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focus-area/safety-and-health/first-aid-and-medical
555156540
['First Aid and Medical']

Employers are required to provide employees with a safe and healthy workplace that is reasonably free of occupational hazards, but accidents still happen. Therefore, first-aid and medical personnel and supplies appropriate to the hazards of the workplace must also be provided. The employer is responsible for evaluating the hazards in the workplace and determining what first-aid supplies are appropriate.

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First aid and medical

Employers must provide employees with a safe and healthy workplace that is reasonably free of occupational hazards. Unfortunately, accidents may happen. Therefore, employers are required to provide medical and first-aid personnel and supplies commensurate with the hazards of the workplace. The employer is responsible for evaluating the hazards in the workplace and determining what first-aid supplies are appropriate.

The Occupational Safety and Health Administration’s (OSHA) medical and first-aid requirements apply to all employers, though how they must comply depends on how close they are to a medical facility that can provide treatment, as well as the type of hazards present.

The American National Standards Institute (ANSI) in collaboration with the International Safety Equipment Association (ISEA) has updated Z308.1-2021, Minimum Requirements for Workplace First Aid Kits, effective October 15, 2022. The ANSI standard has not been adopted by OSHA; therefore, it’s not mandatory for OSHA compliance. OSHA currently references ANSI Z301.1-1998 in Appendix A. OSHA often references consensus standards as a source of guidance to assist employers with complying with its standards or satisfying their duty under the General Duty Clause.

First-aid kits for emergencies

  • First-aid kits must be visibly marked and in good repair.
  • First-aid kits must be stocked with the required unexpired supplies.
  • First-aid kits must be easily accessible in case of an emergency.

Location

The kit must be located in an area which permits easy accessibility in the event of an emergency.

Marking and labeling

The kit and/or location of the kit must be visibly marked.

Condition

  • The outside of the kit must be in good repair to adequately protect supplies.
  • The interior of the kit should not show evidence of moisture or other contamination.
  • All supplies should be secure in their original packaging or container.
  • All supplies with an expiration date should not be expired.

Guide

  • A first-aid guide must be present.
  • The first-aid guide should describe the care needed to be administered until more advanced care can be provided.

Required supplies

  • At least 16 individually packaged, sealed, and sterile adhesive bandages measuring 1 x 3 inches.
  • At least 1 roll of adhesive tape measuring a minimum of 2 1/2 yards.
  • At least 10 individual use packets containing a minimum of 1/57 fluid ounces of antibiotic ointment.
  • At least 10 individual use packets containing a minimum of 1/57 fluid ounces of antiseptic.
  • At least 10 individual use packets or spray containers with a minimum of 1/32 ounces of burn treatment.
  • At least 1 burn dressing/pad (gel soaked) measuring a minimum of 4 x 4 square inches.
  • At least 2 sterile pads measuring a minimum of 3 x 3 inches.
  • At least 1 triangular bandage made from muslin measuring a minimum of 40 x 40 x 56 inches when unfolded.
  • At least 2 pairs of medical grade exam gloves.
  • At least 1 cold pack measuring a minimum of 4 x 5 inches. An individually packaged, single use, disposable breathing barrier containing instructions for use.
  • At least 2 individually packaged, sealed, and sterile eye coverings, with means of attachment, measuring a minimum of 2.9 square inches.
  • An individual use, sterile, isotonic, buffered eye/skin wash containing a minimum of 1 fluid ounces.
  • At least 6 containers of hand sanitizer containing a minimum of 1/32 fluid ounces.
  • At least 1 roller bandage measuring a minimum of 2 inches x 4 yards.
  • At least 2 trauma pads measuring a minimum of 5 x 9 inches.
  • A pair of scissors.
  • If a Class B first aid kit, a splint measuring a minimum of 4 x 24 inches must be present.
  • If a Class B first aid kit, a tourniquet measuring a minimum of 1 inch wide must be present.

Emergency Action Plan

  • Employers need to create a workplace EAP so that employees know what to do in case of an emergency.
  • When an emergency occurs, the first thing to remember is to remain calm.
  • Use the memory jogger “Check-Call-Care” as a reminder of what to do in an emergency.

The following information is an example of what should be included in a workplace Emergency Action Plan (EAP).

Overview

There is nothing new about workplace accidents and injuries. They happen frequently. Thankfully, they are usually minor, but occasionally a coworker may be seriously injured or even killed on the job.

Here is what should be done in case of emergency.

Remain calm

When someone witnesses an injury or comes upon an accident scene, the first thing to remember is to remain calm, and don’t panic. Try to think clearly about what should be done to make the scene safe and to help an injured coworker.

To help remember what to do, use this memory jogger: “Check-Call-Care.”

Check

First, check the scene:

  • to find out what has happened;
  • to determine if it is safe for personnel to enter or stay. If it is not safe, do not enter;
  • for bystanders who saw what happened, or who can assist;
  • for the number of victims.

Next, check the victim to determine if:

  • they are breathing;
  • there is a pulse; or
  • there are any life-threatening conditions.

Call

Call (or have someone else call) the workplace emergency number to report the accident or injury. Be ready to explain where the event occurred, the number of victims and their condition, and what care is being given.

Care

Finally, provide care. If the victim is conscious, ask permission first. Deal with any life-threatening conditions immediately, and then move on to less threatening conditions.

Remember, providing care may mean just staying present at the scene and waiting for the arrival of emergency responders. Reassure the victim that help is coming.

Emergencies in the workplace

The employer will explain to the employees how to contact emergency services at the workplace, as well as the location of first-aid supplies, along with any other emergency information employees should know.

Who does this apply to?

  • Employers must ensure that adequate first-aid supplies are available, prompt first-aid is administered, and eyewash/body flush facilities are available.
  • Employers must ensure that employees are trained in first-aid programs and employees who are expected to provide first aid or medical services must be trained in OSHA’s BBP standard.

Employers must:

  • Determine the need for first-aid supplies and for medical and first-aid services.
  • Ensure that “adequate” first-aid supplies are available at the worksite. The first-aid supplies should reflect the kinds of injuries that occur and must be stored in an area where they are readily available for emergency access. Note that some industries have specific requirements for the first-aid kit locations and contents.
  • Set up a schedule for checking and replenishing the content of the first-aid kit(s).
  • Ensure prompt first-aid treatment for injured employees either by employing a trained first-aid provider at the worksite, or by ensuring that emergency treatment services are within reasonable proximity of the worksite. However, if life-threatening injuries can be reasonably expected, and outside emergency responders are more than 3-4 minutes away, the employer must ensure that trained personnel are available at the workplace. They must also be provided with periodic refresher training.
  • If corrosive materials are used, ensure eyewash and body flush facilities are provided.
  • Instruct all workers about the first-aid program, including instruction on what workers should do if a coworker is injured or ill. A written program of first-aid policies and procedures is recommended, to ensure all the program elements are implemented.
  • Employees who are expected to provide first aid or medical services must be trained per the Occupational Safety and Health Administration’s (OSHA) Bloodborne Pathogens (BBP) standard. Good Samaritans are not covered by OSHA’s BBP standard.
  • Record on the 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.)

What are the key definitions?

  • OSHA refers to ANSI Z308.1 to define the minimal contents of a workplace first-aid kit.
  • First aid is emergency care provided for sudden injury or illness before medical treatment is available. A person trained in the delivery of initial medical emergency procedures is referred to as the first-aid provider.
  • Emergency care must be in near proximity to the workplace, meaning no more than 3-4 minutes away.

ANSI Z308.1: An American National Standards Institute (ANSI) standard that the Occupational Safety and Health Administration (OSHA) refers to as the minimal contents of a workplace first aid kit. OSHA’s referral is non-mandatory, and the kits described are suitable for small businesses.

ANSI Z358.1: An ANSI standard that provides specifications for the design, testing, maintenance, and use of emergency eyewash and shower facilities. OSHA accepts equipment meeting ANSI Z358.1 specifications as being sufficient for compliance with 1910.151(c).

First aid: Emergency care provided for injury or sudden illness before emergency medical treatment is available. The first-aid provider in the workplace is a person trained in the delivery of initial medical emergency procedures, using a limited amount of equipment to perform a primary assessment and intervention while awaiting the arrival of emergency medical service (EMS) personnel.

Near proximity: For the purposes of 29 CFR 1910.151, OSHA interprets the term “near proximity” to mean that emergency care must be available within no more than three to four minutes from the workplace.

Corrosive: A chemical that causes visible destruction of, or irreversible alterations in, living tissue by chemical action at the site of contact. In general, corrosive materials have a very low pH (acids) or a very high pH (bases). Strong bases are usually more corrosive than acids. Examples of corrosive materials are sodium hydroxide (lye) and sulfuric acid.

Exposure: In terms of the requirement to provide an eyewash/shower, “exposure” means that there is an actual or likely chance that an employee’s eyes and/or body could come into contact with a corrosive material. If hazardous materials are present at a worksite in such a way that exposure could not occur (for example, in sealed containers that will not be opened, or caustic materials in building piping), then an eyewash or emergency shower would not be necessary. However, if the building piping containing caustic materials has, at certain locations, a spigot or tap from which the contents are to be sampled or withdrawn, and employees are expected to perform such tasks, then, an emergency eyewash and/or shower would be needed where this task is to occur.

Flushing fluid: Potable water, preserved water, preserved buffered saline solution or other medically acceptable solution.

Tepid: Flushing fluid that is a temperature which promotes continuous flushing for the required minimum of 15 minutes. ANSI defines tepid as a temperature range between 60- and 100-degrees Fahrenheit.

First aid and medical requirements (General industry)

  • In the event of an emergency, employees must know what to do and where first-aid kits and emergency eyewash stations are located.
  • The basic steps of first aid include calling for help, analyzing the situation, refraining from moving the victim, evaluating for signs of life, controlling heavy bleeding, treating for shock, treating for choking, treating for burns, treating for chemical burns to the eye, and treating for fracture.
  • First-aid supplies and other medical services must be available at the workplace, and it is recommended that employees be trained in administering first aid and CPR.

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.

