In emergency situations, prompt, properly administered first aid can mean the difference between life and death, rapid versus prolonged recovery, or temporary versus permanent disability. Safety comes first, but when accidents do happen, it is important to have someone who knows how to handle the situation effectively. It is important for employees to know what to do and what not to do in an emergency. If the person who encounters an emergency situation is not qualified, they should quickly get someone is. Also, employees should know where the first-aid kits and emergency eyewash stations are located before an incident occurs. They should also understand and follow the universal precautions when dealing with blood.
First-aid supplies and treatment requirements
- OSHA has specific requirements for first-aid supplies and medical services at the workplace.
- When an injury or illness occurs, a maximum response time of 15 minutes is currently recognized by OSHA as appropriate for most cases.
- The company EAP should outline everything employees need to know in the event of an emergency.
First-aid supplies and other medical services must be available at the workplace.
The minimum Occupational Safety and Health Administration (OSHA) requirements are:
- Medical personnel must be available for advice on occupational health matters.
- Prior to the start of a project, provisions must be made for prompt medical attention in case of serious injury.
- An infirmary, clinic, hospital, or physician must be nearby; or someone trained in first aid must be available at the worksite.
- First-aid supplies must be easily accessible.
- There must be an available means to transport an injured person to a physician or hospital.
- If 911 service is not available, the emergency numbers for physicians, hospitals, and ambulances must be posted.
On-site medical treatment — When an injury or illness occurs, the maximum response time is 15 minutes. This is currently recognized by OSHA as appropriate for most cases.
However, conditions at each workplace must be considered when developing the first-aid program. This is to ensure that 15 minutes is adequate to meet all needs. Where a medical facility is near the workplace, OSHA rules require the employer to ensure the following:
- In areas where accidents resulting in suffocation, severe bleeding, or other life-threatening injuries or illnesses can be expected, a three to four minute response time is required.
- In other circumstances, for instance where a life-threatening injury is an unlikely outcome of an accident, a longer response time of up to 15 minutes is acceptable.
- If work is conducted in areas where emergency transportation is not available, the company must provide acceptable transportation. If arrangements cannot be made to provide emergency medical service within an appropriate timeframe, then a person trained in first aid must be available for each shift.
Eyewash/Drenching stations — Where workers may be exposed to injurious corrosive materials, suitable eyewash/drenching stations must be available at the jobsite.
Review the company’s Emergency Action Plan (EAP) for first aid and medical services. The EAP should outline everything employees need to know to get help during a medical emergency.
Assessment
- It is important to plan ahead to be prepared for emergencies by obtaining EMS response times for all locations.
- When planning a first-aid program, obtaining and evaluating information about injuries, illnesses, and fatalities at the worksite are essential first steps.
- When outside professionals cannot respond within the required response time for the expected types of injuries, OSHA requires that a person or persons within the facility shall be adequately trained to render first aid.
When planning a first-aid program, obtaining and evaluating information about injuries, illnesses, and fatalities at the worksite are essential first steps.
Where accidents resulting in suffocation, severe bleeding, or other life threatening or permanently disabling injury or illness can be expected, or where there are corrosive materials, a three to four minute response time, from time of injury to time of administering first aid, is required.
The employer should obtain estimates of Emergency Medical Services (EMS) response times for all locations and for all times of the day and night that workers will be present. The Occupational Safety and Health Administration (OSHA) has consistently taken the view that the reasonable availability of a trained emergency service provider, such as fire department paramedics or Emergency Medical Services (EMS) responders, is equivalent to the “infirmary, clinic, or hospital” specified by the literal wording of the standards. EMS can be provided either on-site or by evacuating the employee to an off-site facility in cases where that can be done safely.
An employer who contemplates relying on assistance from outside emergency responders as an alternative to providing a first aid-trained employee must take appropriate steps prior to any accident—such as making arrangements with the service provider—to ascertain that emergency medical assistance will be promptly available when an injury occurs.
When outside professionals cannot respond within the required response time for the expected types of injuries, a person or persons within the facility shall be adequately trained to render first aid. OSHA recognizes that a somewhat longer response time of up to 15 minutes may be reasonable in workplaces, such as offices, where the possibility of such serious work-related injuries is more remote.
The person who has been trained to render first aid must be able to quickly access the first-aid supplies in order to effectively provide injured or ill employees with first-aid attention.
If employees work in areas where public emergency transportation is not available, the employer must make provision for acceptable emergency transportation.
Training
- Several OSHA regulations require first-aid training.
- OSHA says that first-aid courses should be individualized to the needs of the workplace, and the agency offers a list of principles and topics that should be in a first-aid training program.
- Assessment of successful completion of first-aid training should include instructor observation of acquired skills and written performance assessments.
- Instructor-lead retraining for life-threatening emergencies should occur at least annually, according to OSHA, but skills review and practice for CPR and AED skills is suggested every six months.
Sudden injuries or illnesses, some of which may be life-threatening, occur at work. The Occupational Safety and Health Administration (OSHA) Medical Services and First Aid standard at 29 CFR 1910.151 requires trained first-aid providers at all workplaces of any size if there is no “infirmary, clinic, or hospital in near proximity to the workplace which is used for the treatment of all injured employees.”
