Whether you have one employee or over fifty, all workplaces are required to meet the Occupational Safety and Health Administrations (OSHA) standards for first aid. It requires a lot more than just having a first aid kit in the office. If your training, preparation and supplies are not in order, you could face major fines if OSHA conducts a random inspection. OSHA requirements for medical and first aid can be found in the OSHA Standard 29 CFR 1910.151
1910.151(a)
The employer shall ensure the ready availability of medical personnel for advice and consultation on matters of plant health.
1910.151(b)
In the absence of an infirmary, clinic, or hospital in near proximity to the workplace which is used for the treatment of all injured employees, a person or persons shall be adequately trained to render first aid. Adequate first aid supplies shall be readily available.
Medical Services and First Aid
Employers are required to assess the workplace for the types of injuries that can be reasonably expected to occur. Once the types of injuries have been determined, the employer must then determine if the medical services in the area are able to treat the employees for those types of injuries, and whether the medical services are in close proximity (3-4 minutes) to their workplace. When determining whether medical services are in close proximity, an employer must take into consideration hours of service, and when counting on emergency medical services, their response time must be taken into account.
OSHA does take into consideration workplaces, such as offices, where the risk of serious injuries is minimal. According to a Letter of Interpretation, in such cases, OSHA is more flexible, allowing up to fifteen minutes as acceptable.
When a workplace is found not to be in close proximity to medical services, and in hazardous workplaces, such as industrial environments, the employer is required to have a person adequately trained to render first aid. In review of several Letters of Interpretation, OSHA recommends that employers have one or more first aid and CPR trained personnel. Beings a trained provider may not be available at all times, having a minimum of two trained personnel would be optimal.
In large facilities, or where more than fifty persons work, employers need to be able to render first aid in a timely manner. In these situations, being a first aid and CPR instructor for nearly 30 years, I certainly feel that one or two trained personnel would certainly be inadequate. It would be feasible to expect that each department have a trained provider, or that an employer would have one trained provider for every 25 employees.
First aid training can be attained through; The American Red Cross, Medic First Aid, American Heart Association and other recognized providers.
First Aid Kits
OSHA Standard 29 CFR 1910.151 states: First aid supplies are required to be readily available, and contain the minimum requirements of supplies. An example of the minimal contents of a generic first aid kit is described in American National Standard (ANSI) Z308.1-1998 “Minimum Requirements for Workplace First-Aid Kits.” The contents of the kit listed in the ANSI standard should be adequate for most office environments and small business. When larger operations or multiple operations are being conducted at the same location, employers should determine the need for additional first aid kits, and supplies at the worksite.
First aid kits must be properly maintained, accessible to all employees, and stored in a location where it will not be damaged.
Although there are no requirements that employers provide medications, over-the-counter medicine can be put in first aid kits if packaged in single dose, tamper-evident packaging and labeled as required by FDA regulations. Over-the-counter drug products should not contain ingredients which are known to cause drowsiness. It is also important to consider the risks related to employees having allergic and or adverse reactions to medications, before providing such medications.
ANSI Z308.1–1998 Required Minimum Supplies (10 person first aid kit)
Quantity Description
1 ea. ………………….Absorbent Compress,
4" x 8" min.
16 ea. …………………..Adhesive Bandages
1" x 3"
5 yd. …………………………..Adhesive Tape
10 ea. ………………………………..Antiseptic
Applications, 0.5g ea.
6 ea. ………………………….Burn Treatment Applications, 0.5g ea.
4 ea. ……………………………….Sterile Pads,
3" x 3" min.
1 pr. ………………..Medical Exam Gloves
1 ea. …………………..Triangular Bandage,
40" x 40" x 56" min
Personal Protective Equipment
If it is reasonably anticipated that employees will be exposed to blood or other potentially infectious materials while using first aid supplies, employers are required to provide appropriate personal protective equipment (PPE) in compliance with the provisions of the Occupational Exposure to Bloodborne Pathogens Standard, OSHA Standard 29 CFR 1910.1030(d)(3). PPE must be provided at no charge, and be available at the location of the first aid kit
Minimum PPE equipment requirements:
• Disposable medical gloves (Latex or Nitrile)
• Safety glasses or face shield
• Mask
• CPR barrier
Emergency Eye Wash and Emergency Shower
OSHA Standard 29 CFR 1910.151(c) states: Where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use.
For locations that meet the requirements of an eye wash station or emergency shower, facilities must be properly maintained, flushed regularly, unobstructed by doors, within a ten second walking distance, and accessible to all employees involved in the corrosive materials.
All emergency eye wash and emergency shower facilities must meet the American National Standards Institute (ANSI) Standard Z358.1-1990
Automated External Defibrillator (AED)
A person experiencing cardiac arrest is two to three times more likely to survive if a bystander applies an automated external defibrillator (AED) before EMS arrival. Statistics show that at the onset of a cardiac arrest, the survival rate decreases by 10% for each one minute that Cardiopulmonary Resuscitation (CPR) and the use of an AED is delayed.
Many states have now enacted laws requiring AEDs to be made available in public places such as: federal buildings, schools, businesses, medical offices, dental offices and other public gathering areas. Since each state has different requirements, you should contact your state’s regulatory authority for information regarding AEDs, and if you’re required to provide the availability of one at your particular location or business. At the time this document was written, there were numerous states with bills pending, or that were recently adopted relating to defibrillators or AEDs.
The Cardiac Arrest Survival Act of 2000 required the establishment of federal guidelines for AED placement in federal facilities and provides immunity from civil suits to any person who uses an AED in an emergency. Many states have what is known as the Good Samaritan Act, which protects a person from providing first aid treatment from civil suits, as long as they provide care within their scope of training.
Emergency Medical Plan
As part of the workplaces Emergency Action Plan, each workplace must have an Emergency Medical Plan. This plan must be posted in a location where it is visible to employees in the event of a medical emergency.
The plan should include the following:
• Address of the workplace
• Phone number of the workplace
• Location of the first aid kits
• Location of emergency eye wash or emergency shower
• Names of those persons trained to render first aid
• Emergency services phone number
• List of medical services located in close proximity to the workplace (Minimum of three);
• Phone numbers
• Address and directions
• Hours of service
All personnel should be trained on the Emergency Medical Plan at their initial hire, and at least annually thereafter. It is a good idea to keep records that help verify the proper training was done at hire and annually thereafter.
The OSHA regulations are the minimum requirements that employers must follow. As always, you should check with your state and local regulatory authority for additional requirements. For more information, employers can find OSHA regulations at www.osha.gov.
Editor’s Note: Jary Winstead is a safety consultant, author and trainer who serves a variety of industries including the forest products sector. He owns Work Safety Services LLC and can be reached at SAFEJARY@aol.com.