The following table lays out some basic first-aid information:

First aid basicsDetails
Call for helpIf the employee is not alone, they should have someone go for help immediately. If they are alone, immediate care is a priority. However, that immediate care may be going for help.
Analyze the situationEmployees must take precautions to avoid becoming a victim themselves. If they can safely do so, they should move the victim away from any sources of danger such as water, fire, or downed power lines. All power sources should be turned off before touching an electrocuted victim.
Don’t move the victimIf there is any chance of spine or neck injury, the victim should not be moved unless they are in a life-threatening situation.
Look for signs of lifeLook for signs of life and give artificial respiration or cardiopulmonary resuscitation (CPR) if necessary but only if employees have been trained. Confirm that help is on the way before starting CPR. Do not tilt the victim’s head back if there is a suspected neck injury.
Control heavy bleedingStop the flow of blood by applying direct pressure and/or elevating the injury above the heart or pressure points. Do not use a tourniquet unless the person is in danger of bleeding to death and employees have been trained to apply one.
Treat for shockSigns of shock include cold, pale skin; a rapid, faint pulse; nausea; rapid breathing; and weakness. To treat for shock, keep the victim lying down; cover them only enough to maintain body heat; don’t move the victim unless absolutely necessary; and get medical help immediately.
Treat for chokingA person can choke to death in a few minutes. A sign of choking is if a person can’t speak, cough, or breathe. If the person is choking, use the Heimlich Maneuver.
Treat for burnsFor small burns, gently soak the burn in cold water or pour cold water on the burn. Don’t treat large burns with water unless they’re chemical burns. Cover the burn with a dry, sterile bandage. Provide artificial respiration as needed. Seek medical attention. Some chemicals should not be flushed with water but neutralized by other means—see chemical label.
Treat for chemical burn in eyeQuickly flush the eyes with lots of water for at least 15 minutes (for best results, do so at an eyewash station, emergency shower, or hose). Try to force the eyes open to wash chemical out. Do not bandage eyes. Seek medical attention.
Treat for fractureDo not move the victim unless absolutely necessary. This is especially important if there is a suspected neck or back injury. Seek medical help.

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

  • OSHA accepts any first-aid training program that covers the fundamental requirements.
  • First-aid training programs should adequately cover the types of illnesses and injuries that are likely to occur in the workplace.
  • Trainees should be tested upon completion and retraining should occur annually.

The first-aid training program should be kept updated with current first-aid techniques and knowledge. Outdated training and reference materials should be replaced or removed.

The Occupational Safety and Health Administration (OSHA) recognizes any nationally accepted and medically sound first-aid training program that covers the fundamentals of first aid as meeting the requirements stated in 29 CFR 1910.151.

Each employer using any first aid and/or cardiopulmonary resuscitation (CPR) courses must ensure that the course adequately covers the types of injuries/illnesses likely to be encountered in the workplace.

According to OSHA CPL 2-2.53, these are the general program elements required for a training program:

  1. Emphasis on “hands-on” training involving mannequins and trainee partners.
  2. Exposure to acute injury and illness settings as well as appropriate response including the use of visual aids.
  3. Include a course workbook.
  4. Allow enough time for the course to cover likely situations for your facility.
  5. Emphasis on quick response.

Topics to be included:

  1. Injury and acute illness;
  2. Working with local emergency response system and teams, and how they are to be contacted;
  3. Principles of triage;
  4. Legal aspects of providing first aid;
  5. Methods of surveying an incident scene and assessment of need for first aid and how to provide it safely;
  6. Performing primary survey(s) of victim(s), including airway, breathing and circulation;
  7. Getting a victim’s health history at the scene;
  8. CPR;
  9. Bandaging;
  10. Splinting;
  11. Rescue and transport of victim(s);
  12. Personal protective equipment (PPE); and
  13. Tagging and disposal of any contaminated sharp or material. See Bloodborne Pathogens topic.

Trainees should be tested upon completion of initial training. Assessment should include instructor observation of acquired skills and written performance assessments.

First-aid responders may have long intervals between learning and using CPR and automated external defibrillator (AED) skills. OSHA recommends that instructor-led retraining for life-threatening emergencies should occur at least annually. Retraining for non-life-threatening response should occur periodically.

Must emergency responders be certified?

If an employer is required to have employees who are “trained responders” on site per an applicable standard (e.g., permit-required confined spaces), then they must have current certifications. Typically, these certifications are administered by the entity which provides the training (e.g., American Red Cross, American Heart Association, National Safety Council, etc.). As such, an employer would be expected to follow that entity’s re-certification schedule as necessary.

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.

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.

Additional emergency

  • AEDs are not required to be included in first-aid supplies.
  • OSHA recommends employers consider AED equipment as part of a medical and first-aid program.
  • If it is reasonably anticipated that employees will be exposed to blood or other potentially infectious materials while using first-aid supplies, employers are required to provide appropriate PPE.

Automated external defibrillators (AED) are not required to be included in first-aid supplies; however, the Occupational Safety and Health Administration (OSHA) recommends employers consider the equipment as part of a medical and first-aid program. All worksites are potential candidates for AED programs because of the possibility of sudden cardiac arrest (SCA) and the need for timely defibrillation. Each workplace must make a determination based upon its own requirements.

AEDs provide the critical and necessary treatment for SCA caused by ventricular fibrillation, the uncoordinated beating of the heart leading to collapse and death. Using AEDs as soon as possible after SCA, within 3-4 minutes, can lead to a 60% survival rate among victims of SCA.

PPE

If it is reasonably anticipated that employees will be exposed to blood or other potentially infectious materials while using first-aid supplies, employers are required to provide appropriate personal protective equipment (PPE).

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.

Use of the OSHA 300 Log, OSHA 301

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, Federal Occupational Health at www.foh.dhhs.gov, 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:

  1. 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.
  2. 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.
  3. 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.
  4. 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.
  5. 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.

Automated external defibrillators

  • AED programs provide critical treatment for SCA events and using AEDs within 3-4 minutes can lead to a 60% survival rate among SCA victims.
  • AEDs are not required by OSHA but are recommended and some state statutes require certain facilities to have AEDs at the workplace.
  • Employers should consult a medical professional to determine whether an AED is warranted.

All worksites are potential candidates for automated external defibrillator (AED) programs because of the possibility of sudden cardiac arrest (SCA) and the need for timely defibrillation. AEDs provide the critical and necessary treatment for 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 among victims of SCA.

AEDs are not required to be included in first-aid supplies; however, the Occupational Safety and Health Administration (OSHA) recommends employers consider the equipment as part of a medical and first-aid program. Each workplace must make a determination based upon its own requirements.

Do I need an AED in the workplace?

OSHA doesn’t require employers to have an automated external defibrillator (AED) on the premises. As such, employers should carefully evaluate whether an AED should be provided for use. Keep in mind that OSHA 1910.151(a) states, “The employer shall ensure the ready availability of medical personnel for advice and consultation on matters of plant health.” In this case, employers may wish to consult their medical professional on whether an AED is warranted.

AEDs are considered a medical device, therefore the Food and Drug Administration (FDA) may require a prescription to obtain them.

Do certain states have specific requirements for AEDs?

Some states require that certain facilities have AEDs. These facilities may include:

  • Schools (public and private)
  • State buildings
  • Sports venues
  • Gambling parlors
  • Non-health facilities

State and local codes should be reviewed on a regular basis to keep current with the requirements.

Addressing SCA with AEDs

  • AEDs are devices used to restore a heart in defib to a normal rhythm.
  • SCA is when a victim’s heart stops beating and then beats irregularly.
  • When a SCA event occurs, emergency medical help must be summoned, and the AED used.

Automated External Defibrillator (AED)

Modern AEDs:

  • Are light, small, and portable.
  • Provide an electric shock to restore a heart in defib to a normal rhythm.
  • Are automated and will typically talk the rescuer through the necessary procedures and automatically monitor a victim’s heart rhythm.

Sudden Cardiac Arrest (SCA)

  • The heart normally has a rhythmic beat. A sudden cardiac arrest (SCA) victim’s heart stops beating and then beats irregularly, like a quiver.
  • This is called ventricular fibrillation (VF). VF is not to be confused with a heart attack where blood flows to the heart muscle is blocked. With VF, the blood stops circulating adequately, and the victim loses consciousness.
  • Breathing stops and the person will eventually die.
  • Cardiopulmonary resuscitation (CPR) alone does not replace defibrillation in a SCA incident. CPR merely gives a person precious time until emergency medical help arrives.
  • Without access to an AED, very few people have survived a SCA after 10 minutes.

What is SCA?

The heart normally has a rhythmic beat. When someone experiences sudden cardiac arrest (SCA), the victim’s heart stops beating normally, or beats erratically. Blood stops circulating adequately, and the victim loses consciousness. Breathing stops and the person will die if they do not receive prompt medical attention.

Signs and symptoms of SCA

Symptoms of SCA are very sudden and dramatic. Typically, the victim will collapse, and show no sign of a pulse. At this point, emergency medical help must be summoned, and the AED used.

Many AEDs will prompt the operator through the necessary steps to use it. The AED then checks for the presence of a shockable SCA event. The AED either prompts the operator to apply a shock to the victim’s heart or will prompt to continue CPR. If the AED does not sense a shockable event, no shock is given.

Other AEDs function automatically, applying a shock to the victim after sounding a warning alarm.

Laws and liability

  • Those who intervene to help a victim during a medical emergency are considered a “Good Samaritan.”
  • Good Samaritans are not liable for civil damage that may occur while administering treatment.
  • Cardiac arrest care providers, trainers, and owners of property where AEDs are kept are protected as Good Samaritans by the Cardiac Arrest Survival Act.

Cardiac Arrest Survival Act

In 2000, the Cardiac Arrest Survival Act was signed into law. This law specifically protects those who use automated external defibrillators (AED) on a victim from civil liability. Again, the user must not cause harm by gross negligence, along with willful, criminal or reckless misconduct, or a conscious, flagrant indifference to the rights or safety of the victim.

The Cardiac Arrest Survival Act provides Good Samaritan immunity for cardiac arrest care providers, trainers, and owners of property where Automated External Defibrillators (AED) are kept. The Occupational Safety and Health Administration (OSHA) doesn’t have any AED standards but recommends employers have access to an AED as a best practice, recognizing its value and benefits. State regulations on the purchase and use of AEDs vary.

Good Samaritan laws

The “Good Samaritan” doctrine is a legal principle that prevents a rescuer who has voluntarily helped a victim in distress from being successfully sued for “wrongdoing.” The purpose of such laws is to keep people from being reluctant to help a stranger who needs assistance for fear of possible legal repercussions, in the event that a mistake in treatment is made inadvertently by the rescuer. The Good Samaritan doctrine was primarily developed for first-aid situations.

Every state has its own adaptation of the Good Samaritan legal doctrine. Most states declare that the recipient of the aid must not object to the receipt of the aid but need not consent. Some states have Good Samaritan laws that apply to all citizens. Other states have Good Samaritan laws written specifically for physicians.

Key definitions

A Good Samaritan is generally “Any person who, in good faith, renders emergency medical care or assistance to an injured person at the scene of an accident or other emergency without the expectation of receiving or intending to receive compensation from such injured person for such service.” A Good Samaritan shall not be liable in civil damages for any act or omission, not constituting gross negligence, in the course of such care or assistance.