The standard does not require an employer to designate any employee to render first aid. As presently worded, the standard does not explicitly require that an employee or employees be both trained AND required by the employer to render first aid. OSHA has chosen to interpret the standard as imposing a training requirement but not a designation requirement. Refer to the May 25, 2004, OSHA letter of interpretation for more information.
In addition to first-aid requirements of 1910.151, several OSHA standards require training in cardiopulmonary resuscitation (CPR) because sudden cardiac arrest from asphyxiation, electrocution, or exertion may occur. CPR may keep the victim alive until emergency medical services arrive to provide the next level of medical care. The OSHA standards requiring CPR training are:
- 1910.146 — Permit-required confined spaces;
- 1910.266 Appendix B — Logging operations – First-aid and CPR training (mandatory);
- 1910.269 — Electric power generation, transmission, and distribution; and
- 1910.410 — Qualifications of dive team.
If an employee is expected to render first aid as part of his or her job duties, the employee is covered by the requirements of the Bloodborne Pathogens standard (1910.1030). This standard also includes specific training requirements.
First-aid training trogram
Training for first aid is offered by nationally recognized and private educational organizations. OSHA does not teach first-aid courses or certify first-aid training courses for instructors or trainees.
OSHA says that first-aid courses should be individualized to the needs of the workplace. Some of the noted program elements may be optional for a particular plant or facility. On the other hand, unique conditions at a specific worksite may necessitate the addition of customized elements to a first-aid training program.
Training programs should incorporate the following principles:
- Basing the curriculum on a consensus of scientific evidence where available;
- Having trainees develop “hands-on” skills through the use of mannequins and partner practice;
- Having appropriate first-aid supplies and equipment available;
- Exposing trainees to acute injury and illness settings as well as to the appropriate response through the use of visual aids;
- Including a course information resource for reference both during and after training;
- Allowing enough time for emphasis on commonly occurring situations;
- Emphasizing skills training and confidence-building over classroom lectures; and
- Emphasizing quick response to first-aid situations.
First-aid training program topics
The training program should include instruction or discussion in the following:
- Preparing to respond to a health emergency:
- Prevention as a strategy in reducing fatalities, illnesses, and injuries;
- Interacting with the local emergency medical services (EMS) system;
- Maintaining a current list of emergency telephone numbers (police, fire, ambulance, and poison control) accessible by all employees;
- Understanding the legal aspects of providing first-aid care, including Good Samaritan legislation, consent, abandonment, negligence, assault and battery, and state laws and regulations;
- Understanding the effects of stress, fear of infection, and panic; how they interfere with performance; and what to do to overcome these barriers to action; and
- Learning the importance of universal precautions and body substance isolation to provide protection from bloodborne pathogens and other potentially infectious materials. Learning about personal protective equipment (gloves, eye protection, masks, and respiratory barrier devices) and appropriate management and disposal of blood-contaminated sharps and surfaces. Having an awareness of OSHA’s Bloodborne Pathogens standard.
- Assessing the scene and the victim(s):
- Assessing the scene for safety, number of injured, and nature of the event;
- Assessing the toxic potential of the environment and the need for respiratory protection;
- Establishing the presence of a confined space and the need for respiratory protection and specialized training to perform a rescue;
- Prioritizing care when there are several injured;
- Assessing each victim for responsiveness, airway blockage, breathing, circulation, and medical alert tags;
- Taking a victim’s history at the scene, including determining the mechanism of injury;
- Performing a logical head-to-toe check for injuries;
- Stressing the need to continuously monitor the victim;
- Emphasizing early activation of EMS;
- Knowing the indications for and methods of safely moving and rescuing victims; and
- Repositioning ill/injured victims to prevent further injury.
- Responding to life-threatening emergencies:
- Establishing responsiveness;
- Establishing and maintaining an open and clear airway;
- Performing rescue breathing;
- Treating airway obstruction in a conscious victim;
- Performing CPR;
- Using an automated external defibrillator (AED);
- Recognizing the signs and symptoms of shock and providing first aid for shock due to illness or injury;
- Assessing and treating a victim who has an unexplained change in level of consciousness or sudden illness;
- Controlling bleeding with direct pressure;
- Poisoning:
- Ingested poisons (alkali, acid, and systemic poisons) and role of the Poison Control Center (1-800-222-1222);
- Inhaled poisons (carbon monoxide; hydrogen sulfide; smoke; and other chemical fumes, vapors, and gases) and assessing the toxic potential of the environment and the need for respirators;
- Knowledge of the chemicals at the worksite and of first aid and treatment for inhalation or ingestion; and
- Effects of alcohol and illicit drugs so that the first-aid provider can recognize the physiologic and behavioral effects of these substances; and
- Recognizing asphyxiation and the danger of entering a confined space without appropriate respiratory protection (additional training is required if first-aid personnel will assist in the rescue from the confined space).
- Responding to medical emergencies:
- Chest pain,
- Stroke,
- Breathing problems,
- Anaphylactic reaction,
- Hypoglycemia in diabetics taking insulin,
- Seizures,
- Pregnancy complications,
- Abdominal injury,
- Reduced level of consciousness, and
- Impaled object.
- Responding to non-life-threatening emergencies:
- Wounds:
- Assessment and first aid for wounds including abrasions, cuts, lacerations, punctures, avulsions, amputations, and crush injuries;
- Principles of wound care, including infection precautions; and
- Principles of body substance isolation, universal precautions, and use of personal protective equipment.
