OSHA Compliance for First Aid in the Workplace

The Occupational Safety and Health Administration (OSHA) has certain requirements regarding first aid and CPR preparedness in the workplace. Some OSHA compliance standards require specific types of industry to provide first-aid and CPR training to employees. The specific industries identified by OSHA are:

• 1910.146 Permit-required Confined Spaces
• 1910.266 Appendix B: Logging Operations — First-Aid and CPR Training
• 1910.269 Electric Power Generation, Transmission, and Distribution
• 1910.410 Qualifications of Dive Team
• 1926.950 Construction Subpart V, Power Transmission, and Distribution

In addition to these specific industries, OSHA standard 1910.151 states, "The employer shall ensure the ready availability of medical personnel for advice and consultation on matters of plant health." Compliance with the "ready availability of medical personnel" may mean providing training for employees to have on-site medical assistance.

Part (b) of the same requirement states, "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." Furthermore, OSHA has interpreted "near proximity" to mean 4-6 minutes from injury to medical care in "In areas where accidents resulting in suffocation, severe bleeding, or other life-threatening or permanently disabling injury or illness can be expected." If injuries like these are not common, then OSHA considers it reasonable to have response times as long as 15 minutes. Compliance with the training requirements for OSHA standard 1910.151 includes CPR only as a recommendation, while the standards listed above state CPR must be included.

How Does This Affect Your Workplace?

If your workplace meets one of the specific industries listed above, then you must provide training in first aid and CPR for at least one employee to be able to respond at all times.

If your workplace is in any other industry, OSHA compliance means you must look at the likelihood of injury for your industry. The Department of Labor, Bureau of Labor Statistics (BLS) website provides injury statistics for several industries. Look for your industry in the Summary Reports by year.

Remember that industries with a high incidence of injury must have medical care to the employee within four to six minutes. Since emergency medical services use an eight-minute response time standard for metropolitan areas, employers in high-injury industries need to provide first aid training to employees. Rural ambulance response times are significantly longer. OSHA compliance for employers in those areas — even with low incidences of injuries — means they will need to offer first aid training (and possibly designate a first aid person). Contact your local emergency medical service provider to determine an expected response time for 911 calls in your area.

Any concerns about OSHA compliance for your industry should prompt you to provide first aid and CPR training to employees. Training should be maintained on a regular basis; OSHA suggests updating training for life-threatening emergencies (CPR) every year and updating training for non-life-threatening incidents (first aid) periodically. OSHA has partnered with the American Red Cross (ARC) to determine training standards. ARC recommends updating first aid training every three years and updating CPR every year.

First Aid Kits

Providing first aid and CPR training is just one step in developing a first aid program for your workplace. Employers are also required to provide the tools and supplies necessary to provide first aid. If certain individuals in your workplace are designated for medical response, then the employer is required to develop a bloodborne pathogen exposure control procedure.

OSHA does not have a minimum requirement but references ANSI Z308.1-2003 Minimum Requirements for Workplace First Aid Kits. The listed items are intended to be the minimum for a workplace first aid kit. Depending on the potential for injury, a more complete kit may be necessary. OSHA recommendations do not include an automated external defibrillator (AED), but current emergency cardiac care guidelines from the American Heart Association recommend AEDs in most public places.

Exposure Control Plan

Employees that are expected to come in contact with blood or other potentially infectious materials (body tissues and fluids) must be protected from bloodborne pathogens. Employers are required to develop an exposure control plan to protect employees and respond to accidental exposures.

Someone in the organization must be designated as the infectious disease officer. OSHA's directives include an exposure control plan that can be adapted for each organization. Any employee who handles blood or other potentially infectious material must utilize universal precautions, which include:

• Use of barrier devices such as medical exam gloves, masks, eye protection, and gowns whenever contact with blood or body fluids is expected.
• Washing hands after any contact with blood or body fluids, even if barrier devices are used. Hands should be washed as soon as gloves are removed.
• Taking care to prevent injuries from sharps, including needles and scalpels. Used needles and scalpels should never be re-capped. Any sharp objects contaminated with blood are considered "sharps" for the purposes of universal precautions. For example, if an employee cuts herself on broken glass, the glass is considered potentially infectious.

There are several other plan components that need to be implemented. Items contaminated with blood or body fluids need to be discarded into proper containers labeled as bio-hazardous waste. Sharps in particular need to be discarded into puncture-resistant containers that are also clearly labeled as bio-hazardous waste.