First aid requirements

Responding is Rachel Krubsack, workplace safety editor, J. J. Keller & Associates Inc., Neenah, WI.

Regulations short on details, long on questions

OSHA’s medical and first aid requirements apply to all general industry employers, although how they must comply depends on the distance to a medical facility that can provide treatment, as well as the type of hazards present in the workplace.

Parsing the proximity question

If life-threatening injuries can be reasonably expected and outside emergency responders are more than three to four minutes away, the employer must have one or more employees trained in first aid. Where the possibility of serious work-related injuries is less likely, a response time of up to 15 minutes may be reasonable. Employees trained to provide first aid likely will be expected to do so as part of their job duties, which means they also need training under OSHA’s bloodborne pathogens standard (1910.1030).

First aid supplies and placement

First aid supplies should reflect the kinds of injuries that could occur in the workplace, and must be stored in an area where they’re readily available for emergency access. (Note: Some industries have specific requirements for first aid kit locations and contents.) Appendix A to 1910.151 [medical services and first aid] states that employers “should assess the specific needs of their worksite periodically and augment the first aid kit appropriately.”

Although the standard doesn’t provide a list of supplies employers should keep on hand, it offers the ANSI standard as the minimum materials that OSHA would consider sufficient for a small workplace. ANSI updated Z308.1 to include Class A (designed to deal with the most common types of workplace injuries) and Class B (designed to deal with injuries in more complex or high-risk environments) first aid kits and fill lists for each. Employers may also want to consult their local fire/rescue department, appropriate medical personnel or local emergency department for guidance on what supplies to include.

The standard doesn’t specifically address the placement of first aid kits and/or cabinets based on employee numbers, density or geography. The employer must assess the particular needs of the workplace, tailor first aid kits and determine their appropriate placement so first aid providers can quickly reach them.

What about good Samaritans?

Not every employee is a designated first responder, and some untrained employees may try to help an injured co-worker; these people should be protected by good Samaritan laws. Employees trained and expected to provide first aid in emergency situations aren’t considered good Samaritans, and as such aren’t covered by good Samaritan laws. Such laws generally protect bystanders who voluntarily provide aid from lawsuits for “wrongdoing” if they make a mistake while trying to help.

Good Samaritan laws vary by state. Some apply to all citizens, while others are written specifically for physicians. Employers should familiarize themselves with the laws of their state.

Employees trained as first responders should understand their responsibilities. They shouldn’t try to provide help beyond the scope of their training. Also, once they begin to render first aid to a victim, they should continue until they no longer can supply aid, or until help arrives and relieves them.

Editor's note: This article represents the independent views of the author and should not be construed as a National Safety Council endorsement.