Medical services and first aid

Scope

OSHA’s 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.

Regulatory citations

• 29 CFR 1910.151 — Medical services and first aid

The following regulations have related or separate first aid requirements:

• 29 CFR 1910.120 — HAZWOPER
• 29 CFR 1910.141 — Sanitation
• 29 CFR 1910.142 — Temporary Labor Camps
• 29 CFR 1910.146 — Permit-Required Confined Spaces
• 29 CFR 1910.156 — Fire Brigades
• 29 CFR 1910.160 — Fixed Extinguishing Systems
• 29 CFR 1910.261 — Pulp, Paper and Paperboard Mills
• 29 CFR 1910.262 — Textile mills
• 29 CFR 1910.266 — Logging, Appendix B
• 29 CFR 1910.268 — Telecommunications
• 29 CFR 1910.269 — Electric Power Generation, Transmission and Generation
• 29 CFR 1910.410 — Diving
• 29 CFR 1910 Subpart Z — Toxic and Hazardous Substances
• 29 CFR 1910.1030 — Occupational Exposure to Bloodborne Pathogens

Key definitions

• ANSI Z308.1: An American National Standard that 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.
• First aid: 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 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 3-4 minutes from the workplace,

Summary of requirements

Employers must:

• Determine the need for first-aid supplies and for medical and first-aid services.
• Ensure that “adequate” first-aid supplies are available at the worksite. The first-aid supplies should reflect the kinds of injuries that occur, and must be stored in an area where they are readily available for emergency access. OSHA advises employers to utilize their 300 Log to review injury history for determining first aid supplies appropriate for the workplace. NOTE: Some industries have specific requirements for first-aid kit locations and contents.
• Set up a schedule for checking/replenishing the content of the first-aid kit(s).
• 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. However, if life-threatening injuries can be reasonably expected, and outside emergency responders are more than 3 - 4 minutes away, the employer must ensure trained personnel are available in the workplace. Provide them periodic refresher training.
• If corrosive materials are used, ensure an eyewash and body flush facilities are provided.
• Instruct all workers about the first-aid program, including what workers should do if a coworker is injured or ill. Putting the policies and program in writing is recommended to implement this and other program elements.
• Train a person(s) to render first aid, if there’s an absence of an infirmary, clinic, or hospital in near proximity to the workplace which is used for treatment of all injured employees. While OSHA requires employers to train a person(s), section 1910.151, as presently worded, does not explicitly require that an employee or employees be both trained AND required by the employer to render first aid.
• Train and protect employees under the Bloodborne Pathogens standard at 1910.1030 if the employees are expected to render first aid as part of their job duties.
• Record on the OSHA 300 logs all injuries/illnesses that result in medical treatment beyond first aid. (See OSHA’s 1904.7(b)(5)(ii) for a definition of first aid for recordkeeping purposes.) OSHA references employers’ OSHA 300 Logs as guidance in its letters of interpretation for determining what injuries occur and associated first aid supplies that employers could use to stock their kits.