Be Part of the Ultimate Safety & Compliance Community
Trending news, knowledge-building content, and more – all personalized to you!
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.
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.
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
Guide
Required supplies
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:
Next, check the victim to determine if:
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.
Employers must:
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.
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 basics | Details |
---|---|
Call for help | If 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 situation | Employees 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 victim | If 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 life | Look 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 bleeding | Stop 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 shock | Signs 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 choking | A 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 burns | For 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 eye | Quickly 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 fracture | Do 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 other medical services must be available at the workplace.
The minimum Occupational Safety and Health Administration (OSHA) requirements are:
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:
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.
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.
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:
Topics to be included:
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.
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.
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:
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.
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.
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
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:
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.
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
Confined spaces rescue and emergency services
General safety and health provisions-first aid and medical attention
First aid kits (non-mandatory)
Occupational health and environmental controls
Special industries
Logging
Electric power generation, transmission and distribution
General industries
General environmental controls-permit-required confined spaces
Commercial diving operations-qualifications of dive team
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.
First aid supplies are required to be easily accessible under paragraph 1926.50(d)(1). The American National Standards Institute (ANSI) has updated their Z308.1-2021, Minimum Requirements for Workplace First Aid Kits, effective October 15, 2022.
The ANSI standard has not been adopted by OSHA; therefore, is not mandatory for OSHA compliance. OSHA currently references ANSI Z301.1-1998 in Appendix A. This being said, OSHA often references the most recent consensus standard as a source of guidance to ensure employers are meeting the standard or the requirements of the General Duty Clause.
Employers who have unique or changing first-aid needs in their workplace, may need to enhance their first-aid kits. The employer can use the OSHA 300 Log of Work-Related Injuries and Illnesses, the 300-A Summary of Work-Related Injuries and Illnesses, or the OSHA 301 Injury and Illness Incident Report to identify these unique problems. Consultation from the local Fire/Rescue Department, appropriate medical professional, or local emergency room may be helpful to employers in these circumstances. By assessing the specific needs of their workplace, employers can ensure that reasonably anticipated supplies are available. Employers should assess the specific needs of their worksite periodically and augment the first aid kit appropriately.
If it is reasonably anticipated employees will be exposed to blood or other potentially infectious materials while using first-aid supplies, employers should provide personal protective equipment (PPE). Appropriate PPE includes gloves, gowns, face shields, masks, and eye protection.
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:
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.
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:
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:
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.
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.
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.
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:
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.
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:
State and local codes should be reviewed on a regular basis to keep current with the requirements.
Automated External Defibrillator (AED)
Modern AEDs:
Sudden Cardiac Arrest (SCA)
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.
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.
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.
OSHA
Consensus standards
Emergency Action Plan
AED user manual
State AED regulations
Other sources of information
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
General
Design and installation
Location
Marking and labeling
Operation
Flushing fluid
Maintenance and inspection
Training
Personal wash units
Drench hoses
Emergency showers
General
Design and installation
Location
Marking and labeling
Operation
Flushing fluid
Maintenance and inspection
Training
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 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:
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.
There are several types of wash stations and showers. You should be aware of a few distinctions:
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
Other sources of information
Employers must:
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:
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.
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.
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
Emergency eyewashes maintenance and inspection
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:
Installation | Location | Rate of water delivery | Water temperature |
---|---|---|---|
Eye wash | Within 55 ft. per ANSI | 0.4 gal/min. for 15 min. | 60° to 105° F |
Shower | Within 55 ft. per ANSI | 20 gal/min. for 15 min. | 60° to 105° F |
Notes:
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.
Location
The route to the emergency equipment should be easily traveled and free of obstructions. The standards say:
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.
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.
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 |
|
|
|
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.
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:
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 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.
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
Guide
Required supplies
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:
Next, check the victim to determine if:
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.
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:
Next, check the victim to determine if:
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.
Employers must:
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.
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 basics | Details |
---|---|
Call for help | If 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 situation | Employees 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 victim | If 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 life | Look 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 bleeding | Stop 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 shock | Signs 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 choking | A 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 burns | For 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 eye | Quickly 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 fracture | Do 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 other medical services must be available at the workplace.
The minimum Occupational Safety and Health Administration (OSHA) requirements are:
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:
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.
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.
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:
Topics to be included:
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.
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.
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:
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.
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.
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
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:
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.
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
Confined spaces rescue and emergency services
General safety and health provisions-first aid and medical attention
First aid kits (non-mandatory)
Occupational health and environmental controls
Special industries
Logging
Electric power generation, transmission and distribution
General industries
General environmental controls-permit-required confined spaces
Commercial diving operations-qualifications of dive team
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.
