Question: An employee is off the worksite for lunch and has an incident that results in medical treatment beyond first aid. Is it recordable?
Answer: NO*. The case is not work-related because the employee was not within the work environment and he was not present as a condition of employment or engaged in a work activity.
*OSHA has not provided a clear letter of interpretation on this subject and so the answer is based on the limited response found in OSHA e-correspondence that is provided with the following caveat "Note: Unless the search results indicate that the source for the Q & A is the recordkeeping rule (29 CFR 1904), the Q & As presented do not themselves impose enforceable recordkeeping or reporting obligations, since such obligations are imposed only by the regulation." The answer is subject to change pending additional clarification provided by OSHA in the future.