In CPL 02-02-069, OSHA stated that designated first aid providers are covered, and that “An employee who routinely provides first aid to fellow employees with the knowledge of the employer may also fall, de facto, under this designation even if the employer has not officially designated this employee as a first aid provider.”
To illustrate, suppose a worker volunteers as an EMT outside of work, so other employees routinely go to that individual for first aid when injured. If the employer is aware of this, the worker could be considered a de facto responder with occupational exposure. Similarly, if the first aid supplies are stored in a supervisor’s office, and the supervisor routinely helps injured employees with first aid, OSHA could consider the supervisor a de facto first aid provider with occupational exposure.