Is an Injury During the Commute to Work Recordable?
An injury sustained during the commute to or from work is not work-related and not recordable on the OSHA 300 Log. This rule holds even when the injury occurs on the company's own parking lot or access road, because [1904.5(b)(2)(vii)](https://www.osha.gov/laws-regs/regulations/standardnumber/1904/1904.5) explicitly excludes commute-time motor vehicle accidents from work-relatedness.
The Scenario
An employee is driving to work at 7:45 AM. They pull into the company parking lot, and while turning into a parking space, they're rear-ended by another driver entering the lot. The employee strikes their head against the headrest and reports neck pain. Their supervisor sends them to urgent care, where a PLHCP recommends two days of rest and prescribes a muscle relaxant.
The employee returns to work two days later with no restrictions.
The Reasoning
Three independent questions decide recordability:
- Was the injury work-related? No. The injury occurred during the employee's commute, before they had begun work activities. [1904.5(b)(2)(vii)](https://www.osha.gov/laws-regs/regulations/standardnumber/1904/1904.5) explicitly excludes "motor vehicle accidents in company parking lots or company access roads while commuting to or from work" from work-relatedness.
- Did the case involve medical treatment beyond first aid? Yes (prescription medication is medical treatment), but this question is irrelevant — work-relatedness is the threshold question. If the case isn't work-related, the recording criteria don't apply.
- Were any other recording criteria met? Yes (two days away from work), but again irrelevant once work-relatedness fails.
The case is not recordable because it isn't work-related, regardless of treatment received or days lost.
Edge Cases
Several variations on this fact pattern flip the determination:
- Injury on company premises after clocking in or beginning work activities — work-related. The commute exception only applies during travel to or from work, not after the employee has begun their workday on premises. - Injury during a work-required errand mid-shift — work-related. Travel between work locations during work hours is part of the work activity, not a commute. - Injury in the parking lot due to an unsafe condition the employer failed to address — still not recordable for OSHA purposes under [1904.5(b)(2)(vii)](https://www.osha.gov/laws-regs/regulations/standardnumber/1904/1904.5), though general liability obligations may still apply. - Injury during business travel (away from primary workplace) — likely work-related. [1904.5(b)(4)](https://www.osha.gov/laws-regs/regulations/standardnumber/1904/1904.5) governs travel-status work-relatedness, with separate rules for hotels and personal time. - Injury while running a personal errand on the way home — not work-related. The commute exception covers reasonable direct travel; personal detours fall under [1904.5(b)(2)(v)](https://www.osha.gov/laws-regs/regulations/standardnumber/1904/1904.5).
Reporting & Timeline
This case is not recordable on the OSHA 300 Log. No external OSHA reporting is required.
If the employee files a workers' compensation claim, that's a separate process governed by state law — workers' comp eligibility does not determine OSHA recordability, and vice versa. The two systems use different work-relatedness tests.
Conclusion
A motor vehicle accident during the commute, even on company property, is not work-related under OSHA's recordkeeping rules. Do not enter the case on your OSHA 300 Log. Document the incident in any internal incident-tracking system your company maintains, but it has no effect on your recordable injury rate.
For injuries on company premises that occur *after* the employee has begun work activities — different determination. The commute exception is narrow.
Citations Referenced
The OSHA regulations this determination relies on. Linked to the official text on osha.gov.
Determination of work-relatedness
An injury or illness is work-related if an event or exposure in the work environment either caused or contributed to the resulting condition or significantly aggravated a pre-existing injury or illness. Work-relatedness is presumed for injuries and illnesses resulting from events or exposures occurring in the work environment, unless an exception in 1904.5(b)(2) applies.
Definition of work environment
The work environment is the establishment and other locations where one or more employees are working or are present as a condition of their employment. The work environment includes the locations themselves, as well as the equipment or materials used by the employee during the course of his or her work.
Exceptions to work-relatedness presumption
Lists nine specific exceptions where an injury or illness occurring in the work environment is NOT considered work-related: (i) employee present as member of general public; (ii) symptoms appearing at work but solely from non-work event; (iii) voluntary participation in wellness, medical, fitness, or recreational activity off-the-clock; (iv) eating, drinking, or preparing food for personal consumption; (v) personal tasks outside of working hours; (vi) personal grooming, self-medication for non-work condition, or intentionally self-inflicted; (vii) motor vehicle accident on company parking lot or access road during commute; (viii) common cold or flu; (ix) mental illness without PLHCP diagnosis as work-related.
Letters of Interpretation
Official OSHA clarifications applied to this scenario.
Pre-clock-in injuries in the work environment
OSHA Letter of Interpretation · January 1, 2003
An injury occurring in the work environment is presumed work-related under 1904.5 regardless of whether the employee was officially "on the clock" for pay purposes. Pay status does not determine work-relatedness; presence in the work environment as a condition of employment does.
Company parking lot definition
OSHA Letter of Interpretation · January 1, 2003
A company parking lot is one owned, controlled, or maintained by the employer for the use of employees. Whether the employer owns the lot or it is rented/leased, if the employer controls or maintains it for employee use, it qualifies as a company parking lot.