Note: All information is drawn from OSHA’s Web site (www.osha.gov), including Standards and “Letters of Interpretation.”

What OSHA standard covers first aid?
Medical and First Aid is covered by OSHA standard 1910.151, Medical services and first aid. The standard states: “The employer shall ensure the ready availability of medical personnel for advice and consultation on matters of plant health. In the absence of an infirmary, clinic, or hospital in near proximity to the workplace that 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.”

How does OSHA define first aid?
First aid refers to medical attention that is usually administered immediately after the injury occurs and at the location where it occurred. It often consists of a one-time, short-term treatment and requires little technology or training to administer.

New definitions are included for medical treatment and first aid in OSHA’s 2002 recordkeeping requirements update. First aid is defined by treatments on a finite list. All treatment not on this list is medical treatment. (§1904.7(b)(5))

What are specific examples of first aid treatment?
For the purposes of Part 1904, “first aid” means the following:

• Using a non-prescription medication at non-prescription strength (for medications available in both prescription and non-prescription form, a recommendation by a physician or other licensed health care professional to use a non-prescription medication at prescription strength is considered medical treatment for recordkeeping purposes);
• Administering tetanus immunizations (other immunizations, such as Hepatitis B vaccine or rabies vaccine, are considered medical treatment);
• Cleaning, flushing or soaking wounds on the surface of the skin;
• Using wound coverings such as bandages, Band-Aids™, gauze pads, etc.; or using butterfly bandages or Steri-Strips™ (other wound closing devices such as sutures, staples, etc., are considered medical treatment); Using hot or cold therapy;
• Using any non-rigid means of support, such as elastic bandages, wraps, non-rigid back belts, etc. (devices with rigid stays or other systems designed to immobilize parts of the body are considered medical treatment for recordkeeping purposes);
• Using temporary immobilization devices while transporting an accident victim (e.g., splints, slings, neck collars, back boards, etc.);
Drilling of a fingernail or toenail to relieve pressure, or draining fluid from a blister;
• Using eye patches;
• Removing foreign bodies from the eye using only irrigation or a cotton swab;
• Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs or other simple means;
• Using finger guards;
• Using massages (physical therapy or chiropractic treatment are considered medical treatment for recordkeeping purposes); or
• Drinking fluids for relief of heat stress.

Must I record first aid cases? OSHA’s revised recordkeeping rule, which went into effect January 1, 2002, does not require first aid cases to be documented.

Is there a response time for first aid? “OSHA’s regulation does not set specific response time requirements for the term ‘near proximity’; however, in areas where accidents resulting in suffocation, severe bleeding, or other life-threatening or permanently disabling injury or illness are likely, a 3 to 4 minute response time, from time of injury to time of administering first aid, is required.” (This letter was edited on 6/12/2002 to strike information that no longer reflects current OSHA policy.)

Does OSHA require CPR training? “It is not a requirement of OSHA that cardiopulmonary resuscitation (CPR) and first aid training take place every year. The OSHA requirement at 29 CFR 1910.151(b) 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.’ Basic adult CPR retesting should occur every year and first aid skills and knowledge should be reviewed every three years.”
(Letter from OSHA chief Joseph Dear to Sen. Charles Grassley, March 19, 1996)