- Burns:
- Assessing the severity of a burn;
- Recognizing whether a burn is thermal, electrical, or chemical and the appropriate first aid; and
- Reviewing corrosive chemicals at a specific worksite, along with appropriate first aid.
- Temperature extremes:
- Exposure to cold, including frostbite and hypothermia; and
- Exposure to heat, including heat cramps, heat exhaustion, and heat stroke.
- Musculoskeletal injuries:
- Fractures;
- Sprains, strains, contusions, and cramps;
- Head, neck, back, and spinal injuries; and
- Appropriate handling of amputated body parts.
- Eye injuries:
- First aid for eye injuries; and
- First aid for chemical burns.
- Mouth and teeth injuries:
- Oral injuries, lip and tongue injuries, and broken and missing teeth; and
- The importance of preventing aspiration of blood and/or teeth.
- Bites and stings:
- Human and animal bites; and
- Bites and stings from insects and instruction in first-aid treatment of anaphylactic shock.
First-aid training assessments and updates
Assessment of successful completion of the first-aid training program should include instructor observation of acquired skills and written performance assessments.
First-aid responders may have long intervals between learning and using CPR and AED skills. Numerous studies have shown a retention rate of six to twelve months of these critical skills. OSHA says it is encouraged that a skills review and practice sessions occur at least every six months for CPR and AED skills. Instructor-led retraining for life-threatening emergencies should occur at least annually, according to the agency. Retraining for non-life-threatening response should occur periodically.
Cardiopulmonary resuscitation (CPR)
- OSHA recommends CPR be a part of a company’s first-aid program, but it is not a requirement except for certain industries.
- OSHA requires a first-aid program for logging operations, permit-required confined spaces, and electric power generation, transmission, and distribution.
- If a company does not plan to designate employees as first-aid responders, then OSHA would recommend that employees who participate in company-provided first-aid training should be made aware of the company’s plan for addressing all workplace medical emergencies.
Is it acceptable for the employer to provide training on first aid, including cardiopulmonary resuscitation (CPR), as well as first-aid supplies, to employees who are not officially responsible for performing first aid, including CPR, and who would be responding on a voluntary basis?
Section 29 CFR 1910.151(b) does not prohibit employers from providing first aid training to employees, even when the employees will not be expected to respond in workplace emergencies. However, if the company does not plan to designate employees as first-aid responders, then OSHA would recommend that employees who participate in company-provided first-aid training should be made aware of the company’s plan for addressing all workplace medical emergencies.
Must an employer have personnel trained in CPR?
OSHA recommends that CPR training be part of a first-aid program, but it is not a requirement. However, some OSHA standards (e.g., logging operations (1910.266); permit-required confined spaces (1910.146); and electric power generation, transmission, and distribution (1910.269), require employees be trained in first aid and CPR. If an employer is covered by one of these specific standards, CPR training would be required.
Supplies
- OSHA requires that first-aid supplies be adequate, reflect the kinds of injuries that occur, and must be stored in an area where they are readily available for emergency access.
- ANSI standards outline the minimum quantities and sizes of required first-aid supplies.
Occupational Safety and Health Administration (OSHA) standards indicate that first-aid supplies must be adequate, should reflect the kinds of injuries that occur, and must be stored in an area where they are readily available for emergency access. While the agency doesn’t specifically prescribe first-aid kit contents, specific examples of the minimum supply requirements are described in American National Standards Institute (ANSI)/International Safety Equipment Association standard (ISEA) Z308.1, “Minimum Requirements for Workplace first-aid Kits.”
Required supplies
The ANSI Z308.1 standard outlines the minimum quantities and sizes of required supplies. The most current edition of the industry standard divides kits into two classes, based on the assortment and quantity of first-aid supplies. Class A kits are designed to deal with the most common workplace injuries, such as minor cuts, abrasions, and sprains. Class B kits include a broader range and quantity of supplies to deal with injuries in more complex or high-risk environments. Kits are also designated by Type (I, II, III or IV) depending on the work environment, e.g., Type 1 kits will be used indoors and be permanently mounted, whereas Type IV kits will be suitable for outdoor use. This standard and its contents are copyrighted by ISEA.
Recommended supplies
In addition to reviewing the most current edition of ANSI Z308.1, employers can consult their local fire or rescue department, medical professional, or emergency room for first-aid kit recommendations.
What supplies must be in a first-aid kit?
OSHA 1910.151(b) requires that “adequate first-aid supplies shall be readily available.” The agency does not and cannot define what constitutes “adequate” since the needs of each workplace will be unique. However, in Appendix A to 1910.151, OSHA says that “by assessing the specific needs of their workplace, employers can ensure that reasonably anticipated supplies are available.” OSHA further requires at 1910.151(a), that an employer have a medical professional to advise on matters of plant health, such as what first-aid supplies should be available.
OSHA’s First Aid Handbook states that workplace first-aid supplies “must be adequate, should reflect the kinds of injuries that occur, and must be stored in an area where they are readily available for emergency access.” This is supported by a February 2, 2007, Letter of Interpretation which says that “employers are required to provide first-aid supplies that are most appropriate to respond to incidents at their workplaces. OSHA allows employers to provide first-aid supplies specific to the needs of their workplace.”