First aid supplies are required to be easily accessible under paragraph 1926.50(d)(1). The American National Standards Institute (ANSI) has updated their Z308.1-2021, Minimum Requirements for Workplace First Aid Kits, effective October 15, 2022.
The ANSI standard has not been adopted by OSHA; therefore, is not mandatory for OSHA compliance. OSHA currently references ANSI Z301.1-1998 in Appendix A. This being said, OSHA often references the most recent consensus standard as a source of guidance to ensure employers are meeting the standard or the requirements of the General Duty Clause.
Employers who have unique or changing first-aid needs in their workplace, may need to enhance their first-aid kits. The employer can use the OSHA 300 Log of Work-Related Injuries and Illnesses, the 300-A Summary of Work-Related Injuries and Illnesses, or the OSHA 301 Injury and Illness Incident Report to identify these unique problems. Consultation from the local Fire/Rescue Department, appropriate medical professional, or local emergency room may be helpful to employers in these circumstances. By assessing the specific needs of their workplace, employers can ensure that reasonably anticipated supplies are available. Employers should assess the specific needs of their worksite periodically and augment the first aid kit appropriately.
If it is reasonably anticipated employees will be exposed to blood or other potentially infectious materials while using first-aid supplies, employers should provide personal protective equipment (PPE). Appropriate PPE includes gloves, gowns, face shields, masks, and eye protection.
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:
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.
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:
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:
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.
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.
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.
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:
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 other medical services must be available at the workplace.
The minimum Occupational Safety and Health Administration (OSHA) requirements are:
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:
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.
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.
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:
Topics to be included:
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.
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.
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:
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.
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.
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.
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:
Topics to be included:
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.
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.
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:
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.
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.
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
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:
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.
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
Confined spaces rescue and emergency services
General safety and health provisions-first aid and medical attention
First aid kits (non-mandatory)
Occupational health and environmental controls
Special industries
Logging
Electric power generation, transmission and distribution
General industries
General environmental controls-permit-required confined spaces
Commercial diving operations-qualifications of dive team
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.
First aid supplies are required to be easily accessible under paragraph 1926.50(d)(1). The American National Standards Institute (ANSI) has updated their Z308.1-2021, Minimum Requirements for Workplace First Aid Kits, effective October 15, 2022.
The ANSI standard has not been adopted by OSHA; therefore, is not mandatory for OSHA compliance. OSHA currently references ANSI Z301.1-1998 in Appendix A. This being said, OSHA often references the most recent consensus standard as a source of guidance to ensure employers are meeting the standard or the requirements of the General Duty Clause.
Employers who have unique or changing first-aid needs in their workplace, may need to enhance their first-aid kits. The employer can use the OSHA 300 Log of Work-Related Injuries and Illnesses, the 300-A Summary of Work-Related Injuries and Illnesses, or the OSHA 301 Injury and Illness Incident Report to identify these unique problems. Consultation from the local Fire/Rescue Department, appropriate medical professional, or local emergency room may be helpful to employers in these circumstances. By assessing the specific needs of their workplace, employers can ensure that reasonably anticipated supplies are available. Employers should assess the specific needs of their worksite periodically and augment the first aid kit appropriately.
If it is reasonably anticipated employees will be exposed to blood or other potentially infectious materials while using first-aid supplies, employers should provide personal protective equipment (PPE). Appropriate PPE includes gloves, gowns, face shields, masks, and eye protection.
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:
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.
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:
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:
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.
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.
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.
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:
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.
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.
First aid supplies are required to be easily accessible under paragraph 1926.50(d)(1). The American National Standards Institute (ANSI) has updated their Z308.1-2021, Minimum Requirements for Workplace First Aid Kits, effective October 15, 2022.
The ANSI standard has not been adopted by OSHA; therefore, is not mandatory for OSHA compliance. OSHA currently references ANSI Z301.1-1998 in Appendix A. This being said, OSHA often references the most recent consensus standard as a source of guidance to ensure employers are meeting the standard or the requirements of the General Duty Clause.
Employers who have unique or changing first-aid needs in their workplace, may need to enhance their first-aid kits. The employer can use the OSHA 300 Log of Work-Related Injuries and Illnesses, the 300-A Summary of Work-Related Injuries and Illnesses, or the OSHA 301 Injury and Illness Incident Report to identify these unique problems. Consultation from the local Fire/Rescue Department, appropriate medical professional, or local emergency room may be helpful to employers in these circumstances. By assessing the specific needs of their workplace, employers can ensure that reasonably anticipated supplies are available. Employers should assess the specific needs of their worksite periodically and augment the first aid kit appropriately.
If it is reasonably anticipated employees will be exposed to blood or other potentially infectious materials while using first-aid supplies, employers should provide personal protective equipment (PPE). Appropriate PPE includes gloves, gowns, face shields, masks, and eye protection.
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:
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.