Slips, trips, and falls are one of the most frequent causes of workplace injuries. They’re even more common in the winter and are often the result of icy and snowy surfaces outdoors or slippery floors inside from snow being tracked in. They can happen at any workplace and can lead to serious injuries including severe bruising, broken bones, and concussions.
We’re often asked if slips and falls related to winter weather conditions are Occupational Safety and Health Administration (OSHA) recordable, especially when they occur outside. The answer is yes, in many cases these types of incidents are recordable.
For instance, in a 2004 OSHA interpretation letter, an incident was described that involved an employee who slipped on snow and ice on a sidewalk in the company’s parking lot on their way into work. The individual suffered a back injury and missed multiple days of work. OSHA determined that the case was work-related and therefore recordable.
OSHA explained that the company parking lot and sidewalk are part of the employer’s establishment for recordkeeping purposes. The employee was on the sidewalk because of work; therefore, the case is work-related regardless of the fact that they were outside and had not actually checked in to work for the day.
In an FAQ on OSHA’s injury and illness recordkeeping requirements, OSHA also clarified that an incident involving an employee who slipped, fell, and suffered a sprained knee while clearing snow from their personal vehicle before leaving the parking lot to drive home from work was OSHA recordable. Again, the determination was that the company parking lot, where the injury occurred, is a part of the employer’s establishment.
In determining whether or not an incident is work related, it’s helpful to refer to the exceptions listed in section 1904.5(b)(2) of the OSHA regulation on Recording and Reporting Occupational Injuries and Illnesses. As described in the rule, there are some situations where an injury or illness occurs in the work environment, but it is not considered work-related. However, in the cases mentioned above, OSHA determined that none of the work-related exceptions applied to the events and therefore the cases are work-related and recordable.
As you’re preparing your OSHA Form 300A for posting on February 1st summarizing last year’s injuries and illnesses, don’t forget to include any recordable winter weather-related injuries that may have occurred in 2023. Also, keep them on your radar to make sure you’re compliant with 2024 reporting requirements.
For assistance determining the recordability of incidents that have occurred at your workplace, or for help meeting other OSHA recordkeeping requirements, please contact us.
This blog was written by Beth Graham, Director of Quality, Research, and Training