An employee travels to a third-party training session for one week where the employer is not supervising the employee. During the training, the employee is injured and receives medical treatment. Does the employer need to record the injury even if they weren't supervising the employee at the training? Is it recordable?
YES. The employee were traveling for the purposes of attending training on behalf of their employer as a condition of their employment. They were not conducting work on behalf of another entity.
Letter of Interpretation Under OSHA’s recordkeeping system, in order for the concept of day-to-day supervision to apply, there must be an employer-employee relationship. Based on the information in your letter, your client’s employees are present at the [third-party training] for the purpose of receiving training. As such, they are not conducting work activities on behalf of the [third-party trainer], and are therefore not under the day-to-day supervision of that employer.
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