By: HUB's Absence Management Team

Overview

On April 10, 2025, Oregon Governor Tina Kotek signed Senate Bill 1108 into law, expanding Oregon’s earned sick time law to include blood donation as a covered reason. The additional covered reason is effective as of January 1, 2026. This update outlines the bill's impact on employer obligations and provides guidance for compliance.

Key Provisions of Oregon SB 1108

Blood Donation Leave Entitlement

New requirement:

SB 1108 adds blood donation as a covered reason for using accrued sick time under Oregon’s earned sick time law. Employees may use up to four hours of their accrued sick time for this purpose each calendar year. If accrued sick time is available, blood donation leave must be paid in accordance with Oregon’s earned sick time law.

Leave Usage Rules

Specific requirements:

  • Leave must be taken in hourly increments
  • Leave may only be used for actual blood donation, not for related activities such as scheduling or travel time
  • Donations must be made to a voluntary program approved by the American Association of Blood Banks or the American Red Cross

Notice and Documentation

Employer rights:

  • Employers may require employees to provide up to 14 days’ advance notice of intended blood donation
  • Employers may request certification confirming the blood donation appointment and/or completion of donation
  • Documentation requirements must be reasonable and not create an undue burden

Anti-Retaliation Provisions

Employee protections:

  • Employers are prohibited from denying an employee's request for blood donation leave if requirements are met
  • Retaliating against an employee for requesting or taking blood donation leave is unlawful
  • Prohibited actions include discrimination, discipline, discharge, or counting the leave as an absence under attendance policies

Next Steps for Employers

Pre-Implementation Activities (By December 31, 2025)

  • Finalize Written Policies: Create or update existing leave policies to include:
    • Leave entitlement (4 hours per calendar year)
    • Procedure for requesting leave
    • Documentation requirements
    • Anti-retaliation provisions
  • Train HR Personnel and Managers: Educate your team on:
    • New leave entitlement
    • Appropriate and inappropriate reasons for denial
    • Documentation that may be requested
    • Prohibition against retaliation
  • Develop Notice Templates: Create forms for:
    • Employee requests for blood donation leave
    • Certification of donation if required
  • Update Timekeeping Systems: Ensure systems can track blood donation leave separately from other leave types

Post-Implementation Activities (January 2026 onward)

  • Communicate to Employees: Distribute blood donation leave policy to all employees
  • Post Notices: Consider posting information about the new leave entitlement in common areas
  • Monitor Compliance: Conduct regular audits of your leave administration processes
  • Document Everything: Maintain thorough records of leave requests, approvals, and denials
  • Stay Informed: Watch for regulatory guidance or clarifications from the Oregon Bureau of Labor and Industries

Additional Considerations

  • This leave requirement applies to all Oregon employers regardless of size
  • Consider partnering with blood donation organizations to host on-site donation events, which may reduce productivity disruption
  • Multi-state employers should review how this law interacts with similar laws in other states
  • Review absence control policies to ensure blood donation leave is not counted as an absence

Additional Resources

For more information regarding Oregon SB 1108 and blood donation leave requirements, visit:

If you have any questions, please contact your HUB Advisor. We will continue to monitor and provide updates as more information becomes available. View more Workforce Absence Management updates in our WAM Bulletins page.

Notice of Disclaimer

Neither Hub International Limited nor any of its affiliated companies is a law or accounting firm, and therefore they cannot provide legal or tax advice. The information herein is provided for general information only and is not intended to constitute legal or tax advice as to an organization’s specific circumstances. You should consult an attorney, accountant, or other legal or tax professional regarding the application of the general information provided here to your organization’s specific situation in light of your organization’s particular needs.