Summary of requirements

When it comes to the legal aspects of rendering first aid, there are a few things to consider. An obvious consideration is that people should not act in ways that could fall under the definition of gross negligence. They should also not try to provide help that is beyond the scope of their training. Once someone begins to render first aid to a victim, they are not to abandon the victim. They must continue until they can no longer supply aid, or until other help arrives and relieves them.

Many employers have employee volunteers who are willing to render first aid to those in need should a workplace incident occur. In such situations, employers are often concerned with risk and legal liability issues. In these cases, there is generally the absence of a contractual, special professional, or trustee relationship or statutory requirement; and the person rendering aid is not under a legal duty to assist or care for the injured. This means that those employee volunteers — unlike traditional medical doctors — do not have a legal obligation to treat people. These are the folks that are generally protected by “Good Samaritan” laws.

Training

  • Instructors should explain how employees can receive formal training to use an AED.
  • Instructors should point out the location AEDs at the facility.
  • Instructors should teach trainees in a language they understand and obtain a translator if necessary.

Learning to use an automated external defibrillator (AED) is not difficult. Modern AEDs are easy to operate and typically instruct the operator on how to proceed.

Instructors will explain how to receive formal training. Instructors will also inform trainees of how to summon emergency medical assistance at the facility and will identify who is designated as a “first responder.”

Instructors will also point out the location of AEDs at the facility.

  • Teach in a language that trainees understand. If a trainee’s vocabulary is limited, account for that limitation. Translators may be needed.
  • Review the company emergency action plan. Use the employee handout to review the requirements for first aid in the workplace.
  • Review the location of first-aid supplies, how to contact a company “first responder,” and the location of emergency numbers.
  • Review the company policy on medical transportation.

Where to go for more information?

  • For more information, employees should examine OSHA regulations, INSEA/ANSI standards, the company Emergency Action Plan, and the Cardiac Arrest Survival Act.
  • AED users should examine the AED User’s Guide and applicable state regulations.

OSHA

Consensus standards

  • ISEA/ANSI Z308.1-2021, Minimum Requirements for Workplace First-Aid Kits and Supplies.

Emergency Action Plan

  • The company Emergency Action Plan.

AED user manual

  • AED user’s guide.

State AED regulations

  • Applicable state AED regulations.
  • States regulate the purchase and use of AEDs

Other sources of information

  • Cardiac Arrest Survival Act (CASA).

Eyewashes and showers

  • OSHA requires all employers who have employees that may be exposed to injurious corrosive materials to have emergency eyewash/shower units available.
  • Emergency showers and eyewash stations are the first treatment to help reduce the effects of a chemical accident at the workplace.

OSHA’s emergency eyewash/shower requirements apply to all employers who have employees who may be exposed to injurious corrosive materials (as defined by the SDS). In addition, a few industry-specific standards have requirements.

When employees could be exposed to hazardous chemicals, they must be provided suitable facilities to flush the chemical from their eyes and/or body. This must take the form of a properly designed eyewash and/or shower.

Working around hazards which pose a threat to your vision may be unavoidable. However, you can prevent painful injury and possible permanent vision damage if you, and your employer, prepare for the unexpected. Emergency showers and eyewashes are provided as a first treatment to help reduce the effects of a chemical accident on the job.

The first thing to do for chemical burns to the eyes or when these chemicals splash on the skin is to flush them immediately with lots of water. An emergency eyewash and shower allow you to do this.

Emergency eyewashes in general industry

  • Employers must provide suitable facilities for quick drenching and flushing of the eyes from exposure to injurious corrosive materials.
  • Various ANSI standards regulate the design, installation, location, marking, labeling, operation, flushing fluid, maintenance and inspection of emergency eyewashes.
  • Employees must be trained on the proper use and application of emergency eyewashes.

Emergency eyewashes

General

  • Suitable facilities must be provided for quick drenching and flushing of the eyes from exposure to injurious corrosive materials (1910.151(c)).
  • The sole purpose of the unit should be for it to be used as an emergency eyewash.

Design and installation

  • The unit must be installed in accordance with the manufacturer’s instructions (ANSI Z358.1-2014).
  • The eyewash must be designed and positioned in a way that doesn’t pose a hazard to the user (ANSI Z358.1-2014).
  • The supply piping of plumbed eyewashes must be adequately sized to meet flow requirements (ANSI Z358.1-2014).
  • Nozzles must be protected from airborne contaminants (ANSI Z358.1-2014).
  • The eyewash must be equipped with valves that stay open without the use of hands once activated (ANSI Z358.1-2014).
  • The eyewash must be constructed of materials that will not corrode while fluid is flushing (ANSI Z358.1-2014).
  • The eyewash must provide enough room to allow the eyelids to be held open during flushing (ANSI Z358.1-2014).
  • The flushing fluid nozzles must be at least 33 inches, but not more than 53 inches, in height from the floor or platform (ANSI Z358.1-2014).
  • The flushing fluid nozzles must be at least six inches from the wall or nearest obstruction (ANSI Z358.1-2014).
  • The nozzles must be protected from airborne contaminants (e.g., having integrated covers) (ANSI Z358.1-2014).
  • The eyewash must be protected from freezing (e.g., heated blankets) (ANSI Z358.1-2014).

Location

  • The area around the eyewash must be well-lit (ANSI Z358.1-2014).
  • The eyewash must be located in an area that makes it highly visible (ANSI Z358.1-2014).
  • The eyewash must be located on the same level as the hazard (ANSI Z358.1-2014).
  • The eyewash must be able to be reached within 10 seconds (ANSI Z358.1-2014).
  • The path of travel to the eyewash must be free of obstructions (e.g., a door) that may inhibit immediate use (ANSI Z358.1-2014).

Marking and labeling

  • A highly visible sign must be positioned to clearly identify the location of the eyewash (ANSI Z358.1-2014).

Operation

  • Manual or automatic valve activators must be easy to locate and readily accessible (ANSI Z358.1-2014).
  • The valve must be operable.
  • The valve must be able to be activated “off” to “on” in one second or less (ANSI Z358.1-2014).
  • The valve must be able to remain open without the use of the operator’s hands (ANSI Z358.1-2014).
  • The unit must allow both eyes to be flushed at the same time (ANSI Z358.1-2014). The valve must be free of corrosion (ANSI Z358.1-2014).
  • The eyewash piping connections must be free of leaks (ANSI Z358.1-2014).

Flushing fluid

  • The flushing fluid used must be potable water, preserved water, preserved buffered saline solution, or other medically acceptable solution (ANSI Z358.1-2014).
  • The temperature of the flushing fluid must be between 60 and 100 degrees Fahrenheit (ANSI Z358.1-2014).
  • The flow of flushing fluid at a controlled velocity must be non-injurious to the user.
  • The eyewash must deliver a minimum of 0.4 gallons of flushing fluid per minute for 15 minutes (ANSI Z358.1-2014).
  • The spray pattern must be a minimum of four inches in length with two sets of parallel lines equidistant from the center of the eyewash (ANSI Z358.1-2014).
  • The interior sets of lines must be 1 1/4 inches apart and the exterior lines 3 1/4 inches apart (ANSI Z358.1-2014).
  • The flushing fluid must cover the areas between both the interior and exterior lines at some point less than eight inches above the eyewash nozzle(s) (ANSI Z358.1-2014).

Maintenance and inspection

  • Manufacturer operating instructions must be readily accessible to maintenance personnel (ANSI Z358.1-2014).
  • Plumbed eyewashes must be activated weekly to ensure flushing fluid is available (ANSI Z358.1-2014.).
  • Self-contained eyewashes must be visually checked in accordance with the manufacturer’s instructions to determine if flushing fluid needs to be changed or supplemented (ANSI Z358.1-2014).
  • All eyewashes must be inspected annually (ANSI Z358.1-2014).

Training

  • Manufacturer operating instructions must be readily accessible to training personnel (ANSI Z358.1-2014).
  • Employees must be trained on the location of emergency eyewashes (ANSI Z358.1-2014).
  • Employees must be trained on the proper use of emergency eyewashes (ANSI Z358.1-2014).

Personal wash units

  • Units must be supplemented by a readily available plumbed or self-contained eyewash (ANSI Z358.1-2014).
  • The flushing fluid used must be potable water, preserved water, preserved buffered saline solution, or another medically acceptable solution (ANSI Z358.1-2014).
  • The unit must have the capacity to deliver flushing fluid without being injurious to the user (ANSI Z358.1-2014).
  • The unit must be protected from temperatures exceeding 100 degrees Fahrenheit (ANSI Z358.1-2014).
  • The unit must be protected from freezing (ANSI Z358.1-2014).
  • Units must be inspected and maintained in accordance with the manufacturer’s instructions (ANSI Z358.1-2014).
  • Manufacturer operating instructions must be readily accessible to maintenance personnel (ANSI Z358.1-2014).
  • Manufacturer operating instructions must be readily accessible to inspection personnel (ANSI Z358.1-2014).
  • Employees must be trained on the location of personal wash units (ANSI Z358.1-2014).
  • Employees must be trained on the proper use and application of personal wash units (ANSI Z358.1-2014).

Drench hoses

  • The drench hose must be assembled and installed in accordance with manufacturer’s instructions (ANSI Z358.1-2014).
  • The drench hose must be connected to a supply of flushing fluid (ANSI Z358.1-2014).
  • The flushing fluid used must be potable water, preserved water, preserved buffered saline solution, or other medically acceptable solution (ANSI Z358.1-2014).
  • The temperature of the flushing fluid must be between 60 and 100 degrees Fahrenheit (ANSI Z358.1-2014).
  • The drench hose must have the capacity to deliver a controlled flow of flushing fluid at a velocity low enough without being injurious to the user (ANSI Z358.1-2014).
  • The drench hose must be protected from freezing (ANSI Z358.1-2014).
  • The valve must be operable.
  • The valve must be able to be activated “off” to “on” in one second or less (ANSI Z358.1-2014).
  • The valve must be free of corrosion (ANSI Z358.1-2014). Manual or automatic valve activators must be easy to locate and readily accessible (ANSI Z358.1-2014).
  • A highly visible sign must be positioned to clearly identify the location of the drench hose (ANSI Z358.1-2014).
  • The area around the drench hose must be well-lit (ANSI Z358.1-2014).
  • The area around the drench hose must be free of debris or obstructions that may inhibit immediate use (ANSI Z358.1-2014).
  • Plumbed drench hoses must be activated weekly to verify operation and ensure flushing fluid is available (ANSI Z358.1-2014).
  • Self-contained drench hoses must be visually checked in accordance with the manufacturer’s instructions to determine if flushing fluid needs to be changed or supplemented (ANSI Z358.1-2014).
  • Manufacturer operating instructions must be readily accessible to maintenance personnel (ANSI Z358.1-2014).
  • Manufacturer operating instructions must be readily accessible to inspection personnel (ANSI Z358.1-2014).
  • Employees must be trained on the location of drench hoses (ANSI Z358.1-2014).
  • Employees must be trained on the proper use of drench hoses (ANSI Z358.1-2014).

