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OSHA 300 Recordkeeping - Procedures

City Risk LogoLoss Prevention

Risk Management, Portland, OR






City of Portland

OSHA Recordkeeping Program




The City of Portland is self-insured for workers’ compensation exposures.  State statute and administrative rule obligates OMF Risk Management, (here after “City Risk”) to:

  1. Provide leadership and direction to City bureaus;
  2. Communicate compliance requirements;
  3. Establish citywide reporting framework;
  4. Provide consulting assistance;
  5. Collect, compile and process bureaus’ recordkeeping information; and,
  6. Direct and coordinate the City’s annual report of Occupational Injuries and Illnesses to OR OSHA.


The purpose of this document is to explain the procedures, division of duties and responsibilities between City Risk and City bureaus in administering the recordkeeping and reporting of occupational injuries and illnesses.

For Applicable Program Definitions See: Appendix 1


OSHA Recordkeeping & Reporting Administration and Services

Program Element


Procedure or Reference


City-wide Program Administration

City Risk

Develop, implement, administer and maintain City-wide OSHA 300 Recordkeeping in complia


nce with:

  • Oregon Administrative Rules, Chapter 437, Division 1:
  • Title 29 of the Code of the Federal Regulations (CFR) 1904 Recording and Reporting Occupational Injuries and Illnesses.
  • Collect and maintain copies of bureaus’ recordkeeping documents for central reporting purposes; and,
  • Direct and coordinate affected bureaus in preparing and submitting mandatory annual reports of Occupational Injuries and Illnesses to OR OSHA.


Bureau Specific Program Administration

City Bureaus

Develop, implement, administer and maintain bureau specific OSHA 300 Recordkeeping in compliance with:


Leadership and consultation to City Bureaus related to OSHA 300 Recordkeeping


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City Risk

  • Provide Loss Prevention Services specific to OSHA 300 Recordkeeping and Reporting,  including:
    • Consulting and technical expertise;
    • Recordkeeping tools and resources for recordkeepers;
    • Monitoring and communicating changes to the statutes, regulations, rules and requirements.


Reporting Injuries and Illnesses:

Program Element


Procedure or Reference

Reporting incidents to Oregon OSHA

Bureau Managers and Supervisors

Shall report the following to OR OSHA within the given time limits (click the link to view an OR OSHA contacts list):

  • A fatality within 8-hours of occurrence or employer knowledge of occurrence, including:
    • Fatality caused by heart attack at work
    • Motor vehicle collision that occurred during the employee’s work shift. Report a fatality only if it occurs within 30 days of the collision.
  • A catastrophe within 8-hours of occurrence or employer knowledge of occurrence. 
  • An overnight hospitalization within 24 hours of occurrence or employer knowledge of one or more employees. 

    • This requirement only applies to overnight hospitalization for medical treatment for work related injuries, heart attack and motor vehicle collisions while on the job.
    • Hospitalization for observation is not reportable, nor is emergency room treatment.

Incident Reporting and Investigation




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Bureau Managers, Supervisors and Safety Representatives

  • Establish and maintain an incident reporting system within their operations (click on the links to see example Incident Report 1 and Report 2);
  • Ensure prompt report of injury or illness made by an employee under the bureau’s supervision;
  • Investigate every lost time injury that workers suffer in connection with their work and determine loss prevention measure to prevent recurrence; and,
  • Forward a copy of a complete and accurate incident report to the bureau’s designated recordkeeper in a timely manner.

