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OSHA interpretation · 1992-01-23

Injuries occurring to employees engaged in activities at a company picnic.

← All interpretations§ 1904

OSHA’s standing caveat

Interpretation letters explain existing requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. Enforcement guidance may be affected by later changes to OSHA rules, and a letter addresses the facts it was given — not necessarily yours.

January 23, 1992 Ms. Jeanette Rauba Safety Administration Assistant AT&T Bell Laboratories 600 Mountain Avenue Murray Hill, New Jersey 07974-0636 Dear Ms. Rauba: Thank you for your letter of January 3, requesting a recordkeeping interpretation on injuries occurring to employees engaged in activities at a company picnic. This situation is best addressed by question C-13 on page 35 of the Recordkeeping Guidelines for Occupational Injuries and Illnesses , 1986. If the employee is required to participate in an off-premises activity, any resulting injury or illness is presumed work related for OSHA recordkeeping purposes. In your letter you specify that the employees are required to attend the picnic, but are not required to participate in the sports activities. Though it is not required, it may reasonably be assumed that participation in sports activities will occur at a picnic. Because the employees are required to attend the picnic, work relationship is established, and any resulting injury meeting the recordability criteria must be recorded. If you have any further questions, please contact my staff at Area Code (202) 523-1463. Sincerely, STEPHEN A. NEWELL Acting Director Office of Statistics

Reproduced verbatim from osha.gov. US Government work, public domain (17 U.S.C. § 105).

Other letters on the same sections

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Not legal advice. This page republishes 29 CFR Part 1904 as published by the eCFR and explains it. The recordkeeping duty is the employer’s. Where the rule requires judgement, Job13 says so rather than guessing — run your own case through the free check.