Answer Library / Recordkeeping Easter egg — the citations are real

An employee was struck by a falling drone delivering someone else's lunch. Recordable?

Quick answer

Very likely yes, if the injury meets a recording criterion. The drone's owner, its cargo, and whose lunch it was are all irrelevant — injuries from events in the work environment are presumed work-related (29 CFR 1904.5(a)), and 'struck by falling object' doesn't stop being struck by a falling object because the object was carrying a burrito.

This one sounds absurd but is barreling toward relevance as delivery drones multiply over jobsites and parking lots. The analysis is refreshingly clean, and it teaches one of recordkeeping's most misunderstood principles: fault has nothing to do with recordability.

Start with geography, as always. If the employee was in the work environment — the establishment or any location where employees are working or are present as a condition of their employment (29 CFR 1904.5(b)(1)) — then an injury from an event occurring there is presumed work-related (29 CFR 1904.5(a)). A falling drone is an event. None of the nine exceptions in 1904.5(b)(2) mentions aircraft, robots, or other people's lunches.

Notice what the analysis never asks: whose drone it was, whether the employer could have prevented it, whether anyone was negligent. OSHA recordkeeping is no-fault by design — the 300 log is a census of workplace injuries, not a verdict on blame. Employers regularly burn hours arguing 'but it wasn't our fault!' — true, perhaps, and irrelevant to the log. (Whether OSHA could cite anyone is a completely separate question from whether you record the injury.)

So: work environment + no exception + medical treatment beyond first aid, days away, or any other criterion in 29 CFR 1904.7 = recordable. The takeaway worth keeping: recordability asks where and how bad — never whose fault.

29 CFR 1904.5(a)29 CFR 1904.5(b)(1)29 CFR 1904.5(b)(2)29 CFR 1904.7
Source: An analysis from the recordkeeping rule itself (29 CFR 1904.5, 1904.7) — no drone-specific interpretation letter exists yet, which frankly feels like a matter of time. The serious lesson inside the joke: recordability is no-fault. Primary reference: read it on osha.gov →

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