he “going and coming rule” is that “injuries sustained while an employee is traveling to or from work do not occur in the course of employment and, consequently, are not compensable.” Krushwitz v. McDonald ’s Restaurants, 323 Or 520, 526 (1996). The theory underlying the rule is that, while a worker is traveling to or from work, the worker generally ‘“is rendering no service for the employer.’” Id. at 527 (quoting HeideflDarker v. T.C.I. Incorporated, 264 Or 535, 540 (1973).
The courts apply the going and coming rule broadly, “not only to injuries that occur before the workday begins and after it ends, but also when a claimant is injured while leaving the workplace for lunch or returning from a lunch break.” Enterprise Rent-A-Car Co. of Oregon v. Frazer, 252 Or App 726, 731 (2012), rev den, 353 Or 428 (2013) (Frazer I); accord, Frazer v.
Enterprise Rent-A~Car Co. of Oregon, 278 Or App 409, 412 (2016) (Frazer 11). Moreover, the courts apply the rule “when a claimant is injured while on a shorter break—-even a paid break—— away from work.” Id. (quoting Frazer I, 252 Or App at 731).
The courts have recognized several exceptions to the going and coming rule, which they generally interpret and apply narrowly. See Krushwitz, 323 Or at 528-29 (noting the court’s “traditionally narrow approach to applying the exceptions to the going and coming rule”); [Ziazfar v. SAIF, 160 Or App 116, 126 (1999) (same, citing Krushwitz).
These include the “parking lot” and “greater hazard” exceptions, the “employer conveyance” and “paid travel” exceptions, and the “special errand” exception, especially when the errand is specifically directed by the employer. See Fred Meyer, Inc. v. Hayes, 325 Or 592, 59798 (1997) (acknowledging the “parking lot” exception); Krushwitz, 323 Or at 529 (acknowledging the “special errand” and “geater hazard” exceptions); Beaudry v. SAIF, 288 Or App 139, 144 (2017) (acknowledging the “employer conveyance” exception); Kiewr‘t Pacific v. Ennis, 119 Or App 123, 128 n. l (1993) (acknowledging an exception for paid travel); Kevin M. Lyon, 54 VN 1397, 1400 (2002) (holding that an employer’s “specific direction” to the worker to take the worker’s personal toolbox home brought the activity within the “Special errand” exception).