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Applying “In the Course of Employment”: Insights from WSIAT Decision No. 774/25

February 8, 2026 | Kelly Rodrigues, Solicitor, The Regional Municipality of Durham

In Decision No. 774/25, the Workplace Safety and Insurance Appeals Tribunal (the Tribunal) offered a practical application of the “in the course of employment” requirement under Policy 11‑01‑01 (Adjudicative Process) and Policy 15‑02‑02 (Accident in the Course of Employment). The decision highlights how location, timing, and the nature of a worker’s activity remain determinative factors in cases where an injury occurs off employer premises.

Background

The Worker, an Educational Assistant (EA), sustained multiple injuries on September 1, 2020, after tripping on publicly‑owned bleachers while returning from lunch during a PD workday. The WSIB denied initial entitlement, finding that the accident did not occur in the course of employment. The Worker appealed to the Tribunal.

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