OSHA Regulations
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The following should help guide stakeholders when making purchasing decisions related to first aid kits/supplies and the need for training of their employees.
OSHA Regulations
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.
OSHA's standard for first aid training in general industry, 29 CFR 1910.151(b), provides:
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.
In the construction industry, 29 CFR 1926.50(c) provides:
In the absence of an infirmary clinic, hospital, or physician, that is reasonably accessible in terms of time and distance to the worksite, which is available for the treatment of injured employees, a person who has a valid certificate in first-aid training from the U.S. Bureau of Mines, the American Red Cross, or equivalent training that can be verified by documentary evidence, shall be available at the worksite to render first aid.
The primary requirement addressed by these standards is that an employer must ensure prompt first aid treatment for injured employees, either by providing for the availability of a trained first aid provider at the worksite, or by ensuring that emergency treatment services are within reasonable proximity of the worksite. The basic purpose of these standards is to assure that adequate first aid is available in the critical minutes between the occurrence of an injury and the availability of physician or hospital care for the injured employee.
One option these standards provide employers is to ensure that a member of the workforce has been trained in first aid. This option is, for most employers, a feasible and low-cost way to protect employees, as well putting the employer clearly in compliance with the standards. OSHA recommends, but does not require, that every workplace include one or more employees who are trained and certified in first aid, including CPR.
Clarification of "in near proximity"
OSHA stated in a letter of interpretation dated January 16, 2007 to Mr. Charles F. Brogan: "The primary requirement addressed by these first aid standards is that an employer must ensure prompt first aid treatment for injured employees, either by providing for the availability of a trained first aid provider at the worksite, or by ensuring that emergency treatment services are within reasonable proximity of the worksite." The employer must ensure that ". . . adequate first aid is available in the critical minutes between the occurrence of an injury and the availability of physician or hospital care for the injured employee."
The letter further explains: "While the first standards do not prescribe a number of minutes, OSHA has long interpreted the term 'near proximity' to mean that emergency care must be available within no more than 3-4 minutes from the workplace. Medical literature establishes that, for serious injuries such as those involving stopped breathing, cardiac arrest, or uncontrolled bleeding, first aid treatment must be provided within the first few minutes to avoid permanent medical impairment or death. Accordingly, in workplaces where serious accidents such as those involving falls, suffocation, electrocution, or amputation are possible, emergency medical services must be available within 3-4 minutes, if there is no employee on the site who is trained to render first aid."
OSHA does exercise discretion in enforcing the first aid requirements in particular cases. For example, OSHA recognizes that in workplaces, such as offices, where the possibility of such serious work-related injuries is less likely, a longer response time of up to 15 minutes may be reasonable.
Question 1: How does the ANSI standard Z308.1-1998 relate to 29 CFR 1910.151(b)? In a non-industrial workplace (for example, a corporate office) where employees perform administrative duties and there are no specific employment-related injuries anticipated, would a kit matching the ANSI standard be sufficient for compliance with
Paragraph (b) of 29 CFR 1910.151 requires that in the absence of an infirmary, clinic, or hospital near the workplace, a person or persons must be adequately trained to render first aid. Adequate first aid supplies must be readily available.
ANSI standards become mandatory OSHA standards only when, and if, they are adopted by OSHA; ANSI Z308.1, Minimum Requirements for Workplace First Aid Kits, was not adopted by OSHA. However, ANSI Z308.1 provides detailed information regarding the requirements for first aid kits; OSHA has often referred employers to ANSI Z308.1 as a source of guidance for the minimum requirements for first aid kits.
The contents of the first aid kit listed in ANSI Z308.1 should be adequate for a small worksite. However, larger or multiple operations should consider the need for additional first aid kits, additional types of first aid equipment, and first aid supplies in larger quantities. You may wish to consult your local fire and rescue department, an appropriate medical professional, your local OSHA area office, or a first aid supplier for assistance in putting together a first aid kit which suits the needs of your workplace. You should also periodically assess your kit and increase your supplies as needed.
Are there any specific interpretations for the term “readily available”?
The term “readily available” is not defined in the standard. However, responding in a timely manner can mean the difference between life and death. Therefore, the person who has been trained to render first aid must be able to quickly access the first aid supplies in order to effectively provide injured or ill employees with first aid attention. The first aid supplies should be located in an easily accessible area, and the first aid provider generally should not have to travel through several doorways, hallways and/or stairways to access first aid supplies.
ANSI Z308.1
History
The International Safety Equipment Association (ISEA), in conjunction with leading industry stakeholders, developed this standard in 2014, updating and expanding ANSI/ISEA Z308.1-2009. A subsequent revision in 2015 corrected a minor technical revision to the 2014 edition.
In an effort to emphasize the importance of the contents included in the first aid kit, rather than the configuration in which they are provided, specific requirements for unitized first aid kits have been removed from the 2014 edition. Guidance on color-coding of first aid supplies for these configurations of kits is included in the appendix to provide users and suppliers with an easy reference when identifying and stocking first aid items.
Scope
The standard classifies first aid kits based on the assortment and quantity of first aid supplies intended to deal with most types of injuries and sudden illnesses encountered in the workplace including: major wounds, minor wounds (cuts and abrasions), minor burns, sprains and strains, and eye injuries.
