Is a Slip and Fall in the Company Parking Lot Recordable?
A slip and fall in a company parking lot is recordable when the employee has already begun their work activities. The same fall during the commute — before work begins or after it ends — is not work-related under [1904.5(b)(2)(vii)](https://www.osha.gov/laws-regs/regulations/standardnumber/1904/1904.5). The location alone does not determine work-relatedness; timing relative to the workday does.
The Scenario
An employee has clocked in and is walking from the company building back to their car at 11:45 AM to retrieve a tool from the trunk for an afternoon job. The parking lot has visible ice patches from the morning's freezing rain. The employee slips, falls onto their right side, and lands hard on their hip. A coworker helps them up. The employee finishes the afternoon shift on light duty. The next morning, persistent pain leads them to urgent care, where the PLHCP diagnoses a hip contusion, prescribes prescription-strength ibuprofen for one week, and recommends two days of restricted duty.
The employee returns to work the same day on restricted duty.
The Reasoning
Three independent questions decide recordability:
- Was the injury work-related? Yes. The employee had clocked in and was performing a work task — retrieving a tool for a work assignment — when the fall occurred. [1904.5(b)(2)(vii)](https://www.osha.gov/laws-regs/regulations/standardnumber/1904/1904.5) excludes parking lot motor vehicle accidents during commuting, but a slip and fall mid-shift is a different fact pattern. The employee was in the work environment, on company-controlled premises, performing a work task.
- Did the case involve medical treatment beyond first aid? Yes. Prescription-strength ibuprofen is medical treatment beyond first aid. OTC ibuprofen at over-the-counter strength would be first aid under [1904.7(b)(5)(ii)(A)](https://www.osha.gov/laws-regs/regulations/standardnumber/1904/1904.7); prescription strength flips the determination per OSHA's letter of interpretation on prescription vs. non-prescription strength.
- Were any other recording criteria met? Yes. The restricted duty (two days) is independently recordable under [1904.7(b)(4)](https://www.osha.gov/laws-regs/regulations/standardnumber/1904/1904.7). Either the medical treatment or the restricted duty alone is sufficient to record the case.
The case is recordable.
Edge Cases
Parking lot injuries turn on the timing relative to the workday. Several variations:
- Same fall during the morning commute (employee not yet clocked in) — not recordable. [1904.5(b)(2)(vii)](https://www.osha.gov/laws-regs/regulations/standardnumber/1904/1904.5) excludes commute-time injuries, including slips and falls. - Same fall after clocking out at end of shift — also not recordable. The commute exception covers travel both to and from work. - Fall during the lunch break, off-premises, returning to the parking lot to drive back — not recordable if the employee was on a personal break (eating lunch, running an errand). Recordable if returning from a work-related task. - Visitor or member of the public falls in the same parking lot — not recordable on the OSHA 300 Log. Per [1904.5(b)(2)(i)](https://www.osha.gov/laws-regs/regulations/standardnumber/1904/1904.5), injuries to people present as members of the general public are not work-related. - Contractor or non-payroll employee under day-to-day supervision — recordable on the host employer's log per [1904.31](https://www.osha.gov/laws-regs/regulations/standardnumber/1904/1904.31), if they had begun work activities. - Fall in a parking lot the employer doesn't own or control — case-by-case. The work environment under [1904.5(b)(1)](https://www.osha.gov/laws-regs/regulations/standardnumber/1904/1904.5) includes locations where employees are present as a condition of employment. A leased parking lot used by employees as part of their employment generally counts.
Reporting & Timeline
This case is recordable on your internal OSHA 300 Log. No external OSHA notification is required.
Document the case within seven calendar days of the fall per 1904.29(b)(3). Note in the case file that the employee had clocked in and was performing a work task — the timing detail is what makes this work-related rather than commute-time.
Conclusion
A slip and fall in a company parking lot is recordable when the employee was performing work activities at the time of the fall. Document the case using the date of the fall and note the work activity context.
For falls during commuting, lunch breaks off-premises, or other non-work-related times — even on company-controlled property — the case is not work-related and not recordable. The location is shared; the timing is what matters.
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.
General recording criteria
You must consider an injury or illness to meet the general recording criteria, and therefore to be recordable, if it results in any of the following: death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, loss of consciousness, or significant injury or illness diagnosed by a physician or other licensed health care professional.
Restricted work or job transfer
Restricted work occurs when, as a result of a work-related injury or illness: (1) you keep the employee from performing one or more of the routine functions of his or her job, or from working the full workday; or (2) a physician or other licensed health care professional recommends that the employee not perform one or more of the routine functions of the job, or not work the full workday.
First aid (parent section)
For the purposes of Part 1904, first aid means: (A) using non-prescription medications at non-prescription strength; (B) administering tetanus immunizations; (C) cleaning, flushing, or soaking surface wounds; (D) using wound coverings such as bandages, gauze pads, or butterfly bandages or Steri-Strips; (E) using hot or cold therapy; (F) using non-rigid means of support; (G) temporary immobilization while transporting an accident victim; (H) drilling a fingernail or toenail to relieve pressure, or draining fluid from a blister; (I) using eye patches; (J) removing foreign bodies from the eye using only irrigation or a cotton swab; (K) removing splinters or foreign material from areas other than the eye by simple means; (L) using finger guards; (M) using massages; or drinking fluids for relief of heat stress.
Covered employees
You must record on the OSHA 300 Log the recordable injuries and illnesses of all employees on your payroll, whether they are labor, executive, hourly, salary, part-time, seasonal, or migrant workers. You also must record the recordable injuries and illnesses that occur to employees who are not on your payroll if you supervise these employees on a day-to-day basis.
Letters of Interpretation
Official OSHA clarifications applied to this scenario.
Contractor employees on day-to-day supervision
OSHA Letter of Interpretation · January 1, 2003
Per 1904.31(b)(2), if a contractor's employee is under the day-to-day supervision of the host employer, the host employer must record any recordable injury or illness on its OSHA 300 Log. Day-to-day supervision means controlling the conditions of work, including assignments, hours, and methods.
Non-prescription strength vs. prescription strength medications
OSHA Letter of Interpretation · January 1, 2003
Medications available in both prescription and non-prescription form are treated based on the strength used. A PLHCP recommendation to use the non-prescription medication at prescription strength (e.g., ibuprofen 800mg) constitutes medical treatment beyond first aid.
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.