• OSHA requires that first-aid supplies be adequate, reflect the kinds of injuries that occur, and must be stored in an area where they are readily available for emergency access.
• ANSI standards outline the minimum quantities and sizes of required first-aid supplies.

Occupational Safety and Health Administration (OSHA) standards indicate that first-aid supplies must be adequate, should reflect the kinds of injuries that occur, and must be stored in an area where they are readily available for emergency access. For large operations, employers should determine how many first-aid kits are needed, and if it is appropriate to augment the kits with additional first-aid equipment and supplies.

Employers who have unique or changing first-aid needs should consider upgrading their first-aid kits. Employers can use the OSHA 300 log, OSHA 301 reports, or other records to identify the first-aid supply needs of their workplace. By assessing the specific needs of their workplaces, employers can ensure the availability of adequate first-aid supplies. Employers should periodically reassess the demand for these supplies and adjust their inventories.

Adequate first-aid supplies

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.

The OSHA booklet, "Best Practices Guide: Fundamentals of a Workplace First-aid Program," OSHA 3317-06N 2006, 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, OSHA letter of interpretation, which explains, “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.”

Recommended supplies

While OSHA doesn’t specifically prescribe first-aid kit contents, examples of the minimum supply requirements are described in American National Standards Institute (ANSI)/International Safety Equipment Association (ISEA) standard Z308.1, Minimum Requirements for Workplace First-aid Kits. OSHA references the 1998 edition of ANSI Z308.1 in the non-mandatory Appendix to 1910.151.

However, ISEA offers later editions of ANSI/ISEA Z308.1. The current ANSI/ISEA Z308.1 standard outlines the minimum quantities and sizes of required supplies. It 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 I kits will be used indoors and be permanently mounted, whereas Type IV kits will be suitable for outdoor use.

In addition to reviewing the most current edition of ANSI/ISEA Z308.1, employers can consult their local fire or rescue department, medical professional, or emergency room for first-aid kit recommendations.

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, the consensus standard recommends that it be removed from the kit and replaced.