Emergency showers in general industry

  • Employers must provide suitable facilities for quick drenching and flushing from exposure to injurious corrosive materials.
  • Various ANSI standards regulate the design, installation, location, marking, labeling, operation, flushing fluid, maintenance and inspection of emergency showers.
  • Employees must be trained on the proper use and application of emergency showers.

Emergency showers

General

  • Suitable facilities must be provided for quick drenching and flushing of the body from exposure to injurious corrosive materials (1910.151(c)).
  • The sole purpose of the unit must be as an emergency shower.

Design and installation

  • The shower must be constructed of materials that will not corrode while fluid is flushing (ANSI Z358.1-2014).
  • The unit must be installed in accordance with the manufacturer’s instructions (ANSI Z358.1-2014).
  • The supply piping of plumbed showers must be adequately sized to meet flow requirements (ANSI Z358.1-2014).
  • The flushing fluid column must be at least 82 inches, but not more than 96 inches, in height from the floor or platform (ANSI Z358.1-2014).
  • The valve actuator must be located no more than 69 inches above the floor or platform (ANSI Z358.1-2014).
  • Once activated, the shower must be able to be used without requiring the use of the operator’s hands (ANSI Z358.1-2014).
  • The shower must be protected from freezing (ANSI Z358.1-2014).

Location

  • The area around the shower must be well-lit (ANSI Z358.1-2014).
  • The shower must be located in an area that makes it highly visible (ANSI Z358.1-2014).
  • The shower must be located on the same level as the hazard (ANSI Z358.1-2014).
  • The shower must be able to be reached within 10 seconds (ANSI Z358.1-2014).
  • The path of travel to the shower must be free of obstructions (e.g., a door) that may inhibit immediate use (ANSI Z358.1-2014).

Marking and labeling

  • A highly visible sign must be positioned to clearly identify the location of the shower (ANSI Z358.1-2014).

Operation

  • Manual or automatic valve activators must be easy to locate and readily accessible (ANSI Z358.1-2014).
  • The valve must be operable.
  • The valve must be able to be activated “off” to “on” in one second or less (ANSI Z358.1-2014).
  • The valve must be able to remain open without the use of the operator’s hands (ANSI Z358.1-2014).
  • The valve must be free of corrosion (ANSI Z358.1-2014). The shower piping connections must be free of leaks (ANSI Z358.1-2014).

Flushing fluid

  • The flushing fluid used must be potable water, preserved water, preserved buffered saline solution, or other medically acceptable solution (ANSI Z358.1-2014).
  • The temperature of the flushing fluid must be between 60 and 100 degrees Fahrenheit (ANSI Z358.1-2014).
  • The flow of flushing fluid must be at a controlled velocity so as to be non-injurious to the user (ANSI Z358.1-2014).
  • The shower must deliver a minimum of 20 gallons of flushing fluid per minute for 15 minutes (ANSI Z358.1-2014).
  • The spray pattern must have a minimum diameter of 20 inches (ANSI Z358.1-2014).
  • The center of the spray pattern must be located at least 16 inches from any obstruction (ANSI Z358.1-2014).
  • The spray pattern must be at least 60 inches above the floor or platform (ANSI Z358.1-2014).
  • The flushing fluid must be substantially dispersed throughout the pattern (ANSI Z358.1-2014).
  • The stored flushing fluid must be protected against airborne contaminants (ANSI Z358.1-2014).

Maintenance and inspection

  • Manufacturer operating instructions must be readily accessible to maintenance personnel (ANSI Z358.1-2014).
  • Plumbed showers must be activated weekly (ANSI Z358.1-2014).
  • Self-contained showers must be visually checked in accordance with the manufacturer’s instructions to determine if flushing fluid needs to be changed or supplemented (ANSI Z358.1-2014).
  • All showers must be inspected annually (ANSI Z358.1-2014).

Training

  • Manufacturer operating instructions must be readily accessible to training personnel (ANSI Z358.1-2014).
  • Employees must be trained on the location of emergency showers (ANSI Z358.1-2014).
  • Employees must be trained on the proper use of emergency showers (ANSI Z358.1-2014).

Construction

  • OSHA requires covered employers to provide suitable facilities for quick drenching or flushing of the eyes and body whenever a person may be exposed to injurious corrosive material.
  • OSHA says a plumbed or self-contained eyewash or shower unit that meets the specifications of ANSI Z358.1 would be compliant.
  • Eyewash bottles can only be used to support a plumbed or self-contained unit but cannot replace them.

Medical services and first aid for construction

The Occupational Safety and Health Association (OSHA) medical and first aid requirements apply to all construction jobsites.

Regulatory citation

OSHA uses the associated American National Standards Institute (ANSI) standard during inspections when evaluating the suitability of emergency eyewash and shower protection provided by the employer as stated in a November 1, 2002, Letter of Interpretation.

In general, the standard requires covered employers to provide suitable facilities (for immediate emergency use) quick drenching or flushing of the eyes and body whenever a person may be exposed to injurious corrosive material. OSHA says a plumbed or self-contained eyewash or shower unit that meets the specifications of ANSI Z358.1 would be compliant. A personal wash unit (e.g., eyewash bottle) would not be compliant. Eyewash bottles can only be used to support a plumbed or self-contained unit but cannot replace them.

The standard also requires employers to ensure eyewash/showers are located within 10 seconds of the hazard. The eyewashes must be capable of delivering a minimum of .4 gallons of flushing fluid per minute for 15 minutes. Showers must deliver a minimum of 20 gallons of flushing fluid per minute for 15 minutes.

Eyewash/shower equipment must be inspected and maintained per manufacturer’s specifications and instructions. Employees must also be trained on the locations and use of eyewash/shower equipment. All injuries/illnesses that result in medical treated beyond first aid should be recorded on the OSHA 300 logs.

When are they required?

  • If injurious corrosive materials are present and onsite and employees may be exposed, then an emergency eyewash and/or shower is required.
  • OSHA expects the employer to determine the level of potential risk to employees and provide protection accordingly.
  • Whether an emergency shower is needed in addition to an eyewash is dependent upon several factors, including what the SDS says about eye vs. bodily injury.

When is an eyewash and/or shower required?

The Occupational Safety and Health Administration (OSHA) eyewash/shower requirement at 1910.151(c) states, “Where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use.” [bold emphasis added]

OSHA further addresses this issue in a Letter of Interpretation dated April 14, 2008, which says, “the employer must determine if employees can or will be exposed during the course of their duties to hazardous materials in such a way that the protections of an eyewash or emergency shower would be necessary. If hazardous materials are present at a worksite in such a way that exposure could not occur (for example, in sealed containers that will not be opened, or caustic materials in building piping), then an eyewash or emergency shower would not be necessary. However, if the building piping containing caustic materials has, at certain locations, a spigot or tap from which the contents are to be sampled or withdrawn and employees are expected to perform such tasks, then, certainly, an eyewash and/or emergency shower would be needed where this task is to occur.”

Ask:

  1. Are injurious corrosive materials present onsite? (Refer to the Safety Data Sheet (SDS) for guidance)
  2. Are employees exposed?

If the answer to both of these questions is ‘yes,’ then an emergency eyewash and/or shower is required. If the answer is ‘no’ to either of these questions, then a unit would not need to be provided.

Ultimately, OSHA expects the employer to determine the level of potential risk to employees and provide protection accordingly.

When is an emergency shower required as opposed to just an eyewash?

Whether an emergency shower is needed in addition to an eyewash is dependent upon several factors, including what the SDS says about eye vs. bodily injury. The need for one or the other is sometimes specified. Also, what is the possibility that the chemical could splash or spill onto the employee’s body vs. just the eyes? How much chemical are employees being exposed to, etc.? These are all questions employers need to ask during a hazard assessment. Based on the answers, an employer then must decide what the level of exposure and risk is and provide the necessary protection accordingly.

Should an eyewash be made available to remove metal fragments, wood chips, etc.?

OSHA says that eyewashes (and showers) are intended to be used for strong acids and alkalis. That doesn’t mean, however, that they wouldn’t be useful under other circumstances. In these cases, employers should consult with a medical professional regarding the best course of treatment when workers are exposed to potential eye hazards.

Is an eyewash or shower required for small amounts of corrosive chemicals?

The OSHA standard requires that an emergency eyewash or shower be provided if the eyes or body is exposed to any amount of injurious corrosive material.

Eyewash and shower regulations

  • Eyewashes and showers come in three types: Plumbed, self-contained and personal.
  • Various regulations apply to the use of medical services and first aid.
  • Consult the applicable standard to determine the requirements for first aid, eyewashes and showers in the workplace.

There are several types of wash stations and showers. You should be aware of a few distinctions:

  • Plumbed eyewashes are stations connected permanently to a potable water source.
  • Self-contained eyewashes and showers contain their own flushing fluid and are similar to plumbed eyewashes and showers but do not have an unlimited water supply.
  • Personal eyewashes are supplemental stations that support plumbed units with immediate flushing fluid, such as a squeeze bottle.

OSHA’s emergency eyewash/shower requirements apply to all employers who have employees who may be exposed to injurious corrosive materials. Corrosive materials are defined by the Safety Data Sheet (SDS). In addition, a few industry-specific standards have requirements.

OSHA

Regulations

1910.151 — Medical services and first aid.

(a) The employer shall ensure the ready availability of medical personnel for advice and consultation on matters of plant health.

(b) In the absence of an infirmary, clinic, or hospital in near proximity to the workplace which is used for the treatment of all injured employees, a person or persons shall be adequately trained to render first aid. Adequate first aid supplies shall be readily available.

(c) Where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use.

Appendix A to 1910.151 — First aid kits (non-mandatory)

First aid supplies are required to be readily available under paragraph 1910.151(b). An example of the minimal contents of a generic first aid kit is described in American National Standard (ANSI) Z308.1-1998 “Minimum Requirements for Workplace First-aid Kits.” The contents of the kit listed in the ANSI standard should be adequate for small worksites. When larger operations or multiple operations are being conducted at the same location, employers should determine the need for additional first aid kits at the worksite, additional types of first aid equipment and supplies and additional quantities and types of supplies and equipment in the first aid kits.

