Is a Commuting Injury Recordable on an OSHA 300 Log? Parking Lot Exceptions Explained
Picture this. An employee pulls into the company parking lot. The engine shuts off. Before reaching the door, tires skid on black ice. The car slams into a pole. Does this commuting injury OSHA 300 count? Small teams face these moments often. One wrong call risks compliance issues. Parking lots blur the line between home and work.
OSHA rules draw clear boundaries. Understand them. Protect your records. This guide breaks down the rules. It focuses on parking lot cases. Know when to record. Know when to skip.
FORM 300 LOGBOOK is independent software for organizing OSHA 300, 300A, and 301 recordkeeping information. It is not affiliated with, endorsed by, approved by, or operated by OSHA or the U.S. Department of Labor. This article is independent educational guidance based on sources published by OSHA. It is not legal advice, does not replace official OSHA forms, does not submit records to OSHA, and does not guarantee compliance.
Step 1: Test for Work-Relatedness
Start here. Under 29 CFR 1904.5(a), an injury or illness counts as work-related if an event or exposure in the work environment caused or contributed to it. Or significantly aggravated a pre-existing condition. Work-relatedness presumes true for events in the work environment. Unless an exception applies.
Learn more in our guide on how to decide if an injury is work-related for OSHA 300.
What Counts as the Work Environment?
Per 1904.5(b)(1), the work environment includes the establishment. That covers buildings and grounds. It also includes other spots where employees work or must be for the job. Company parking lots qualify. So do access roads. Injuries there fall into the work environment. Presume work-related. Check exceptions next.
The Key Parking Lot Exception: Motor Vehicle Commutes
OSHA Commuting Exception Parking Lot Rule
Look at 29 CFR 1904.5(b)(2)(vii). This OSHA commuting exception parking lot applies only if all three conditions hold:
- A motor vehicle accident caused the injury.
- The accident happened on a company parking lot or access road.
- The employee commuted to or from work.
All must be true. If not, the exception fails. The injury stays work-related. A company parking lot injury recordable decision follows.
Ordinary commutes off-site differ. A crash on a public road during home-to-work drive sits outside the work environment. No presumption applies. Skip recording.
Parking Lot Injuries Beyond Motor Vehicles
Not every lot mishap involves a vehicle. Consider slips, trips, falls. Twisted ankles on curbs. Assaults. Ice patches. These hit the work environment. No motor vehicle exception covers them. Treat as work-related. Move to recording tests.
Travel for the employer changes things. Driving between job sites? That counts under 1904.5(b)(6). Work-related. Not a commute.
From Work-Related to Recordable: The Next Test
Work-related does not mean recordable. Check 29 CFR 1904.7. Record if the case involves death. Days away from work. Restricted work or transfer. Medical treatment beyond first aid. Loss of consciousness. Significant injury or illness diagnosed.
See details on OSHA first aid vs. medical treatment beyond first aid—what gets recorded.
Practical Checklist for Commuting Injury OSHA 300 Decisions
Use this step-by-step list. Answer each question.
- Did the employee commute? Or work/travel for the employer?
- Where? Public road, company lot, access road, building?
- Motor vehicle accident?
- Does 1904.5(b)(2) exception apply? (All parts of (vii) for lot MVAs.)
- Work-related? Check 1904.7 criteria.
Real-World Examples
Test the rules.
- Public road crash: Employee wrecks car en route to work. Outside work environment. Not work-related. Do not record.
- MVA in company lot while commuting: Car hits pole arriving. Meets all 1904.5(b)(2)(vii) parts. Exception applies. Not work-related. Skip the log.
- Slip on ice walking from car: Employee falls in lot before clocking in. Work environment. No vehicle. Work-related. Record if days away or treatment beyond first aid.
- Twisted ankle on curb: Stepping from vehicle. Lot injury. No exception. Work-related. Check 1904.7.
- Drive between sites: Employee shuttles tools. Employer business. Work-related. Record per criteria.
Document for Your Team
Note facts right away. Location. Task at the time. Clocked in? Vehicle involved? Walk-in fall? These details let reviewers trace the logic. After deciding, organize in FORM 300 LOGBOOK. Use it as your recordkeeping workspace. For more, visit OSHA guidance.
Currentness note: This draws from 29 CFR 1904.5 as published by OSHA, current as of August 2026. Confirm the latest OSHA regulation text and FAQs for your establishment.
Parking lots test your grasp of the rules. Apply them steadily. Keep records clean.