Personal Comfort Doctrine

The personal comfort doctrine aids a court in determining whether, and under what circumstances, entirely personal activities engaged in by an employee at work may be considered incidental to employment. Osteen v. Greenville County Sch. Dist., 333 S.C. 43, 508 S.E.2d 21 (1998). The doctrine provides "such acts as are necessary to the life, comfort, and convenience of the servant while at work, though strictly personal to himself, and not acts of service, are incidental to the service, and injury sustained in the performance thereof is deemed to have arisen out of the employment." Id. at 46, 508 S.E.2d at 23 (quoting Mack v. Post Exchange, 207 S.C. 258, 264-65, 35 S.E.2d 838, 840 (1945)). In Osteen v. Greenville County Sch. Dist, the Court significantly narrowed the application of the personal comfort doctrine, finding it "has consistently been limited to imperative acts such as eating, drinking, smoking, seeking relief from discomfort, preparing to begin or quit work, and resting or sleeping." 333 S.C. at 47-48, 508 S.E.2d at 23