Medical services and first aid for construction activities

Scope

OSHA’s medical and first aid requirements apply to all construction jobsites.

Regulatory citation s

• 29 CFR 1926.50 — Medical services and first aid.
• 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.

Key definitions

• ANSI Z308.1: An American National Standard that OSHA refers to for minimum contents to be included in a first-aid kit.
• ANSI Z358.1: An American National 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).
• Corrosive: A chemical that causes visible destruction of, or irreversible alterations in, living tissue by chemical action at the site of contact. Generally speaking, 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 in 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containing caustic materials has, at certain locations, a spigot or tap from which the contents are to be sampled or withdrawn and employees are expected to perform such tasks, then, an emergency eyewash and/or shower would be needed where this task is to occur.
• 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.
• 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 15 minutes. ANSI defines tepid as a temperature range between 60 and 100 degrees Fahrenheit.

Summary of requirements

In general, the standard requires covered employees to:

• Ensure the availability of medical personnel for advice and consultation on matters of occupational health.
• Assess the workplace for substances that could cause harm or adverse effects to the eyes or body. The chemical’s Safety Data Sheet (SDS) is generally the indicator that an eyewash/shower is needed for exposure to the substance. However, there are other guidance available, such as W. Morton Grant’s Toxicology of the Eye (Charles C Thomas Pub. Ltd., 4th edition, August 1993) and the NIOSH Pocket Guide to Chemical Hazards.
• Make provisions for prompt medical attention in case of serious injury prior to the start of the construction project .
• Determine that an infirmary, clinic, hospital, or physician is reasonably accessible in terms of time and distance, OR have someone who has a valid certificate in first aid training available to render first aid.
• Have first aid supplies readily available and easily accessible:
  • Place the contents of the first aid kit in a weatherproof container with individual sealed packages for each type of item.
  • Check the contents of the first-aid kit by the employer before being sent out on each job and at least weekly on each job to ensure that the expended items are replaced.
• Have available means to transport an injured person to a physician or hospital.
• Post emergency numbers for physicians, hospitals, and ambulances in a conspicuous location if you do not have 911 service.
• 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.
• Ensure eyewash/showers are located within 10 seconds of the hazard.
• Ensure eyewashes can deliver a minimum of .4 gallons of flushing fluid per minute for 15 minutes.
• Ensure showers can deliver a minimum of 20 gallons of flushing fluid per minute for 15 minutes.
• Inspect and maintain eyewash/shower equipment per manufacturer’s specifications and instructions.
• Train employees on locations and use of eyewash/shower equipment.
• Record on the OSHA 300 logs all injuries/illnesses that result in medical treatment beyond first aid.