In a similar fashion, 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, OSHA 301 log, or other reports 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 that employees will be exposed to blood or other potentially infectious materials while using first aid supplies, employers are required to provide appropriate personal protective equipment (PPE) in compliance with the provisions of the Occupational Exposure to Bloodborne Pathogens standard, 1910.1030(d)(3) (56 FR 64175). This standard lists appropriate PPE for this type of exposure, such as gloves, gowns, face shields, masks, and eye protection.

Consensus standard

  • ANSI Z358.1-2009 — Emergency Eyewashes and Shower Equipment.

Other sources of information

  • OSHA CPL 2-2.53 — Guidelines for first aid programs.
  • OSHA STD 1-8.2 — Instruction on eyewash and body flushing facilities in storage battery charging and maintenance areas.

What is required of employers and employees?

  • A chemical’s SDS is generally the indicator that an eyewash/shower is needed for exposure to the substance.
  • If there is the possibility of exposure to injurious corrosive materials, provide suitable facilities for drenching or flushing of the eyes and body.
  • To protect employees from dangerous chemicals, ensure they follow work rules and wear the right PPE.

Employers must:

  • Assess the workplace for substances that could cause harm or adverse effects to the eyes or body. The chemical’s Safety Data Sheet (SDS) is generally the indicator that an eyewash/shower is needed for exposure to the substance. However, there are other guidance available, such as W. Morton Grant’s Toxicology of the Eye (Charles C Thomas Pub. Ltd., 4th edition, August 1993) and the National Institute for Occupational Safety and Health (NIOSH) Pocket Guide to Chemical Hazards.
  • Provide suitable facilities for drenching or flushing of the eyes and body where there is exposure to injurious corrosive materials. The Occupational Safety and Health Administration (OSHA) says a plumbed or self-contained eyewash or shower unit that meets the specifications of American National Standards Institute (ANSI) Z358.1 would be compliant. A personal wash unit (e.g., eyewash bottle) would not be compliant. Eyewash bottles can only be used to support a plumbed or self-contained unit but cannot replace them.
  • Ensure eyewash/showers are located within 10 seconds of the hazard.
  • Ensure eyewashes can deliver a minimum of .4 gallons of flushing fluid per minute for 15 minutes.
  • Ensure showers can deliver a minimum of 20 gallons of flushing fluid per minute for 15 minutes.
  • Inspect and maintain eyewash/shower equipment per manufacturer’s specifications and instructions.
  • Train employees on locations and use of eyewash/shower equipment.

Training for employees

The best protection from dangerous chemicals is to ensure that employees follow work rules and wear the right personal protective equipment (PPE). Employees should know how to get first aid and where the eyewash and shower stations are located. Employees must also know how to activate the emergency medical system.

Provide the following instructions to employees on how to use the emergency eyewash:

  • Don’t panic. Calmly make your way to the eyewash station. If there’s a coworker nearby, ask him or her to help you.
  • Start the eyewash and place your eyes in the stream of water.
  • Use your fingers to hold your eyelids open.
  • Periodically, lift your eyelids further and roll your eyeballs around.
  • Flush for at least 15 minutes. Have someone time you, if possible.
  • Seek medical attention right away.

Following using the eyewash or shower, instruct employees to follow company rules for notifying management of the need to use the eyewash/shower, and seek follow-up medical care.

Training

  • OSHA CPL 2-2.53 explains the formal first-aid training for chemical burns and the importance of flushing out the eye.
  • When training employees, review the employee handout, and stress workplace emergency procedures, especially how to activate the emergency medical system.
  • Explain to employees why it is so important to properly assist fellow employees in distress to reach the eyewash/shower station.

Employee training

While there are no specific training requirements for eyewashes and showers, formal first aid training for chemical burns and the importance of flushing out the eye is explained under Occupational Safety and Health Administration (OSHA) CPL 2-2.53, Guidelines for First Aid Programs.

Training tips

When training employees, review the employee handout, and stress workplace emergency procedures, especially how to activate the emergency medical system.

  • Teach in a language that the trainees understand. If a trainee’s vocabulary is limited, account for that limitation. Translators may be needed.
  • Show employees locations of emergency eyewash/shower stations.
  • Explain when they might have to use it.
  • Demonstrate how to activate the eyewash/shower and review proper use.
  • Remind employees to flush eyes and skin for at least 15 minutes.
  • Emphasize the importance of keeping the path to the equipment free of obstacles.
  • Explain why it is important to properly assist fellow employees in distress to reach the eyewash/shower station.

Inspection and maintenance

  • ANSI standards outline maintenance and inspection regulations for emergency showers and emergency eyewashes.
  • Squeeze bottles also require frequent testing, refilling, and maintenance

Eyewashes and safety showers should be inspected according to manufacturer instructions. Squeeze bottles also require frequent testing, refilling, and maintenance since they lose water to evaporation, become contaminated, and are easily misplaced.

Emergency showers maintenance and inspection

  • Manufacturer operating instructions must be readily accessible to maintenance personnel (ANSI Z358.1-2014).
  • Plumbed showers must be activated weekly (ANSI Z358.1-2014).
  • Self-contained showers must be visually checked in accordance with the manufacturer’s instructions to determine if flushing fluid needs to be changed or supplemented (ANSI Z358.1-2014).
  • Showers must be inspected annually (ANSI Z358.1-2014).

Emergency eyewashes maintenance and inspection

  • Manufacturer operating instructions must be readily accessible to maintenance personnel (ANSI Z358.1-2014).
  • Plumbed eyewashes must be activated weekly to ensure flushing fluid is available (ANSI Z358.1-2014).
  • Self-contained eyewashes must be visually checked in accordance with the manufacturer’s instructions to determine if flushing fluid needs to be changed or supplemented (ANSI Z358.1-2014).
  • Eyewashes must be inspected annually (ANSI Z358.1-2014).

Location

  • Emergency eyewash and shower installations must meet ANSI specifications.
  • According to ANSI standards, it should only take an injured person 10 seconds or less to reach emergency equipment, which is about 55 feet.
  • Eyewash/shower stations should draw attention to themselves. Emergency equipment should feature prominent signs with large letters, stand in a well-lit area, and be painted with bright colors.

The Occupational Safety and Health Administration (OSHA) does not provide much detail about emergency eyewash and shower installations. Instead, OSHA letters of interpretation state that these installations must meet the specifications of American National Standards Institute (ANSI) Z358.1, Emergency Eyewash and Shower Equipment. OSHA has also released OSHA STD 1-8.2, Instruction on eye wash and body flushing facilities in storage battery charging and maintenance areas. These two documents generally require:

InstallationLocationRate of water deliveryWater temperature
Eye washWithin 55 ft. per ANSI0.4 gal/min. for 15 min.60° to 105° F
ShowerWithin 55 ft. per ANSI20 gal/min. for 15 min.60° to 105° F

Notes:

  • A water hose may be used in conjunction with eye washes or safety showers, but not as a substitute for them.
  • The exposed employee (who may be partly blinded by chemicals) must be able to reach and use the eye wash and/or body drenching equipment within 10 seconds. ANSI says this is 55 feet.
  • Obstructions, such as machines and equipment, must be considered in locating eye wash stations.

10 second rule

If work processes will expose anyone to highly corrosive or extremely dangerous chemicals, then the emergency equipment is required to be immediately adjacent to the work area, meaning there should be no delay in reaching the eyewash/shower station.

  • The ANSI standards say it should only take an injured person 10 seconds or less to reach emergency equipment. ANSI says this is about 55 feet.
  • Employees who need to use emergency eyewashes or showers may experience pain, blurred vision, impaired judgment, or panic
  • Assist affected employees in an emergency. Contact management and emergency medical services whenever the eyewash/shower is used.

Location

The route to the emergency equipment should be easily traveled and free of obstructions. The standards say:

  1. The eyewash/shower should be on the same level. Employees should not have to use staircases or elevators to reach them.
  2. One door between the workspace and the shower station is allowed, but only if there’s no risk of exposure to corrosives. It can’t lock to prevent access.
  3. The path to the equipment should be kept free from any obstruction. Nothing should stand between the injured worker and the eyewash/shower station.
  4. The eyewash/showers should not be placed next to electric hazards. Water and electricity don’t mix.
  5. There should be some way to contain or drain the runoff. 15 minutes of continuous flushing creates quite a puddle!

Eyewash/shower stations should draw attention to themselves. Emergency equipment should feature prominent signs with large letters, stand in a well-lit area, and be painted with bright colors.

Battery charging and eyewashes

Does the Occupational Safety and Health Administration (OSHA) require an eyewash in a forklift battery charging area? Based on an Occupational Safety and Health Review Commission ruling, employers are not required to have an eyewash (and/or shower) station for an area where no maintenance is performed on powered industrial truck batteries; that is, when they are being charged only. However, it would still be considered a best practice to have an eyewash (and/or shower) station in the charging area.

Fluids

  • Because eyewash bottles do not provide an adequate amount of flushing fluid, they cannot be considered a primary means of protection.
  • Both eyewashes and showers should deliver tepid flushing fluid, which is defined in the ANSI standard as a temperature range of 60 to 100 degrees Fahrenheit.

Eyewash bottles

Eyewash bottles do not provide an adequate amount of flushing fluid and cannot be considered a primary means of protection. Employers can provide eyewash bottles in instances where plumbed or self-contained units can’t reasonably be provided (e.g., an outside yard) in the immediate work area, but only until they can reach a plumbed or self-contained unit which can provide the amount of flushing fluid necessary to flush the eyes for at least 15 minutes.

Flushing fluid requirements

Eyewashes should deliver a minimum of 1.5 liters a minute (0.4 gallons a minute) of a potable water or commercial flush for 15 minutes. Showers should deliver a minimum of 75.7 liters a minute (20 gallons a minute) flow of flushing fluid dispersed throughout the pattern.

Both eyewashes and showers should deliver tepid flushing fluid, which is defined in the American National Standards Institute (ANSI) standard as a temperature range of 60 to 100 degrees Fahrenheit.

Common eye/skin hazardous chemicals

  • OSHA expects the employer to determine the level of potential risk to employees and provide protection accordingly.
  • What protection is appropriate at the workplace should be based on a hazard assessment and exposure determination.
  • Commonly encountered hazardous materials may be liquids, gases or solids.

There are times when the use of emergency eyewash and shower equipment becomes crucial in the workplace. In instances where employees are exposed to injurious corrosive materials, The Occupational Safety and Health Administration (OSHA) requires at 29 CFR 1910.151(c) that employers provide suitable facilities for quick drenching or flushing of the eyes and body within the immediate work area. OSHA provides no additional requirements, and as a result, employers often ask whether or not emergency eyewashes or showers are needed at their facility. OSHA says in an April 14, 2008, Letter of Interpretation (LOI) that “the employer must determine if employees can or will be exposed during the course of their duties to hazardous materials in such a way that the protections of an eyewash or emergency shower would be necessary.”