Documentation and Record Retention:

Program Element


Procedure or Reference

Keeping and maintaining OSHA 300 Log

Bureau/Location Designated Recordkeepers

  • Use Appendix 2:OSHA 300 Recordkeeping Forms or any equivalent bureau generated forms
    • to Maintain a 300 Log for each bureau location that operates for 1 year or longer, or
    • In a bureau’s central administrative office if all of the following can be met:
      • Transmit information about an injury or illness within 7 days of receiving information that the event occurred,
      • Produce and send records from the central location within the time frames specified under “Document Requests”.
  • Assign each bureau employee to a location for the purpose of OSHA 300 Recordkeeping.
  • Record injuries and illnesses by location. If an employee is injured or becomes ill at a location other than one owned or controlled by the City of Portland, record the injury to the location where the employee is assigned.
  • Record injuries and illnesses to:
    • All employees on the bureau’s payroll,
    • Workers not on the bureau’s payroll but supervised by a bureau supervisor or manager on a day-to-day basis, such as:
      • Employees of temporary service providers.
      • A contractor’s employee if the employee is not under the day-to-day supervision of the contractor.

Note:  Coordinate with contractors and temporary service providers as necessary to ensure that a case is only recorded to one log.

  • Enter incidents on the 300 Log within 7 calendar days of bureau management receiving information that a recordable injury or illness has occurred.  Bureaus are responsible for meeting the 7-day posting deadline.

Recording Privacy Cases

Bureau/Location Designated Recordkeepers

Keep sensitive injuries and illnesses confidential. Record these types of incidents on a separate privacy log (click on the following link for an example Privacy Log).

  • On the 300 Log, enter “Privacy Case Concern” where the employee’s name would be written.
  • Recordkeepers must use discretion; if the identity of a privacy concern case may be recognizable even though the employee’s name is omitted, provide only enough information to identify the cause and general severity of the injury or illness. Do not provide details of an intimate or private nature on the 300 Log. 
  • Examples of injuries and illnesses that are privacy concern cases are provided in Appendix 3.

Recording Medical Removal of an Employee

Bureau/Location Designated Recordkeepers,

  • Record a case on the 300 Log if another OR-OSHA standard requires the medical removal of an employee:
    • Recorded the case as either a case involving days away from work or a case involving restricted work activity. 
    • Check the “poisoning column” if a medical removal results from a chemical exposure.
  • Do not record an incident involving a voluntary medical removal that occurs before reaching the medical removal levels required by an OR-OSHA standard.

Recording cases of Occupational Hearing Loss

Bureau/Location Recordkeepers,

  • Record a hearing loss case by checking the hearing loss column when:
    • An annual audiogram reveals a Standard Threshold Shift (STS) in either or both ears; and
    • The hearing level in the same ear is 25 dB above audiometric zero.
  • In determining whether an STS has occurred, recordkeepers may elect to correct for the age of the employee using information provided in Appendix 4.
  • Do not record an STS if: 

    • If the STS is less than 10 dB after the age correction,
    • If a retest is conducted within 30 days of the first test and the retest does not confirm a recordable STS,
    • If a physician or other licensed health care professional determines that the hearing loss is not work-related or has not been significantly aggravated by exposure to work-related noise.

Recording Cases of Tuberculosis

Bureau/Location Recordkeepers,

  • Record a case of tuberculosis (TB) if an employee was exposed to a known case of active TB and the employee subsequently develops a TB infection as evidenced by a positive skin test or diagnosis by a physician or other licensed health care professional.
  • Record the case on the Log by checking the “respiratory condition” column.
  • Do not record a pre-employment positive skin test.
  • Line-out or erase a recorded case of TB if it’s later found that:
    • The employee lives with a person diagnosed with active TB;
    • The Public Health Department identifies the employee as a contact of an individual with a case of active TB unrelated to the workplace;
    • A medical investigation shows that the employee’s infection was caused by exposure to TB away from work or otherwise proves that the case is not related to workplace TB exposure.

Completing and Posting OSHA 300A Summaries

Bureau/Location Designated Recordkeepers, accounting personnel and executive management

  • Annually, prepare the 300A Summary using the 300 Log and retrieving employment information from the bureau’s accounting division.
  • Complete a Summary for each 300 Log the bureau keeps, along with information specific to the corresponding location.
  • Ensure that the Summary is certified as complete and accurate and signed by an appropriate bureau executive.
  • Post the Summary:
    • By February 1 of the year following the year covered by the record;
    • In areas conspicuous to employees;
    • Ensure that the Summary remains legible for the duration the required posting period; and
    • The Summary may be taken down after April 30 of the year following the year covered by the document.