Why this standard is important
The assortment and quantity of supplies included in a first aid kit were chosen based upon a review of increased workplace incidents requiring first aid treatment, similar international standards and current practices in treating injuries. This revision introduces two classes of first aid kits: Class A kits with contents designed to deal with most common types of workplace injuries, and Class B kits with a broader range and quantity of supplies to deal with injuries in more complex or high-risk environments. By expanding the items in a basic first aid kit, employees will have greater access to items needed to treat common workplace injuries.
What employers should do
In deciding which class of kit is more appropriate for a given workplace, employers should consider the risks and task load of the work environment and the potential severity and likelihood of occurrence of an injury. Employers should also consider whether multiple first aid kits are needed, based on the number of employees, physical layout of the work environment and the remoteness of the worksite to emergency services. These same considerations can be taken into account when determining if a first aid kit should be augmented with additional supplies, as noted in the appendix of this standard.
Types of first aid kit containers
- Type I intended for use in stationary, indoor settings where the potential for damage of kit supplies due to environmental factors and rough handling is minimal.
- Type II intended for portable use in indoor settings where the potential for damage of kit supplies due to environmental factors and rough handling is minimal.
- Type III intended for portable use in mobile, indoor and/or outdoor settings where the potential for damage of kit supplies due to environmental factors is not probable.
- Type IV intended for portable use in the mobile industries and/or outdoor settings where the potential for damage to kit supplies due to environmental factors and rough handling is significant.
General requirements
Refer to standard for Class A Kits and Class B kits minimum quantities of first aid supplies.
Adhesive Bandage- Each adhesive bandage shall consist of a non-adherent absorbent pad attached to the central area of a strip of adhesive material 3.0 in. ± 1/16 in. (76 mm ± 1.6 mm) by 1.0 in. ± 1/32 in. (25.4 mm ± 0.8 cm).
Adhesive Tape- Adhesive tape shall be at least 3/8 in. (9.5 mm) wide and a minimum of 2.5 yd (2.3 m) long and meet the applicable requirements for adhesive tape as defined in the current edition of the USP/NF.
Antibiotic Application- Each antibiotic application shall meet the applicable requirements as defined in the current edition of the USP/NF.
Antiseptic- Each antiseptic shall meet the requirements of all applicable FDA requirements and shall be contained in an individual-use, non-reusable application containing at least 1/57 oz (0.5 g) of antiseptic.
Breathing Barrier- The breathing barrier shall be a single use disposable medical device listed with the U.S. Food and Drug Administration (FDA) and have a current valid 510 (k) with the purpose of delivering ventilations by a responder to a non-breathing victim (e.g., rescue breaths and CPR ventilations).
Burn Dressing (gel soaked)- Burn dressings shall be a sterile gel-soaked pad made of a material that prevents fibers from becoming embedded in the burn wound. Gel material shall be water-soluable.
Burn Treatment- Each burn treatment shall be a water soluble compound packaged in individual-use applications containing at least 1/32 oz (0.9 g).
Cold Pack- Each cold pack shall be at least 4 x 5 in. (10 x 12.5 cm) in size and shall reach a temperature between 20 - 40˚F (-6 - 4˚C) within 10 seconds of activation and shall maintain this temperature for a period of at least 10 minutes.
Eye Covering with means of attachment- Eye covering(s) shall have the ability to cover both eyes, an area of at least 2.9 sq. in. (19 sq. cm) per eye, and conform to each eye cavity.
Eye/Skin Wash- A sterile, isotonic, buffered solution as specified in FDA regulation 21 CFR 349 shall be contained in at least 0.5 fl. oz. (15 ml) individual-use applications.
First Aid Guide- Guidance for immediate care given to a victim of injury or sudden illness until arrival of more advance care, if needed, shall be included in the kits.
Hand Sanitizer- Hand sanitizers shall be water-soluable with a minimum 62% ethyl alcohol as the active ingredient.
Medical Exam Gloves- Gloves shall meet the requirements of FDA regulation 21 CFR 800.20 for medical grade gloves.
Roller Bandage (2 inch, 4 inch)- Each bandage shall be constructed from a material at least the equivalent strength of Type I USP 28-NF23 (44/36) gauze as defined by the current edition of USP/NF. Each bandage shall be individually packaged and sealed.
Scissors- Scissors shall be autoclavable, at least 3.5 in. long (8.9 cm), capable of cutting through clothing, feature a blunt end to protect a person from accidental injury and of medical professional quality.
Splint- Each splint shall be padded, made of malleable material and shall be at least 4.0 in. x 24 in. (10.2 cm x 61.0 cm).
Sterile Pad- Each sterile pad shall be at least 3 x 3 in. (7.5 x 7.5 cm) in size and shall have at least the absorbency of absorbent gauze as defined by the current edition of the USP/NF.
Tourniquet- Each tourniquet shall be at least 1 in. (2.5 cm) wide.
Trauma Pad- Each trauma pad shall be at least 45 sq. in. (290.33 sq cm) with no side smaller than 5 in. (12.7 sq cm) and shall have at least the absorbency of absorbent gauze as defined by the current edition of the USP/NF.
Triangular Bandage- Each bandage shall be made from muslin at least 60/48 weave or a material of equivalent mechanical strength.
First aid kit marking and labeling
All labeling and markings shall be legible and permanent. Where adhesive labels are used they shall not be easily removed. Each kit and/or location shall be visibly marked as a place where first aid supplies are located.