Essentially, OSHA expects the employer to determine the level of potential risk to employees and provide protection accordingly.

What protection is appropriate should be based on a hazard assessment and exposure determination because an employer doesn’t always need an eyewash or shower just because they have chemicals.

Common eye/Skin hazardous chemicals
Source: Minnesota Department of Labor and Industries’ Fact Sheet
Some commonly encountered chemicals that present eye and/or skin hazards are listed below. This list does not include all hazardous chemicals that may be encountered. The hazardous materials may be liquids, gases or solids
Very acidic (low pH)Highly alkaline (high pH)Other
  • Acetic acid
  • Chromic acid (crystals or solution)
  • Hydrochloric acid (muriatic acid)
  • Hydrofluoric acid (glass etching, dry cleaners/laundry)
  • Nitric acid (aqua fortis)
  • Phosphoric acid (solid or liquid)
  • Sulfuric acid (battery acid)
  • Ammonia
  • Ammonium hydroxide (aqueous ammonia)
  • Boiler additives calcium hydroxide (hydrated lime, slaked lime)
  • Calcium oxide (lime, quick lime, unslaked lime)
  • Diethylaminoethanol (boiler treatment)
  • Ethanolamine (corrosion inhibitor, detergents)
  • Ethylenediamine (solvent, photoresist stripper, corrosion inhibitor in antifreeze)
  • Hypochlorites (disinfectants, household bleach)
  • Potassium hydroxide (lye, caustic potash)
  • Sodium hydroxide (lye, caustic soda)
  • Sodium metasilicate (water glass, detergents)
  • Trisodium phosphate (TSP, detergents)
  • Chlorine
  • Chlorine dioxide
  • Cyanoacrylate adhesives (Super glue)
  • Diethylene dioxide (boiler treatment, toxic through skin absorption)
  • Epoxy resins (epichlorohydrin/bisphenol A)
  • Ethylene oxide (gas sterilant)
  • Formaldehyde (gas, or up to 50 percent solution, Formalin)
  • Glutaraldehyde (cold sterilant)
  • Hydrogen peroxide (> 5 percent, a bleach)
  • Isocyanates (MDI, TDI)
  • Methyl ethyl ketone peroxide (MEKP, catalyst for styrene resins)
  • Any chemical labeled oxidizer, corrosive, or caustic

OSHA says employers should refer to the chemical’s Safety Data Sheet (SDS) when making this evaluation. For example, if the SDS indicates irritation only, an eyewash or shower may not be required. On the other hand, if the SDS states that burns, corneal damage, or blindness could happen, the material would be considered hazardous and an eyewash and possibly a shower must be provided. Employers should also consult with the product manufacturer and sources such as the National Institute for Occupational Safety and Health (NIOSH) “Pocket Guide to Chemical Hazards.” The guide lists the physical and chemical properties and health hazards for many different substances. If the entry for the material in question says, “provide quick drench,” this would obviously be an indication that an eyewash or shower is needed. Also, in a May 5, 2004, LOI, OSHA says that employers should consult references such as W. Morton Grant’s “Toxicology of the Eye” when considering potential chemical exposures to the eye and the appropriateness of installing eyewashes to protect employees against hazards associated with particular chemicals and substances.

An emergency eyewash or shower isn’t necessarily needed just because an employer possesses an injurious corrosive material. In an April 14, 2008, LOI, OSHA also says that: “If hazardous materials are present at a worksite in such a way that exposure could not occur (for example, in sealed containers that will not be opened, or caustic materials in building piping), then an eyewash or emergency shower would not be necessary. However, if the building piping containing caustic materials has, at certain locations, a spigot or tap from which the contents are to be sampled or withdrawn and employees are expected to perform such tasks, then, certainly, an eyewash and/or emergency shower would be needed where this task is to occur.” Therefore, when determining exposure, an employer should evaluate the potential for the material to get into the eyes or on the skin.

Employers must consider the type of equipment, worksite conditions, and quantity of exposure among other things. For example, if there is the potential for substantial exposure to the body, then a shower would be needed also. If only the eyes could be impacted, then an eyewash may be all that is needed.

FAQs

  • ANSI standards require that plumbed and self-contained eyewash units must provide flushing fluid to “both eyes simultaneously.”
  • Although OSHA does not have a specific requirement for eyewash fluid temperature, the agency notes that water which is too hot or too cold will prevent the affected person from flushing the eyes for the recommended full 15 minutes.
  • If a chemical splashes into the eye, it should be flushed out for 15 minutes; serious burns (i.e., strong alkalis or acids) should be flushed for 20 to 30 minutes.

Do eyewashes always have to have two separate flush heads?

The Occupational Health and Safety Administration (OSHA) regulates eyewash stations in its 1910.151(c) standard on medical services and first aid. Unfortunately, OSHA does not go into much more detail on eyewashes. However, where the regulations are silent on the details regarding eyewashes and showers, OSHA has referred to the American National Standards Institute (ANSI) standard Z358.1 Emergency Eyewash and Shower Equipment for specific requirements.

The ANSI standard requires that plumbed and self-contained eyewash units must provide flushing fluid to “both eyes simultaneously.” It may be a good idea to check with your safety supplier as to whether or not this “simultaneous” flushing can be accomplished with one flush head.

How many eyewash stations are required and where must they be located?

The OSHA standard which requires emergency eyewashes and showers does not provide detail on the location or number of eyewash stations at a facility, but states that suitable facilities for quick flushing of the eyes and body are to be provided “within the work area for immediate emergency use.”

ANSI Z358.1 requires that eyewash units must be in accessible locations that can be reached within 10 seconds. The path of travel to the eyewash or shower station must remain clear of obstructions and the eyewash must be located on the same level as the hazard.

What is the required water temperature in a plumbed eyewash station?

OSHA does not have a specific requirement for eyewash fluid temperature. In a letter of interpretation dated April 18, 2002, OSHA notes that water which is too hot or too cold will prevent the affected person from flushing the eyes for the recommended full 15 minutes.

The ANSI Z358.1 industry consensus standard for emergency eyewash and shower equipment states that the water should be “tepid,” which is defined as a temperature range of 60 to 100 degrees Fahrenheit.

Chemical splashes

If a chemical splashes into an eye:

  1. Quickly flush the eyes with lots of water for at least 15 minutes (for best results, do so at an eyewash station or safety shower).
  2. For serious burns (i.e., strong alkalis or acids), flushing should continue for 20 to 30 minutes which requires a considerable amount of water.
  3. Force the eyes open to wash chemical out.
  4. Do not bandage eyes.
  5. Seek medical attention.

Is a sign required to indicate the location of an eyewash or shower?

OSHA does not address eyewash or shower signs, but ANSI Z358.1-2014 states that a highly visible sign must be positioned to clearly identify the location of the unit.

Battery charging areas

  • Employers are not required to have an eyewash (and/or shower) station for an area where no maintenance is performed on powered industrial truck batteries; that is, when they are being charged only.
  • At locations where hazardous chemicals are handled by employees (e.g., battery servicing facility), proper eyewash and body drenching equipment must be available.
  • It is considered a “best practice” to have an eyewash or shower station in the charging area, and an employer’s liability insurance carrier may require one in these areas.

Battery charging and eyewashes

Does OSHA require an eyewash in a forklift battery charging area? OSHA says, based on an Occupational Safety and Health Review Commission ruling, that employers are not required to have an eyewash (and/or shower) station for an area where no maintenance is performed on powered industrial truck batteries; that is, when they are being charged only. It would still be considered a best practice to have an eyewash (and/or shower) station in the charging area, however.

Is an eyewash or shower required in a battery charging area?

OSHA specifically addresses battery charging areas in a number of Letters of Interpretation, including a July 26, 1994, letter which states, “At locations where hazardous chemicals are handled by employees (e.g., battery servicing facility), proper eyewash and body drenching equipment must be available.”

In other words, if maintenance is being done, suitable facilities for quick drenching or flushing of the eyes and body are required per 1910.151(c). On the other hand, no eyewash or shower is required if no maintenance is performed on powered industrial truck batteries; that is, when batteries are being charged only. This enforcement policy was affirmed in an Occupational Safety and Health Review Commission decision.

It would still be considered a “best practice” to have an eyewash or shower station in the charging area, and an employer’s liability insurance carrier may require one in these areas.

ANSI Z358.1: An American National Standard that provides specifications for the design, testing, maintenance, and use of emergency eyewash and shower facilities. The Occupational Safety and Health Administration (OSHA) accepts equipment meeting ANSI Z358.1 specifications as being sufficient for compliance with 1910.151(c).

OSHA uses the associated ANSI standard during inspections when evaluating the suitability of emergency eyewash and shower protection provided by the employer as stated in a November 1, 2002, Letter of Interpretation (LOI).

Is ANSI Z358.1 enforced by OSHA?

Yes, OSHA uses ANSI Z358.1-2014 in enforcement. Under 1910.151(c), OSHA requires that “suitable” facilities for the quick drenching of the eyes and body be provided where employees may be exposed to injurious corrosive materials. The agency says in a November 1, 2002, LOI that, “If OSHA inspects a workplace and finds unsuitable facilities for quick drenching or flushing of the eyes and body, a citation under 29 CFR 1910.151(c) would be issued. When determining whether the eyewash or shower facilities are suitable given the circumstances of a particular worksite, OSHA may refer to the most recent consensus standard regarding eyewash or shower equipment ...” Without the ANSI standard, employers would find it difficult to demonstrate to OSHA exactly how their eyewash and/or shower units were “suitable” exclusive to the regulatory language under 1910.151(c) since it is limited and vague.

First-aid kits for emergencies

  • First-aid kits must be visibly marked and in good repair.
  • First-aid kits must be stocked with the required unexpired supplies.
  • First-aid kits must be easily accessible in case of an emergency.

Location

The kit must be located in an area which permits easy accessibility in the event of an emergency.

Marking and labeling

The kit and/or location of the kit must be visibly marked.

Condition

  • The outside of the kit must be in good repair to adequately protect supplies.
  • The interior of the kit should not show evidence of moisture or other contamination.
  • All supplies should be secure in their original packaging or container.
  • All supplies with an expiration date should not be expired.

Guide

  • A first-aid guide must be present.
  • The first-aid guide should describe the care needed to be administered until more advanced care can be provided.