Submission of mandatory Annual Report of Occupational Injuries, Illnesses and Fatalities

Bureau/Location Designated Recordkeepers or Safety Representatives and

City Risk

  • Participate in the mandatory survey of Occupational Injuries and Illnesses (see CFR 1904.41) if any of the bureau’s locations is selected by Oregon OSHA for the survey;
  • City Risk is OR OSHA’s designated recipient of the Survey request form(s) and shall notify the affected bureaus of their selection to participate.  Bureaus may be required to fill out a single location report form, participate in generating a multi-bureau location report form, or both:
    • If the named location is occupied by a single bureau, the bureau shall promptly complete and return the report form provided to by City Risk, and
    • If the named location is occupied by two or more bureaus, the affected bureaus’ shall promptly provide all information requested by City Risk.  City Risk will compile the affected bureaus’ information, complete and submit the report to OR OSHA

Document Updates and Retention







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Bureaus/Location Designated Recordkeepers or Safety Representatives

  • Retain incident reports of injury or illness for 5 years after occurrence.
  • Retain OSHA 300 Logs and 300 A Summaries of each location for 5-years following the end of the year covered by the record,
  • Update OSHA 300 Logs during the retention period to include newly discovered recordable injuries or illnesses and to show any changes that have occurred in the classification of previously recorded injuries and illness. 
    • Remove or line-out an original entry and enter new information if the description or outcome of a case changes.

City Risk

  • Shall retain reports of Occupational Injuries and Illnesses and completed Cases with Days for 5-years following the end of the year covered by the Report.

Document Requests

Program Element


Procedure or Reference

Access to Records for employees, former employees, and personal representatives


  • By end of the next business day of receiving a request from an employee, a former employee or an employee’s personal representative for:
    • A copy of the relevant OSHA 300 Log. The names must remain on the 300 Log. However, any privacy concern cases on the log must not include the injured employee’s name and the corresponding Privacy Log must not be released.
    • A copy of the relevant DCBS Form 801 or its equivalent form that describes an injury or illness to that employee or former employee.

Access to Records authorized employee representatives


  • Within 7 calendar days of receiving a request from an authorized employee representativeor its agent for:
    • A copy of the relevant DCBS Form 801 or its equivalent for a location. Only include information from the releasable part of the DCBS Form 801 or its equivalent section titled “Tell us about the case” or similar section; all other information must be removed before releasing the document.

Providing copies of requested records to an Authorized Government Representative


Provide copies of requested records to City Risk




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  • Within a timely manner for any records City Risk requests that are necessary to perform its duties and obligations under:
    • Annual reporting required of participants in the Occupational Survey of Injuries and Illnesses.
  • To meet any compliance requirement that may be made to City Risk as the City’s administrator of the self-insured program.

Employee Training

Program Element


Procedure or Reference

Incident Reports










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  • Provide training to each employee about how they are to report injuries or illnesses within their respective bureaus.  The training should be specific to each bureau’s structure and operations.
  • Provide training to supervisors and managers including their duties and responsibilities:
    • Within the bureau’s system for reporting injuries and illnesses,
    • Within the bureau’s system for investigating incidents of injuries and illnesses and ensuring complete and accurate information on incident report forms, and
    • Preserving and marking for identification materials, tools or equipment necessary for proper investigation of an incident.
    • The training should be specific to each bureau’s structure and operations.
  • Provide training to designated recordkeepers including:

    • The Bureau’s system for reporting injuries and illnesses and the recordkeeper’s duties within the reporting system;
    • Recordkeeping Requirements and the recordkeeper’s responsibilities and duties for keeping, maintaining, providing and reporting applicable information and documents.

  • NOTE: Free online training for OSHA Recordkeeping is available through OR OSHA

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