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Worker Injured While Getting Lunch From Her Car Not Acting in Scope of Employment

A security officer walked across a parking lot adjacent to her employer’s property to reach her car, parked on a street, so she could retrieve her lunch and move her car into the employer’s parking garage. She was injured when she slipped and fell on ice. Her workers’ comp claim was denied and she appealed. The Appeals Commission upheld the denial saying her injury didn’t arise out of her employment. The Commission said the “worker was performing a personal errand at the time of her slip and fall accident,” the fall happened on a parking lot not owned or controlled by her employer and she wasn’t required to cross that parking lot for work-related duties at the time she fell. Thus, the commission concluded the accident didn’t “happen at a time and place consistent with the obligations  and expectations of employment” [Decision No. 2014-0050, [2014] CanLII 1744 (AB WCAC), Jan. 20, 2014].