Required supplies

  • At least 16 individually packaged, sealed, and sterile adhesive bandages measuring 1 x 3 inches.
  • At least 1 roll of adhesive tape measuring a minimum of 2 1/2 yards.
  • At least 10 individual use packets containing a minimum of 1/57 fluid ounces of antibiotic ointment.
  • At least 10 individual use packets containing a minimum of 1/57 fluid ounces of antiseptic.
  • At least 10 individual use packets or spray containers with a minimum of 1/32 ounces of burn treatment.
  • At least 1 burn dressing/pad (gel soaked) measuring a minimum of 4 x 4 square inches.
  • At least 2 sterile pads measuring a minimum of 3 x 3 inches.
  • At least 1 triangular bandage made from muslin measuring a minimum of 40 x 40 x 56 inches when unfolded.
  • At least 2 pairs of medical grade exam gloves.
  • At least 1 cold pack measuring a minimum of 4 x 5 inches. An individually packaged, single use, disposable breathing barrier containing instructions for use.
  • At least 2 individually packaged, sealed, and sterile eye coverings, with means of attachment, measuring a minimum of 2.9 square inches.
  • An individual use, sterile, isotonic, buffered eye/skin wash containing a minimum of 1 fluid ounces.
  • At least 6 containers of hand sanitizer containing a minimum of 1/32 fluid ounces.
  • At least 1 roller bandage measuring a minimum of 2 inches x 4 yards.
  • At least 2 trauma pads measuring a minimum of 5 x 9 inches.
  • A pair of scissors.
  • If a Class B first aid kit, a splint measuring a minimum of 4 x 24 inches must be present.
  • If a Class B first aid kit, a tourniquet measuring a minimum of 1 inch wide must be present.

Emergency Action Plan

  • Employers need to create a workplace EAP so that employees know what to do in case of an emergency.
  • When an emergency occurs, the first thing to remember is to remain calm.
  • Use the memory jogger “Check-Call-Care” as a reminder of what to do in an emergency.

The following information is an example of what should be included in a workplace Emergency Action Plan (EAP).

Overview

There is nothing new about workplace accidents and injuries. They happen frequently. Thankfully, they are usually minor, but occasionally a coworker may be seriously injured or even killed on the job.

Here is what should be done in case of emergency.

Remain calm

When someone witnesses an injury or comes upon an accident scene, the first thing to remember is to remain calm, and don’t panic. Try to think clearly about what should be done to make the scene safe and to help an injured coworker.

To help remember what to do, use this memory jogger: “Check-Call-Care.”

Check

First, check the scene:

  • to find out what has happened;
  • to determine if it is safe for personnel to enter or stay. If it is not safe, do not enter;
  • for bystanders who saw what happened, or who can assist;
  • for the number of victims.

Next, check the victim to determine if:

  • they are breathing;
  • there is a pulse; or
  • there are any life-threatening conditions.

Call

Call (or have someone else call) the workplace emergency number to report the accident or injury. Be ready to explain where the event occurred, the number of victims and their condition, and what care is being given.

Care

Finally, provide care. If the victim is conscious, ask permission first. Deal with any life-threatening conditions immediately, and then move on to less threatening conditions.

Remember, providing care may mean just staying present at the scene and waiting for the arrival of emergency responders. Reassure the victim that help is coming.

Emergencies in the workplace

The employer will explain to the employees how to contact emergency services at the workplace, as well as the location of first-aid supplies, along with any other emergency information employees should know.

Emergency Action Plan

  • Employers need to create a workplace EAP so that employees know what to do in case of an emergency.
  • When an emergency occurs, the first thing to remember is to remain calm.
  • Use the memory jogger “Check-Call-Care” as a reminder of what to do in an emergency.

The following information is an example of what should be included in a workplace Emergency Action Plan (EAP).

Overview

There is nothing new about workplace accidents and injuries. They happen frequently. Thankfully, they are usually minor, but occasionally a coworker may be seriously injured or even killed on the job.

Here is what should be done in case of emergency.

Remain calm

When someone witnesses an injury or comes upon an accident scene, the first thing to remember is to remain calm, and don’t panic. Try to think clearly about what should be done to make the scene safe and to help an injured coworker.

To help remember what to do, use this memory jogger: “Check-Call-Care.”

Check

First, check the scene:

  • to find out what has happened;
  • to determine if it is safe for personnel to enter or stay. If it is not safe, do not enter;
  • for bystanders who saw what happened, or who can assist;
  • for the number of victims.

Next, check the victim to determine if:

  • they are breathing;
  • there is a pulse; or
  • there are any life-threatening conditions.

Call

Call (or have someone else call) the workplace emergency number to report the accident or injury. Be ready to explain where the event occurred, the number of victims and their condition, and what care is being given.

Care

Finally, provide care. If the victim is conscious, ask permission first. Deal with any life-threatening conditions immediately, and then move on to less threatening conditions.

Remember, providing care may mean just staying present at the scene and waiting for the arrival of emergency responders. Reassure the victim that help is coming.

Emergencies in the workplace

The employer will explain to the employees how to contact emergency services at the workplace, as well as the location of first-aid supplies, along with any other emergency information employees should know.

Who does this apply to?

  • Employers must ensure that adequate first-aid supplies are available, prompt first-aid is administered, and eyewash/body flush facilities are available.
  • Employers must ensure that employees are trained in first-aid programs and employees who are expected to provide first aid or medical services must be trained in OSHA’s BBP standard.

Employers must:

  • Determine the need for first-aid supplies and for medical and first-aid services.
  • Ensure that “adequate” first-aid supplies are available at the worksite. The first-aid supplies should reflect the kinds of injuries that occur and must be stored in an area where they are readily available for emergency access. Note that some industries have specific requirements for the first-aid kit locations and contents.
  • Set up a schedule for checking and replenishing the content of the first-aid kit(s).
  • Ensure prompt first-aid treatment for injured employees either by employing a trained first-aid provider at the worksite, or by ensuring that emergency treatment services are within reasonable proximity of the worksite. However, if life-threatening injuries can be reasonably expected, and outside emergency responders are more than 3-4 minutes away, the employer must ensure that trained personnel are available at the workplace. They must also be provided with periodic refresher training.
  • If corrosive materials are used, ensure eyewash and body flush facilities are provided.
  • Instruct all workers about the first-aid program, including instruction on what workers should do if a coworker is injured or ill. A written program of first-aid policies and procedures is recommended, to ensure all the program elements are implemented.
  • Employees who are expected to provide first aid or medical services must be trained per the Occupational Safety and Health Administration’s (OSHA) Bloodborne Pathogens (BBP) standard. Good Samaritans are not covered by OSHA’s BBP standard.
  • Record on the 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.)

What are the key definitions?

  • OSHA refers to ANSI Z308.1 to define the minimal contents of a workplace first-aid kit.
  • First aid is emergency care provided for sudden injury or illness before medical treatment is available. A person trained in the delivery of initial medical emergency procedures is referred to as the first-aid provider.
  • Emergency care must be in near proximity to the workplace, meaning no more than 3-4 minutes away.

ANSI Z308.1: An American National Standards Institute (ANSI) standard that the Occupational Safety and Health Administration (OSHA) refers to as the minimal contents of a workplace first aid kit. OSHA’s referral is non-mandatory, and the kits described are suitable for small businesses.

ANSI Z358.1: An ANSI standard that provides specifications for the design, testing, maintenance, and use of emergency eyewash and shower facilities. OSHA accepts equipment meeting ANSI Z358.1 specifications as being sufficient for compliance with 1910.151(c).

First aid: Emergency care provided for injury or sudden illness before emergency medical treatment is available. The first-aid provider in the workplace is a person trained in the delivery of initial medical emergency procedures, using a limited amount of equipment to perform a primary assessment and intervention while awaiting the arrival of emergency medical service (EMS) personnel.

Near proximity: For the purposes of 29 CFR 1910.151, OSHA interprets the term “near proximity” to mean that emergency care must be available within no more than three to four minutes from the workplace.

Corrosive: A chemical that causes visible destruction of, or irreversible alterations in, living tissue by chemical action at the site of contact. In general, corrosive materials have a very low pH (acids) or a very high pH (bases). Strong bases are usually more corrosive than acids. Examples of corrosive materials are sodium hydroxide (lye) and sulfuric acid.

Exposure: In terms of the requirement to provide an eyewash/shower, “exposure” means that there is an actual or likely chance that an employee’s eyes and/or body could come into contact with a corrosive material. If hazardous materials are present at a worksite in such a way that exposure could not occur (for example, in sealed containers that will not be opened, or caustic materials in building piping), then an eyewash or emergency shower would not be necessary. However, if the building piping containing caustic materials has, at certain locations, a spigot or tap from which the contents are to be sampled or withdrawn, and employees are expected to perform such tasks, then, an emergency eyewash and/or shower would be needed where this task is to occur.

Flushing fluid: Potable water, preserved water, preserved buffered saline solution or other medically acceptable solution.

Tepid: Flushing fluid that is a temperature which promotes continuous flushing for the required minimum of 15 minutes. ANSI defines tepid as a temperature range between 60- and 100-degrees Fahrenheit.

First aid and medical requirements (General industry)

  • In the event of an emergency, employees must know what to do and where first-aid kits and emergency eyewash stations are located.
  • The basic steps of first aid include calling for help, analyzing the situation, refraining from moving the victim, evaluating for signs of life, controlling heavy bleeding, treating for shock, treating for choking, treating for burns, treating for chemical burns to the eye, and treating for fracture.
  • First-aid supplies and other medical services must be available at the workplace, and it is recommended that employees be trained in administering first aid and CPR.

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.

The following table lays out some basic first-aid information:

First aid basicsDetails
Call for helpIf the employee is not alone, they should have someone go for help immediately. If they are alone, immediate care is a priority. However, that immediate care may be going for help.
Analyze the situationEmployees must take precautions to avoid becoming a victim themselves. If they can safely do so, they should move the victim away from any sources of danger such as water, fire, or downed power lines. All power sources should be turned off before touching an electrocuted victim.
Don’t move the victimIf there is any chance of spine or neck injury, the victim should not be moved unless they are in a life-threatening situation.
Look for signs of lifeLook for signs of life and give artificial respiration or cardiopulmonary resuscitation (CPR) if necessary but only if employees have been trained. Confirm that help is on the way before starting CPR. Do not tilt the victim’s head back if there is a suspected neck injury.
Control heavy bleedingStop the flow of blood by applying direct pressure and/or elevating the injury above the heart or pressure points. Do not use a tourniquet unless the person is in danger of bleeding to death and employees have been trained to apply one.
Treat for shockSigns of shock include cold, pale skin; a rapid, faint pulse; nausea; rapid breathing; and weakness. To treat for shock, keep the victim lying down; cover them only enough to maintain body heat; don’t move the victim unless absolutely necessary; and get medical help immediately.
Treat for chokingA person can choke to death in a few minutes. A sign of choking is if a person can’t speak, cough, or breathe. If the person is choking, use the Heimlich Maneuver.
Treat for burnsFor small burns, gently soak the burn in cold water or pour cold water on the burn. Don’t treat large burns with water unless they’re chemical burns. Cover the burn with a dry, sterile bandage. Provide artificial respiration as needed. Seek medical attention. Some chemicals should not be flushed with water but neutralized by other means—see chemical label.
Treat for chemical burn in eyeQuickly flush the eyes with lots of water for at least 15 minutes (for best results, do so at an eyewash station, emergency shower, or hose). Try to force the eyes open to wash chemical out. Do not bandage eyes. Seek medical attention.
Treat for fractureDo not move the victim unless absolutely necessary. This is especially important if there is a suspected neck or back injury. Seek medical help.

