Are Railroad Tracks Part of the Employer's Premises ?

In PPG Indus., Inc. v. Workmen's Compensation Appeal Board (Uleski), 116 Pa. Commw. 597, 542 A.2d 621 (Pa. Cmwlth. 1988), the claimant had finished his shift and picked up his car in the employer's parking lot. All employees leaving the parking lot had to cross a set of railroad tracks. The claimant was attempting to cross the tracks when his car was struck by an oncoming train. As a result, the claimant was severely injured. On appeal, we concluded that because the only means of entering and leaving the employer's parking lot was over the railroad tracks, the tracks were essentially a part of the employer's premises. Hence, the Court affirmed the decision that the claimant's injuries were compensable.