OSHA also refers employers to ANSI/ISEA Z308.1-2021, “Minimum Requirement for Workplace First Aid Kits and Supplies.” The standard categorizes first-aid kits into two classes, depending on the assortment and quantity of the supplies contained as follows:
- Class A — Designed for the most common workplace injuries such as minor cuts, sprains, and abrasions.
- Class B — Designed to be equipped with supplies to deal with injuries encountered in more complex or high-risk environments.
Minimum quantities and sizes of required supplies are outlined for both classes of kits. This would include (but is not limited to) scissors, absorbent compresses, adhesive bandages and tape, antibiotic treatment, antiseptic, sterile pads, cold packs, oral analgesics, etc. A splint and a tourniquet are also required for a Class B first-aid kit.
Kits are also designated by type (I, II, III, or IV) depending on the work environment and intended use, e.g., Type I kits will be used indoors and be permanently mounted, whereas Type IV kits will be suitable for outdoor use.
Are over-the-counter (OTC) medications permitted as a first-aid supply?
OSHA neither encourages nor discourages employers from dispensing OTC medications to employees. According to ANSI/ISEA Z308.1-2021, a basic workplace first-aid kit may include oral analgesics packaged in single dose, tamper evident packaging, with full labeling. However, employers should consult their legal professional as state law and relevant state court cases may impact an employer’s decision. Due to risk concerns, some employers make certain OTC medications available through a vending machine.
Do expired supplies need to be replaced?
At 1910.151(b) OSHA states only that “adequate first-aid supplies shall be readily available.” However, ANSI/ISEA Z308.1-2021 says that expiration dates of supplies in kits should be regularly inspected. If an expired supply is found, ANSI recommends that it be removed from the kit and replaced.
Location
- OSHA does not specify the placement of first-aid kits based on employee numbers, density or geography.
- First-aid kits should not be stored in employee break areas.
- The location of first-aid kits, supplies, or cabinets and rooms should be clearly marked
The Occupational Safety and Health Administration (OSHA) does not specify the placement of first-aid kits and/or cabinets based on employee numbers, density, or geography. OSHA does state that supplies must be “readily available.” In a Letter of Interpretation dated April 18, 2002, “readily available” is defined as a three to four minute response time.
Do not store first-aid kits or supplies in areas which are used as break areas by employees. This includes supervisors’ offices. OSHA has cited companies because medical supplies were located in the same room that employees ate or drank in. This violates 1910.1030(d)(2)(ix) which prohibits eating, drinking, smoking, applying cosmetics or lip balm, and handling contact lenses where there is a possibility of exposure to bloodborne pathogens.
Some OSHA standards do address location/placement requirements for first-aid kits, e.g., for telecommunication, logging, and diving operations.
The standard does not specify whether first-aid supplies may be locked up or not. The standard does require first-aid supplies be “readily available.” OSHA says the employer can take “positive control measures” for first-aid supplies as long as supplies are at hand, ready for use, and can be obtained easily and quickly.
Posting
The location of first-aid kits, supplies, or cabinets and rooms should be clearly marked using prominent signs and labels so that employees can quickly find them in an emergency.
Recordkeeping and plan requirements
- A written first-aid program outlines the plan, purpose, administrative duties, designated first-aid personnel, and more.
- All injuries and illnesses that result in medical treatment must be recorded in OSHA 300 logs.
- OSHA recommends that an emergency response plan include preparing for active shooter incidents, such as shelter-in-place and evacuation procedures.
Recordkeeping
Record on the Occupational Safety and Health Administration (OSHA) 300 logs all injuries/illnesses that result in medical treatment beyond first aid. See OSHA’s 1904.7(b)(5)(ii) for a definition of first aid for recordkeeping purposes.
Plan
The following is an example of what should be included in a First-Aid Program.
Purpose
The First-Aid Program should describe the purpose of the program and ensure that the company first aid program meets OSHA’s requirements at 1910.151, Medical Services and First Aid.
Administrative duties
The First-Aid Program should identify a First-Aid Program Administrator that is responsible for establishing and implementing the First-Aid Program. This person has full authority to make necessary decisions to ensure the success of the program.
Designated first-aid personnel
The First-Aid Program should identify first-aid personnel that are readily available for advice and consultation on health matters.
The National Emergency Medical Service (EMS) Education and Practice Blueprint lists the following first-aid designations:
- First-aid provider: Occupationally required to be trained in first aid even though they may not be specifically obligated by law to perform first aid. Responds as a “Good Samaritan.” Uses a limited amount of equipment to perform an initial assessment and provide immediate life support and care while awaiting the arrival of emergency medical services (EMS).
- First responder: Uses a limited amount of equipment to perform initial assessment and intervention and is trained to assist other EMS.
- Emergency medical technician (EMT)-Basic: The second level of professional emergency medical care provider. Qualified to function as the minimum staff for an ambulance.
- EMT-Intermediate: The third level of professional emergency medical care provider. Can perform essential advanced techniques and administer a limited number of medications.
- Paramedic: The fourth level of professional emergency medical care provider. Can administer additional interventions and medications.
Keep a list of the people trained and responsible for rendering first aid at the facility. The list should include their name, title, first-aid designation, department, phone number, and their responsibilities and roles.
