Must an employer have individuals trained to render first aid?

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. First aid supplies approved by the consulting physician shall be readily available."

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 three- to four-minute response time, from time of injury to time of administering first aid, is required.

In other circumstances - where a life-threatening or permanently disabling injury is an unlikely outcome of an accident - a longer response time, such as 15 minutes, is acceptable.

The rationale for requiring a four-minute response time is brain death when the heart or breathing has stopped for that period of time.

If an emergency occurred where first aid was necessary and a trained employee panicked, forgetting all of their training, could the employer be cited?

If a trained employee were to panic in an emergency situation and not administer first aid or administer improper first aid, OSHA would not cite the employer. The employer would have met his obligation under the standard by having individuals trained to render first aid. The standard only requires employees to be trained in first aid, but does not address the actual performance of first aid in an emergency situation.

However, OSHA would conduct an investigation, if deemed necessary, to ensure that proper training certification, such as first aid and CPR certificates, were in order.

Would an employer violate OSHA's first aid standard if the employer issued a policy recommending that employees call "911" in emergency situations?

The purpose of first aid is to give injured employees some level of medical attention as quickly as possible to bridge the gap between the accident and full medical treatment. Therefore, the rendering of first aid should be encouraged by trained employees in addition to calling "911." Thus, an employer would not be in violation of OSHA's first aid standard by issuing such a policy statement, as long as the policy does not discourage the rendering of first aid by trained employees.

Source of first three responses: OSHA's interpretation of the first aid standard (1910.151), 12/11/1996.

Does OSHA require CPR training?

Although it is not an OSHA requirement that employers provide cardiopulmonary resuscitation (CPR) training, OSHA's "Guidelines for First Aid Training Programs" recommends that CPR training be a general program element of a first aid program. It is recommended that employees receive refresher training to retain their knowledge of first aid procedures. Employees should be certified annually to perform CPR, and first aid training should take place at least once every three years.

Source: OSHA's interpretation of standard 1910.151(b), OSHA guidelines for first aid training recommend CPR training as an element, 04/15/1999.

Does OSHA certify first aid training?

OSHA does not certify first aid training programs, instructors, or trainees. It is the responsibility of the employer to make an assessment of the work area and all first aid needs for expected injuries and illnesses.

Each employer using any first aid course must satisfy himself/herself that the course adequately covers the type of injuries/illnesses likely to be encountered in the workplace.

Source: OSHA's interpretation of standard 1910.151, OSHA does not certify first aid training programs, instructors, or trainees, 03/25/1994.

What first aid supplies are required to be stocked?

If there is an infirmary, clinic, or hospital in near proximity, then no first aid supplies are required by the standard. On the other hand, if no infirmary, clinic, or hospital is within proximity, then a physician identified by the employer shall determine the contents of a first aid kit to meet specific needs.

Source: OSHA's interpretation of standard 1910.151(b), first aid supplies required by businesses, 08/31/1990.