vehicle, or a location an employee travels to for work can all count as the work environment.