Hazard and medical services assessment
Assess the job location for hazards to determine whether any pose the risk of a life-threatening or permanently disabling injury or illness. Keep a list of the types of injuries or illnesses that are likely to occur and the department they are likely to occur in.
Document the name and location of the nearest hospital or clinic. A facility is considered in “near proximity” if it is within 3-4 minutes away.
When hazards or locations change, determine who will reassess the risks and decide whether on-site employee(s) must be trained in first aid.
First-aid supplies and equipment
First-aid supplies and equipment must meet the specific needs of the company’s operations and hazard risks.
Determine who is responsible for ensuring that adequate first-aid supplies are readily available and keep a list of first-aid supplies.
Determine what facility the supplies are kept at and their location.
Determine who is responsible for ensuring the first-aid supplies are adequate and supplies are replaced promptly when expended.
Determine what the first-aid program should include. If the facility has injurious corrosive materials, it must have drenching and flushing equipment that meet the specifications of American National Standards Institute (ANSI) Z358.1.
Determine the location that emergency eyewash and shower equipment is installed at.
Designated employees who respond to emergencies or clean up after them have the potential for exposure to blood and body fluids. For their safety and protection, determine what personal protective equipment will need to be provided.
Posting
To help those responding to a medical emergency, post signs directing personnel to emergency equipment and supplies. Document the signs you have posted, their message and their location.
Training
Training is the heart of First-Aid Programs. Employees must not attempt to rescue or treat an injured or ill employee unless they are trained and qualified to do so. Employees are trained to contact a designated qualified individual.
Employees who are trained and qualified to render first aid have completed a first-aid training program. Determine who is responsible for conducting training and what their qualifications include. Determine the frequency of the first-aid training and a description of what the training program includes.
Training certification
After an employee has completed the training program, determine who will certify that the employee can successfully render first aid. An individual responsible for keeping records verifying certification of employees who have completed training should be appointed.
Each certificate should include the name of the employee, the date(s) of the training, and the signature of the person who performed the training and evaluation.
Retraining
Trained employees should receive refresher training frequently to keep their skills and certification current.
First-aid procedures
Document what the workplace first-aid procedures include.
Accident reporting
Employees should be trained to report all injuries and illnesses to management, including first-aid cases and near-miss events. Injuries and illnesses involving a fatality, medical treatment, days away from work, or job transfer, must be reported to the employee’s supervisor immediately.
Recordkeeping
Designate an individual that is responsible for maintaining records relating to the company’s first aid, injury, illness, and accidents cases.
Program evaluation
Ensure the First-Aid Program is effective by thoroughly evaluating and revising the program as necessary. Determine the frequency the evaluation is performed and what evaluation elements should be included.
Active shooter response
In a letter of interpretation dated June 19, 2019, OSHA responded to a question about response times for life-threatening bleeding, including active shooter situations. OSHA reiterated its policy of 3-4 minutes, noting that these are maximums and that shorter response times are encouraged.
OSHA recommends that an emergency response plan include preparing for active shooter incidents, such as shelter-in-place and evacuation procedures. The agency noted that during an active shooter incident and evacuation, employees who voluntarily choose to stay behind to assist the wounded would be considered acting as “Good Samaritans.” OSHA also noted that its standards apply only to employees and not to non-employee bystanders.
Finally, OSHA said that a response time of less than three minutes would likely require onsite trained first-aid employees at every work site. OSHA recommends, but does not require, that every workplace include one or more employees who are trained and certified in first aid, including CPR.
First-aid kit supplies and inspections
- First-aid kits should be regularly inspected to ensure completeness, condition of supplies, and expiration dates to maintain compliance.
- OSHA standards require first-aid supplies to be always available regardless of how often employers inspect first-aid kits.
- The amount of first-aid kits should be based on several factors including the size of the workplace, number of employees, likelihood and location of possible accidents
Inspections
How often do first-aid kits need to be inspected?
The American National Standards Institute (ANSI)/International Safety Equipment Association standard (ISEA) Z308.1-2021 standard states that first-aid kits should be regularly inspected to ensure completeness, condition of supplies, and expiration dates to maintain compliance. Expired supplies should be removed, and additional quantities should be added as needed.
Also, the Occupational Safety and Health Administration (OSHA) states at 1910.151(b) that “adequate first-aid supplies shall be readily available.” By readily available, OSHA means always available regardless of how often employers inspect first -aid kits. Some employers maintain a check-off list with the kit so that items can be marked off as they are taken out/used. This may make the task of keeping track of kit contents easier.
First-aid kit logs
Must a first-aid log be kept of the number and quantity of supplies?
Neither OSHA nor ANSI requires that employers maintain a first-aid log.
First-aid kit markings and labels
Must first-aid kits be labeled?
According to ANSI/ISEA Z308.1-2021, each first-aid kit and/or location must be visibly marked as a place where first-aid supplies are located.
Supplies quantity
How many first-aid kits are needed in a workplace?
OSHA does not require employers to have a certain number of kits in the workplace. The number of first-aid kits should be based on several factors including the size of the workplace, number of employees, likelihood and location of possible accidents, etc. Also, 1910.151(a) states that the employer must have a medical professional to advise on matters of plant health, such as what first-aid supplies should be available, the amount of supplies needed, and where those supplies should be placed. In other words, OSHA would expect employers to consult their medical professional for guidance.
