Your Top 5 First Aid, CPR, and AED questions answered!
OSHA’s Medical Services and First Aid standard (1910.151) often leaves employers with more questions than answers, so we’re here to help! Read on for more clarity on First Aid, CPR, and AED requirements for your workplace!
Question 1 — What is required in my first aid kits?
OSHA technically doesn’t mandate what should be in employer first aid kits. Instead, OSHA expects employers to assess the types of hazards in the workplace and potential injuries to determine what is "adequate."
A great place to start is a company's OSHA log to see what types of injuries are occurring and add that to their assessment of what could occur, then stock their first aid kits accordingly. At a minimum, kits should have adhesive bandages, adhesive tape, antibiotic ointment, antiseptic, burn treatment, burn dressing/pad, and sterile pads.
1910.151 Appendix A provides a list of items that are a great starting point but is not mandatory.
Question 2 — If emergency medical resources (hospital, clinic, etc.) are close by, are you required to have someone on-site that is trained in first aid and CPR?
OSHA requires in 1910.151 that employers have access to a nearby medical facility or have competent onsite first responders who can perform first aid regardless of the number of employees. If the employer chooses to have onsite first responders, OSHA says they must be trained.
While the standards don’t specify 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.
Workplaces where serious incidents, such as those involving falls, suffocation, electrocution, or amputation are possible, emergency medical services must be available within 3-4 minutes, if no employee on the site is trained to render first aid.
OSHA does exercise discretion in enforcing the first aid requirements in particular cases. For example, OSHA recognizes that in workplaces, such as offices, where the possibility of serious work-related injuries is less likely, a longer response time of up to 15 minutes may be reasonable.
Question 3 — Is it required to provide AED training if a company has opted to have AEDs on site?
Though OSHA recognizes automated external defibrillators (AEDs) as important lifesaving technology in treating cardiac arrest, the agency doesn’t currently require their use in the workplace, which means they don't mandate training either.
AEDs are considered Class III medical devices which means the Food and Drug Administration (FDA) has some oversight on their use. OSHA expects that employers assess their own needs and subsequent requirements for AEDs as part of their first aid response.
For employers that opt to have AEDs on site as an added layer of protection, training should be provided as with any other equipment you'd expect employees to operate. Typically, the manufacturers will recommend this as well. Additionally, the American Heart Association requires AED operators to also receive CPR training as an “integral part of providing lifesaving aid to people suffering sudden cardiac arrest.”
Though modern AEDs are designed to be simple to use, each is slightly different, so training is vital to the users understanding of the unique traits and supplies for the units used at their workplace. Also, AED users need to be trained to understand the signs of a sudden cardiac arrest, when to activate the EMS system, and how to perform CPR.
Question 4 — What are OSHA’s requirements for CPR training?
OSHA recommends that CPR training be a general program element of a first aid program. Some OSHA standards, such as Logging operations (1910.266), Permit-required confined spaces (1910.146), and Electric power generation, transmission, and distribution (1910.269), require that employees be trained in first aid and CPR.
Question 5 — How many employees must I have trained to provide first aid, CPR, or AED use?
OSHA doesn't provide specific guidance on the number or percentage of people to be trained in first aid, CPR, or AED use. Instead, the agency expects the employer to determine an adequate number of responders based on the size of the workforce, type of industry, footprint of the facility, etc.
Employers should employ a commonsense approach to ensure they have a sufficient number of individuals to cover all shifts at all times taking into account vacations, absences from the facility, and so on.
Other factors to consider include response times and the size of the facility. If the facility doesn’t have a 3-4 minute response time from emergency personnel, has a larger or complex layout, or has high-injury risks , several “teams” based at various locations within the facility may be necessary.
Key to remember: You aren’t alone in trying to decipher OSHA’s First Aid, CPR, and AED requirements. These answers should help get you on the right path to compliance!