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

  • OSHA accepts any first-aid training program that covers the fundamental requirements.
  • First-aid training programs should adequately cover the types of illnesses and injuries that are likely to occur in the workplace.
  • Trainees should be tested upon completion and retraining should occur annually.

The first-aid training program should be kept updated with current first-aid techniques and knowledge. Outdated training and reference materials should be replaced or removed.

The Occupational Safety and Health Administration (OSHA) recognizes any nationally accepted and medically sound first-aid training program that covers the fundamentals of first aid as meeting the requirements stated in 29 CFR 1910.151.

Each employer using any first aid and/or cardiopulmonary resuscitation (CPR) courses must ensure that the course adequately covers the types of injuries/illnesses likely to be encountered in the workplace.

According to OSHA CPL 2-2.53, these are the general program elements required for a training program:

  1. Emphasis on “hands-on” training involving mannequins and trainee partners.
  2. Exposure to acute injury and illness settings as well as appropriate response including the use of visual aids.
  3. Include a course workbook.
  4. Allow enough time for the course to cover likely situations for your facility.
  5. Emphasis on quick response.

Topics to be included:

  1. Injury and acute illness;
  2. Working with local emergency response system and teams, and how they are to be contacted;
  3. Principles of triage;
  4. Legal aspects of providing first aid;
  5. Methods of surveying an incident scene and assessment of need for first aid and how to provide it safely;
  6. Performing primary survey(s) of victim(s), including airway, breathing and circulation;
  7. Getting a victim’s health history at the scene;
  8. CPR;
  9. Bandaging;
  10. Splinting;
  11. Rescue and transport of victim(s);
  12. Personal protective equipment (PPE); and
  13. Tagging and disposal of any contaminated sharp or material. See Bloodborne Pathogens topic.

Trainees should be tested upon completion of initial training. Assessment should include instructor observation of acquired skills and written performance assessments.

First-aid responders may have long intervals between learning and using CPR and automated external defibrillator (AED) skills. OSHA recommends that instructor-led retraining for life-threatening emergencies should occur at least annually. Retraining for non-life-threatening response should occur periodically.

Must emergency responders be certified?

If an employer is required to have employees who are “trained responders” on site per an applicable standard (e.g., permit-required confined spaces), then they must have current certifications. Typically, these certifications are administered by the entity which provides the training (e.g., American Red Cross, American Heart Association, National Safety Council, etc.). As such, an employer would be expected to follow that entity’s re-certification schedule as necessary.

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.

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.

Additional emergency

  • AEDs are not required to be included in first-aid supplies.
  • OSHA recommends employers consider AED equipment as part of a medical and first-aid program.
  • If it is reasonably anticipated that employees will be exposed to blood or other potentially infectious materials while using first-aid supplies, employers are required to provide appropriate PPE.

Automated external defibrillators (AED) are not required to be included in first-aid supplies; however, the Occupational Safety and Health Administration (OSHA) recommends employers consider the equipment as part of a medical and first-aid program. All worksites are potential candidates for AED programs because of the possibility of sudden cardiac arrest (SCA) and the need for timely defibrillation. Each workplace must make a determination based upon its own requirements.

AEDs provide the critical and necessary treatment for SCA caused by ventricular fibrillation, the uncoordinated beating of the heart leading to collapse and death. Using AEDs as soon as possible after SCA, within 3-4 minutes, can lead to a 60% survival rate among victims of SCA.

PPE

If it is reasonably anticipated that employees will be exposed to blood or other potentially infectious materials while using first-aid supplies, employers are required to provide appropriate personal protective equipment (PPE).

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.

Use of the OSHA 300 Log, OSHA 301

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, Federal Occupational Health at www.foh.dhhs.gov, 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:

  1. 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.
  2. 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.
  3. 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.
  4. 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.
  5. 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.

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

  • OSHA accepts any first-aid training program that covers the fundamental requirements.
  • First-aid training programs should adequately cover the types of illnesses and injuries that are likely to occur in the workplace.
  • Trainees should be tested upon completion and retraining should occur annually.

The first-aid training program should be kept updated with current first-aid techniques and knowledge. Outdated training and reference materials should be replaced or removed.

The Occupational Safety and Health Administration (OSHA) recognizes any nationally accepted and medically sound first-aid training program that covers the fundamentals of first aid as meeting the requirements stated in 29 CFR 1910.151.

Each employer using any first aid and/or cardiopulmonary resuscitation (CPR) courses must ensure that the course adequately covers the types of injuries/illnesses likely to be encountered in the workplace.

According to OSHA CPL 2-2.53, these are the general program elements required for a training program:

  1. Emphasis on “hands-on” training involving mannequins and trainee partners.
  2. Exposure to acute injury and illness settings as well as appropriate response including the use of visual aids.
  3. Include a course workbook.
  4. Allow enough time for the course to cover likely situations for your facility.
  5. Emphasis on quick response.

Topics to be included:

  1. Injury and acute illness;
  2. Working with local emergency response system and teams, and how they are to be contacted;
  3. Principles of triage;
  4. Legal aspects of providing first aid;
  5. Methods of surveying an incident scene and assessment of need for first aid and how to provide it safely;
  6. Performing primary survey(s) of victim(s), including airway, breathing and circulation;
  7. Getting a victim’s health history at the scene;
  8. CPR;
  9. Bandaging;
  10. Splinting;
  11. Rescue and transport of victim(s);
  12. Personal protective equipment (PPE); and
  13. Tagging and disposal of any contaminated sharp or material. See Bloodborne Pathogens topic.

Trainees should be tested upon completion of initial training. Assessment should include instructor observation of acquired skills and written performance assessments.

First-aid responders may have long intervals between learning and using CPR and automated external defibrillator (AED) skills. OSHA recommends that instructor-led retraining for life-threatening emergencies should occur at least annually. Retraining for non-life-threatening response should occur periodically.

Must emergency responders be certified?

If an employer is required to have employees who are “trained responders” on site per an applicable standard (e.g., permit-required confined spaces), then they must have current certifications. Typically, these certifications are administered by the entity which provides the training (e.g., American Red Cross, American Heart Association, National Safety Council, etc.). As such, an employer would be expected to follow that entity’s re-certification schedule as necessary.

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.

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.

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

  • OSHA accepts any first-aid training program that covers the fundamental requirements.
  • First-aid training programs should adequately cover the types of illnesses and injuries that are likely to occur in the workplace.
  • Trainees should be tested upon completion and retraining should occur annually.

The first-aid training program should be kept updated with current first-aid techniques and knowledge. Outdated training and reference materials should be replaced or removed.

The Occupational Safety and Health Administration (OSHA) recognizes any nationally accepted and medically sound first-aid training program that covers the fundamentals of first aid as meeting the requirements stated in 29 CFR 1910.151.

Each employer using any first aid and/or cardiopulmonary resuscitation (CPR) courses must ensure that the course adequately covers the types of injuries/illnesses likely to be encountered in the workplace.

According to OSHA CPL 2-2.53, these are the general program elements required for a training program:

  1. Emphasis on “hands-on” training involving mannequins and trainee partners.
  2. Exposure to acute injury and illness settings as well as appropriate response including the use of visual aids.
  3. Include a course workbook.
  4. Allow enough time for the course to cover likely situations for your facility.
  5. Emphasis on quick response.

Topics to be included:

  1. Injury and acute illness;
  2. Working with local emergency response system and teams, and how they are to be contacted;
  3. Principles of triage;
  4. Legal aspects of providing first aid;
  5. Methods of surveying an incident scene and assessment of need for first aid and how to provide it safely;
  6. Performing primary survey(s) of victim(s), including airway, breathing and circulation;
  7. Getting a victim’s health history at the scene;
  8. CPR;
  9. Bandaging;
  10. Splinting;
  11. Rescue and transport of victim(s);
  12. Personal protective equipment (PPE); and
  13. Tagging and disposal of any contaminated sharp or material. See Bloodborne Pathogens topic.

Trainees should be tested upon completion of initial training. Assessment should include instructor observation of acquired skills and written performance assessments.

First-aid responders may have long intervals between learning and using CPR and automated external defibrillator (AED) skills. OSHA recommends that instructor-led retraining for life-threatening emergencies should occur at least annually. Retraining for non-life-threatening response should occur periodically.

Must emergency responders be certified?

If an employer is required to have employees who are “trained responders” on site per an applicable standard (e.g., permit-required confined spaces), then they must have current certifications. Typically, these certifications are administered by the entity which provides the training (e.g., American Red Cross, American Heart Association, National Safety Council, etc.). As such, an employer would be expected to follow that entity’s re-certification schedule as necessary.

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.

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.

Additional emergency

  • AEDs are not required to be included in first-aid supplies.
  • OSHA recommends employers consider AED equipment as part of a medical and first-aid program.
  • If it is reasonably anticipated that employees will be exposed to blood or other potentially infectious materials while using first-aid supplies, employers are required to provide appropriate PPE.

Automated external defibrillators (AED) are not required to be included in first-aid supplies; however, the Occupational Safety and Health Administration (OSHA) recommends employers consider the equipment as part of a medical and first-aid program. All worksites are potential candidates for AED programs because of the possibility of sudden cardiac arrest (SCA) and the need for timely defibrillation. Each workplace must make a determination based upon its own requirements.

AEDs provide the critical and necessary treatment for SCA caused by ventricular fibrillation, the uncoordinated beating of the heart leading to collapse and death. Using AEDs as soon as possible after SCA, within 3-4 minutes, can lead to a 60% survival rate among victims of SCA.

PPE

If it is reasonably anticipated that employees will be exposed to blood or other potentially infectious materials while using first-aid supplies, employers are required to provide appropriate personal protective equipment (PPE).

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.

Use of the OSHA 300 Log, OSHA 301

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, Federal Occupational Health at www.foh.dhhs.gov, 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:

  1. 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.
  2. 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.
  3. 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.
  4. 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.
  5. 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.

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.

Use of the OSHA 300 Log, OSHA 301

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, Federal Occupational Health at www.foh.dhhs.gov, and the National Center for Early Defibrillation at www.early-defib.org can provide additional information about AED program development.

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