In addition, employers may also discuss this issue with a local ambulance service or outside emergency responders for suggestions. First-aid supply vendors might also be able to provide specific recommendations for a workplace.
First-aid securement
Can first-aid kits or cabinets be locked?
OSHA addresses this issue in a January 23, 2007, Letter of Interpretation in which the agency states, “yes, first-aid cabinets can be locked; however, they must be readily accessible in the event of an emergency. Locking the cabinet may limit accessibility.” Therefore, employers need to ensure that employees and/or first-aid providers/emergency responders can get to the key and the supplies in an emergency.
Construction
- Employers are required to provide medical and first-aid personnel and supplies commensurate with the hazards of the workplace.
- The type of supplies, first aid training and first aid personnel depend on the circumstances of each workplace and employer.
- OSHA’s medical and first-aid requirements apply to all construction job sites.
Construction
Confined spaces rescue and emergency services
1926.1211(b)(3)
1926.1211(b)(4)
General safety and health provisions-first aid and medical attention
1926.23
First aid kits (non-mandatory)
Appendix A to 1926.50
Occupational health and environmental controls
1926.50(a)
1926.50(b)
1926.50(c)
1926.50(d)(1)
1926.50(d)(2)
1926.50(e)
1926.50(f)(1)
1926.50(f)(2)
1926.50(f)(2)(i)
1926.50(f)(2)(ii)(A)
1926.50(f)(2)(ii)(A)(1)
1926.50(f)(2)(ii)(A)(2)
1926.50(f)(2)(ii)(B)
1926.50(g)
Special industries
Logging
1910.266(d)(2)
1910.266(d)(2)(i)
1910.266(d)(2)(ii)
1910.266(d)(2)(iii)
1910.266(d)(2)(iv)
Electric power generation, transmission and distribution
1910.269(b)
1910.269(b)(1)
1910.269(b)(1)(i)
General industries
General environmental controls-permit-required confined spaces
1910.146(k)(2)(iii)
1910.146(k)(2)(iv)
1910.269(b)(1)(ii)
1910.269(b)(2)
1910.269(b)(3)
Commercial diving operations-qualifications of dive team
1910.410(a)(3)
First aid and medical requirements (Construction)
The construction regulation for medical services and first aid at 1926.50(b), says that provisions must be made prior to commencement of the project for prompt medical attention in case of serious injury. The phrase “reasonably accessible” in 1926.50(c) emphasizes the desirability of prompt assistance when an injury or illness occurs. If you’ve been in the safety field long you know that this has been interpreted to mean anything from three to fifteen minutes.
The following information from an OSHA Letter of Interpretation dated January 16, 2007, discusses OSHA’s expectations to what “reasonably accessible” means:
“The primary requirement addressed by these standards is that an employer must ensure prompt first aid treatment for injured employees, either by providing for the availability of a trained first aid provider at the worksite, or by ensuring that emergency treatment services are within reasonable proximity of the worksite. The basic purpose of these standards is to assure that adequate first aid is available in the critical minutes between the occurrence of an injury and the availability of physician or hospital care for the injured employee.”
One option these standards provide employers is to ensure that a member of the workforce has been trained in first aid. This option is, for most employers, a feasible and low-cost way to protect employees, as well putting the employer clearly in compliance with the standards. OSHA recommends, but does not require, that every workplace include one or more employees who are trained and certified in first aid, including CPR.
The other option for employers is to rely upon the reasonable proximity of an infirmary, clinic or hospital. OSHA has consistently taken the view that the reasonable availability of a trained emergency service provider, such as fire department paramedics or EMS responders, would be equivalent to the “infirmary, clinic, or hospital” specified by the literal wording of the standards. Emergency medical services can be provided either on-site or by evacuating the employee to an off-site facility in cases where that can be done safely.
However, the requirements that emergency medical services must be “reasonably accessible” or “in near proximity to the workplace” are stated only in general terms. An employer who contemplates relying on assistance from outside emergency responders as an alternative to providing a first-aid-trained employee must take a number of factors into account. The employer must take appropriate steps prior to any accident (such as making arrangements with the service provider) to ascertain that emergency medical assistance will be promptly available when an injury occurs. While the standards do not prescribe a number of minutes, OSHA has long interpreted the term “near proximity” to mean that emergency care must be available within no more than 3-4 minutes from the workplace, an interpretation that has been upheld by the Occupational Safety and Health Review Commission and by federal courts.
Supplies
First aid supplies are required to be easily accessible under paragraph 1926.50(d)(1). The American National Standards Institute (ANSI) has updated their Z308.1-2021, Minimum Requirements for Workplace First Aid Kits, effective October 15, 2022.
The ANSI standard has not been adopted by OSHA; therefore, is not mandatory for OSHA compliance. OSHA currently references ANSI Z301.1-1998 in Appendix A. This being said, OSHA often references the most recent consensus standard as a source of guidance to ensure employers are meeting the standard or the requirements of the General Duty Clause.
Employers who have unique or changing first-aid needs in their workplace, may need to enhance their first-aid kits. The employer can use the OSHA 300 Log of Work-Related Injuries and Illnesses, the 300-A Summary of Work-Related Injuries and Illnesses, or the OSHA 301 Injury and Illness Incident Report to identify these unique problems. Consultation from the local Fire/Rescue Department, appropriate medical professional, or local emergency room may be helpful to employers in these circumstances. By assessing the specific needs of their workplace, employers can ensure that reasonably anticipated supplies are available. Employers should assess the specific needs of their worksite periodically and augment the first aid kit appropriately.
