What Makes an Injury Work-Related Under OSHA's Recordkeeping Rule?

If you are required to keep OSHA injury and illness records, you must record each fatality, injury, and illness that is work-related, is a new case, and meets one or more of the recording criteria (1904.4(a)). So the first question is whether the case is work-related. The answer is in 29 CFR 1904.5, and it starts with a presumption.

The rule starts with a presumption

You must consider an injury or illness to be 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 in the work environment, unless an exception in 1904.5(b)(2) specifically applies (1904.5(a)).

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." It also includes the equipment or materials the employee uses during the course of his or her work (1904.5(b)(1)).

When it is not obvious whether the precipitating event or exposure occurred at work or away from work, you must evaluate the employee's work duties and environment to decide whether one or more events or exposures there caused or contributed to the condition or significantly aggravated a pre-existing condition (1904.5(b)(3)).

Nine exceptions can take a case out of the presumption

A case in the work environment that falls under one of these exceptions is not work-related, and therefore is not recordable (1904.5(b)(2)). Several turn on the word "solely."

At the time of the injury or illness, the employee was present in the work environment as a member of the general public rather than as an employee (1904.5(b)(2)(i)).
The signs or symptoms surface at work but result solely from a non-work-related event or exposure that occurs outside the work environment (1904.5(b)(2)(ii)).
The case results solely from voluntary participation in a wellness program or in a medical, fitness, or recreational activity such as blood donation, physical examination, flu shot, exercise class, racquetball, or baseball (1904.5(b)(2)(iii)).
The case is solely the result of an employee eating, drinking, or preparing food or drink for personal consumption, whether bought on the employer's premises or brought in. But if the employee is made ill by food contaminated by workplace contaminants (such as lead), or gets food poisoning from food supplied by the employer, the case would be considered work-related (1904.5(b)(2)(iv)).
The case is solely the result of an employee doing personal tasks (unrelated to their employment) at the establishment outside of the employee's assigned working hours (1904.5(b)(2)(v)).
The case is solely the result of personal grooming, self medication for a non-work-related condition, or is intentionally self-inflicted (1904.5(b)(2)(vi)).
The case is caused by a motor vehicle accident and occurs on a company parking lot or company access road while the employee is commuting to or from work (1904.5(b)(2)(vii)).
The illness is the common cold or flu. Contagious diseases such as tuberculosis, brucellosis, hepatitis A, or plague are considered work-related if the employee is infected at work (1904.5(b)(2)(viii)).
Mental illness will not be considered work-related unless the employee voluntarily provides the employer with an opinion from a physician or other licensed health care professional with appropriate training and experience (psychiatrist, psychologist, psychiatric nurse practitioner, etc.) stating that the employee has a mental illness that is work-related (1904.5(b)(2)(ix)).

When does work "significantly aggravate" an old condition?

A preexisting condition is one that resulted solely from a non-work-related event or exposure outside the work environment (1904.5(b)(5)). It has been significantly aggravated when an event or exposure in the work environment results in any of the following (1904.5(b)(4)):

Death or loss of consciousness, provided the preexisting condition would likely not have resulted in that outcome but for the occupational event or exposure (1904.5(b)(4)(i) and (ii)).
One or more days away from work, or days of restricted work or job transfer, that otherwise would not have occurred but for the occupational event or exposure (1904.5(b)(4)(iii)).
Medical treatment where none was needed before the workplace event or exposure, or a change in medical treatment necessitated by it (1904.5(b)(4)(iv)).

How do travel and working at home fit in?

Cases that occur on travel status are work-related if, at the time, the employee was engaged in work activities "in the interest of the employer" (1904.5(b)(6)). Two exceptions apply:

Hotel stays. This exception covers an employee who has checked into a hotel or motel for one or more days. On checking into the hotel, motel, or other temporary residence, the employee is considered to have left the work environment, and re-enters it when work begins each day. You must evaluate activities after check-in the same way you would for a non-traveling employee. If the employee reports to a fixed worksite each day, injuries or illnesses that occur while commuting between the temporary residence and the job location are also not considered work-related (1904.5(b)(6)(i)).
Personal detours. Cases are not considered work-related if they occur while the employee is on a personal detour from a reasonably direct route of travel (1904.5(b)(6)(ii)).

For work at home, a case will be considered work-related if it occurs while the employee is performing work for pay or compensation in the home, and it is directly related to the performance of work rather than to the general home environment or setting. In the rule's example, tripping on the family dog while rushing to answer a work phone call is not work-related (1904.5(b)(7)).

Work through the questions in order

Start from the presumption (1904.5(a)).
Check the nine exceptions, and confirm every condition in any you rely on (1904.5(b)(2)).
For pre-existing conditions, travel, or work at home, apply 1904.5(b)(4), (b)(6), or (b)(7).

Source

This article relies on the regulation text of 29 CFR 1904.5, 29 CFR 1904.4(a), and 29 CFR 1904.37(b) on osha.gov. The regulation itself always controls. States that run their own OSHA-approved State Plans must have the same requirements as Federal OSHA for determining which injuries and illnesses are recordable and how they are recorded (1904.37(b)(1)). For other Part 1904 provisions, State Plan requirements may be more stringent than or supplemental to the Federal requirements (1904.37(b)(2)).