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OSHA 300 Recordkeeping - Policy

 City Risk LogoLoss Prevention

Risk Management, Portland, OR


   

                            Policy No. RMLP 23

                            Subject:  Record Keeping, Reporting and Occupational Survey

                            PREPARED BY:  Loss Prevention Team

   

 Contents

           

 Responsibilities:

 

Background

  1. The City of Portland is self-insured for Workers’ Compensation exposures. Under City Code 3.15.020 F, Office of Management and Finance (OMF) Risk Management (City Risk) is responsible to administer the program on behalf of all City bureaus.  Oregon Statutes and Administrative rules obligate the City, as the self-insured entity, to maintain loss prevention services for hazards in the workplace.   City Risk has the responsibility to:
    • Implement and monitor policies and procedures;
    • Provide loss prevention services; and
    • Provide program framework to ensure adequate implementation, monitoring and compliance of bureau specific policies, procedures and loss prevention programs for occupational safety and health.
  2. Federal and state statutes require employers, such as the City, to record and maintain records of employee work-related injuries and illnesses and report certain types of work-related injuries, illnesses, and fatalities to OSHA within specified time frames.
  3. The United States Bureau of Labor Statistics requires the City to participate annually in a national survey of occupational injuries, illnesses, and fatalities. The program provides information on the rate and number of these kinds of work-related events, and how statistics vary by such measures as incident, industry, geography, and occupation.

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Purpose  

  1. The purpose of this policy is to provide program framework to ensure City of Portland bureaus comply with applicable regulations, statutes, rules, and procedures related to the reporting and recordkeeping of work-related injuries and illnesses. This policy provides:
    • Strategic approaches and technical expertise to assist bureaus in complying with OSHA recordkeeping and reporting rules.
    • Guidance to bureaus regarding their responsibilities for accurate and timely compliance with recordkeeping and reporting requirements.
    • Clarification of City Risk’s obligation as the central unit for coordinating Citywide compliance with the Occupational Survey of Injuries, Illnesses, and Fatalities.
    • Demonstration of City Risk’s commitment to the OMF Strategic Plan goal of being good stewards of City assets.    

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Policy Statement 

  1. The City of Portland takes reasonable measures to comply with Oregon Administrative Rules for documenting injuries, illnesses and fatalities in the workplace.
  2. Documented cases will be processed in a timely manner and accurately posted to the appropriate OSHA 300 Logs by designated recordkeepers.
  3. Annually, the collected data from the 300 logs will be put into summary form and posted in areas conspicuous to employees.  The information on the summaries will correspond with the documented cases incurred at each location.
  4. Bureaus shall directly report work-related fatalities and catastrophes to Oregon OSHA within 8 hours of management having knowledge of any such event; and within 24 hours of having knowledge of any overnight hospitalizations.
  5. City Risk will notify and coordinate with bureaus selected by OSHA to participate in the Annual Survey of Occupational Injuries, Illnesses and Fatalities and submit the information in a timely manner.
  6. City Risk is designated to provide centralized oversight to ensure the City’s compliance with OSHA 300 Recordkeeping and Reporting.

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Scope

This policy applies to all City bureaus.

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Authority and Compliance 

  1. Authority is provided under:
    • City Code 3.54.020, F: Office of Management and Finance, Bureau of Internal Business Services, Risk Management Division
    • Oregon Administrative Rules, Chapter 437, Division 1, Rules for the Administration of Loss Prevention Activities by Insurers/Self-Insured Employers – General Requirements 437-001-1005 through 437-001-1020.
    • Oregon Administrative Rules, Chapter 437, Division 1, Self-Insured and Group Self-Insured Employer Loss Prevention Program, 437-001-1050 through 437-001-1060.
  2. This Policy is in compliance with:
    • Title 29 of the Code of the Federal Regulations (CFR) 1904 Recording and Reporting Occupational Injuries and Illnesses.
    • Oregon Administrative Rules, Chapter 437, Division 1,Recordkeeping and Reporting, 437-001-0700 through 437-001-0742.
    • Oregon Administrative Rules, Chapter 437, Division 1, Rules for All Workplaces 437-001-0760.

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Responsibilities

  1. City Risk:
    • Establishes and maintains City-wide policy, procedures and framework for compliance with:
      • OAR 437-001-0700 Recordkeeping and Reporting, and
      • 29 CFR 1904.41 Occupational Survey of Injuries & Illnesses;
      • Provides leadership and consultation to large City bureaus related to their management of recordkeeping and reporting requirements;
      • Provides consultation, leadership, facilitation, and services to smaller City bureaus as needed to ensure adequate resources and technical expertise are available for OSHA compliance;
      • Collects bureaus’ OSHA 300 Logs and 300A summaries for central recordkeeping;
      • Directs and coordinates affected bureaus in preparing and submitting annual reports of Occupational Injuries and Illnesses to OR OSHA; and
      • Monitors and communicates changes to the statutes, regulations, rules, and requirements.
  2. City Bureaus:
    • Establish and maintain bureau specific policies and procedures in compliance with:
    • Annually provide City Risk with copies of bureau 300 Logs, 300A Summaries and, if requested, Reports of Cases with Days Away, on or before January 15th, of the year following the year covered by the records; and
    • Coordinate with City Risk to resolve any evident errors or incomplete information in submitted recordkeeping documentation in a manner sufficient to meet the 300A Summary posting deadline of February 1 of the year following the year covered by the records.
  3. City Employees:
    • Comply with OSHA regulations;
    • Perform their work in accordance with their bureaus’ safe work practices and procedures, and make full use of safeguards provided for their protection;
    • Report all injuries immediately to the person to whom they report, their bureau safety representative, or a manager of their bureau.

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