If it is reasonably anticipated employees will be exposed to blood or other potentially infectious materials while using first-aid supplies, employers should provide personal protective equipment (PPE). Appropriate PPE includes gloves, gowns, face shields, masks, and eye protection.
Automated external defibrillators (AEDs)
With recent advances in technology, automated external defibrillators (AEDs) are now widely available, safe, effective, portable, and easy to use. They provide the critical and necessary treatment for sudden cardiac arrest (SCA) caused by ventricular fibrillation, the uncoordinated beating of the heart leading to collapse and death. Using AEDs as soon as possible after sudden cardiac arrest, within 3-4 minutes, can lead to a 60% survival rate. CPR is of value because it supports the circulation and ventilation of the victim until an electric shock delivered by an AED can restore the fibrillating heart to normal.
All jobsites are potential candidates for AED programs because of the possibility of SCA and the need for timely defibrillation. Each jobsite should assess its own requirements for an AED program as part of its first-aid response.
A number of issues should be considered in setting up a jobsite AED program:
- Physician oversight
- Compliance with local, state, and federal regulations
- Coordination with local EMS
- A quality assurance program
- A periodic review
The OSHA website at www.osha.gov or the websites of the American College of Occupational and Environmental Medicine at www.acoem.org, the American Heart Association at www.americanheart.org, the American Red Cross at www.redcross.org, and the National Center for Early Defibrillation at www.early-defib.org can provide additional information about AED program development.
Fundamentals of a workplace first aid program
OSHA has a best practice for first aid titled Fundamentals of a Workplace First-Aid Program. Excerpts from it are shown below. First aid is emergency care provided for injury or sudden illness before emergency medical treatment is available. The first-aid provider in the workplace is someone who is trained in the delivery of initial medical emergency procedures, using a limited amount of equipment to perform a primary assessment and intervention while awaiting arrival of emergency medical service (EMS) personnel.
A workplace first-aid program is part of a comprehensive safety and health management system that includes the following four essential elements:
- Management leadership and employee involvement
- Worksite analysis
- Hazard prevention and control
- Safety and health training
The purpose of this guide is to present a summary of the basic elements for a first-aid program at the workplace. Those elements include:
- Identifying and assessing the workplace risks that have potential to cause worker injury or illness.
- Designing and implementing a workplace first-aid program that: 1. Aims to minimize the outcome of accidents or exposures. 2. Complies with OSHA requirements relating to first aid. 3. Includes sufficient quantities of appropriate and readily accessible first-aid supplies and first-aid equipment, such as bandages and automated external defibrillators. 4. Assigns and trains first-aid providers who receive first-aid training suitable to the specific workplace, and receive periodic refresher courses on first-aid skills and knowledge.
- Instructing all workers about the first-aid program, including what workers should do if a coworker is injured or ill. Putting the policies and program in writing is recommended to implement this and other program elements.
- Providing for scheduled evaluation and changing of the first-aid program to keep the program current and applicable to emerging risks in the workplace, including regular assessment of the adequacy of the first-aid training course.
This guide also includes an outline of the essential elements of safe and effective first-aid training for the workplace as guidance to institutions teaching first-aid courses and to the consumers of these courses.
Assessing the risks and design of a first aid program specific for the worksite
Employers should make an effort to obtain estimates of EMS response times for all permanent and temporary locations and for all times of the day and night at which they have workers on duty. They should use that information when planning their first-aid program. When developing a workplace first-aid program, consultation with the local fire and rescue service or emergency medical professionals may be helpful for response time information and other program issues. Because it can be a workplace event, SCA should be considered by employers when planning a first-aid program.
It is advisable to put the First-Aid Program policies and procedures in writing. Policies and procedures should be communicated to all employees, including those workers who may not read or speak English. Language barriers should be addressed both in instructing employees on first-aid policies and procedures and when designating individuals who will receive first-aid training and become the on-site first-aid providers.
First aid courses
Training for first aid is offered by the American Heart Association, the American Red Cross, the National Safety Council, and other nationally recognized and private educational organizations. OSHA does not teach first-aid courses or certify first-aid training courses for instructors or trainees. First-aid courses should be individualized to the needs of the workplace. Some of the noted program elements may be optional for a particular plant or facility. On the other hand, unique conditions at a specific worksite may necessitate the addition of customized elements to a first-aid training program.
Elements of a first aid training program
There are a number of elements to include when planning a first aid training program for a particular workplace. These recommendations are based on the best practices and evidence available at the time this guide was written. Statistical information is available from BLS to help assess the risks for specific types of work. Program elements to be considered are:
- Teaching methods
Training programs should incorporate the following principles: - Basing the curriculum on a consensus of scientific evidence where available;
- Having trainees develop “hands-on” skills through the use of mannequins and partner practice;
- Having appropriate first-aid supplies and equipment available;
- Exposing trainees to acute injury and illness settings as well as to the appropriate response through the use of visual aids;
- Including a course information resource for reference both during and after training;
- Allowing enough time for emphasis on commonly occurring situations;
- Emphasizing skills training and confidence-building over classroom lectures;
- Emphasizing quick response to first-aid situations.
- Preparing to respond to a health emergency
The training program should include instruction or discussion in the following:- Prevention as a strategy in reducing fatalities, illnesses and injuries;
- Interacting with the local EMS system;
- Maintaining a current list of emergency telephone numbers (police, fire, ambulance, poison control) accessible by all employees;
- Understanding the legal aspects of providing first-aid care, including Good Samaritan legislation, consent, abandonment, negligence, assault and battery, State laws and regulations;
- Understanding the effects of stress, fear of infection, panic; how they interfere with performance; and what to do to overcome these barriers to action;
- Learning the importance of universal precautions and body substance isolation to provide protection from bloodborne pathogens and other potentially infectious materials. Learning about personal protective equipment — gloves, eye protection, masks, and respiratory barrier devices. Appropriate management and disposal of blood-contaminated sharps and surfaces, and awareness of OSHA’s Bloodborne Pathogens standard.
- Assessing the scene and the victim(s)
The training program should include instruction in the following:- Assessing the scene for safety, number of injured, and nature of the event;
- Assessing the toxic potential of the environment and the need for respiratory protection;
- Establishing the presence of a confined space and the need for respiratory protection and specialized training to perform a rescue;
- Prioritizing care when there are several injured;
- Assessing each victim for responsiveness, airway patency (blockage), breathing, circulation, and medical alert tags;
- Taking a victim’s history at the scene, including determining the mechanism of injury;
- Performing a logical head-to-toe check for injuries;
- Stressing the need to continuously monitor the victim;
- Emphasizing early activation of EMS; • Indications for and methods of safely moving and rescuing victims;
- Repositioning ill/injured victims to prevent further injury.
- Responding to life-threatening emergencies
The training program should be designed or adapted for the specific worksite and may include first-aid instruction in the following:- Establishing responsiveness;
- Establishing and maintaining an open and clear airway;
- Performing rescue breathing;
- Treating airway obstruction in a conscious victim;
- Performing CPR;
- Using an AED;
- Recognizing the signs and symptoms of shock and providing first aid for shock due to illness or injury;
- Assessing and treating a victim who has an unexplained change in level of consciousness or sudden illness;
- Controlling bleeding with direct pressure;
- Poisoning — Ingested poisons: alkali, acid, and systemic poisons. Role of the Poison Control Center (1-800-222-1222); Inhaled poisons: carbon monoxide; hydrogen sulfide; smoke; and other chemical fumes, vapors, and gases. Assessing the toxic potential of the environment and the need for respirators; knowledge of the chemicals at the worksite and of first aid and treatment for inhalation or ingestion; effects of alcohol and illicit drugs so that the first-aid provider can recognize the physiologic and behavioral effects of these substances
- Recognizing asphyxiation and the danger of entering a confined space without appropriate respiratory protection. Additional training is required if first-aid personnel will assist in the rescue from the confined space.
- Responding to medical emergencies; chest pain; stroke; breathing problems; anaphylactic reaction; hypoglycemia in diabetics taking insulin; seizures; pregnancy complications; abdominal injury; reduced level of consciousness; impaled object.
- Responding to non-life-threatening emergencies
The training program should be designed for the specific worksite and include first-aid instruction for the management of the following:- Wounds — Assessment and first aid for wounds including abrasions, cuts, lacerations, punctures, avulsions, amputations and crush injuries; principles of wound care, including infection precautions; principles of body substance isolation, universal precautions and use of personal protective equipment.
- Burns — Assessing the severity of a burn; recognizing whether a burn is thermal, electrical, or chemical and the appropriate first aid; reviewing corrosive chemicals at a specific worksite, along with appropriate first aid.
- Temperature extremes — Exposure to cold, including frostbite and hypothermia; exposure to heat, including heat cramps, heat exhaustion and heat stroke.
- Musculoskeletal injuries — Fractures; sprains, strains, contusions and cramps; head, neck, back and spinal injuries; appropriate handling of amputated body parts.
- Eye injuries — First aid for eye injuries; first aid for chemical burns.
- Mouth and teeth injuries — Oral injuries; lip and tongue injuries; broken and missing teeth; the importance of preventing aspiration of blood and/or teeth.
- Bites and stings — Human and animal bites; bites and stings from insects; instruction in first-aid treatment of anaphylactic shock.
Trainee assessment
Assessment of successful completion of the first-aid training program should include instructor observation of acquired skills and written performance assessments.
Skills update
First-aid responders may have long intervals between learning and using CPR and AED skills. Numerous studies have shown a retention rate of 6-12 months of these critical skills. The American Heart Association’s Emergency Cardiovascular Care Committee encourages skills review and practice sessions at least every 6 months for CPR and AED skills. Instructor-led retraining for life threatening emergencies should occur at least annually. Retraining for non-life-threatening response should occur periodically.
Program update
The first-aid program should be reviewed periodically to determine if it continues to address the needs of the specific workplace. Training, supplies, equipment and first-aid policies should be added or modified to account for changes in workplace safety and health hazards, worksite locations and worker schedules since the last program review. The first-aid training program should be kept up-to-date with current first-aid techniques and knowledge. Outdated training and reference materials should be replaced or removed.
