In the factory, someone was cut. A trained responder ran to the first-aid supply cabinet. He opened it to find ... nothing! Fortunately, in this case, the cut was not life-threatening, and there was another relatively nearby source of supplies. Unfortunately, however, first-aid supplies pilfered from unlocked wall units or cabinets, or simply used and not regularly restocked, can result in more severe trauma and even tragedy when valuable time is lost before basic first-aid is available.

The solution is not locks on first-aid cabinets, which can delay help and lead to tragic results and possible employer liability. Instead, a well-planned, well-managed first-aid program — one that meets and preferably exceeds the requirements for your industry — is needed.

OSHA has its say
Most employers must comply with the OSHA standard for general industry, 29 CFR 1910.151, for providing medical services and first-aid for their employees. This standard applies even to the smallest businesses and to every location for large businesses. In addition to this standard (found along with official interpretations at, employers also must meet any standards incorporated in it by reference and other pertinent OSHA standards such as 29 CFR 1910.1030 for dealing with bloodborne pathogens.

OSHA recommends using ANSI-compliant kits and supplies. The ANSI Z308.1-2003 Minimum Requirements for Workplace First Aid Kits standard establishes minimum performance requirements for first-aid kits and contents. An ANSI Standards publication can be purchased from the International Safety Equipment Association (ISEA) (

Basic requirements
In brief, the 29 CFR 1910.151 standard addresses three main points:
  • The first requires “ready availability of medical personnel for advice and consultation on matters of plant health.” Therefore, at a minimum, employers need to consult with local medical service and emergency personnel, be familiar with local rescue services, and be assured that these services will be available to their employees in a timely manner.
  • A second part of the standard 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. Adequate first-aid supplies shall be readily available.”
The reference to “infirmary, clinic or hospital” in the original standard has been interpreted to include “the reasonable availability of a trained emergency service provider, such as fire department paramedics or EMS responders.” OSHA usually interprets “near proximity” to mean that emergency treatment must generally be available within three or four minutes, since serious accidents, uncontrolled bleeding, cardiac arrest and other such incidents are more likely to result in permanent injury or death if help is not available within the first few minutes. Where serious injuries are unlikely, such as in offices, OSHA may allow for a response time of up to 15 minutes.

It is best, however, to train a sufficient number of people in basic first-aid to cover every shift and to provide adequate first-aid supplies. OSHA also recommends CPR training but currently does not require it under the general industry standard, except for certain industries such as logging and electrical power.

The third part of CFR 29 1910.151 requires, where there is possible employee “exposure to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body ... within the work area for immediate emergency use.”

Companies should refer to ANSI Standard Z358.1-2004 (also available from ISEA) for information on the type of emergency equipment needed and installation.

Proper training
For some companies, a turnkey first-aid program may be appropriate. For most, however, a self-managed, quality-controlled program that is unbundled is a more cost-effective alternative.

It is most important for the employer to select a well-qualified instructor who has the experience and skills necessary to provide expert training. Training that meets national standards is offered by many occupational health and safety organizations, some of which may customize course topics for various types of industries and occupations.

Basic first-aid training can be covered in as little time as a four-hour course accommodating up to 20 people. In addition to basic first-aid recertification every two years, it also is recommended that first responders be trained and annually certified in cardio-pulmonary resuscitation (CPR) and use of an automated external defibrillator (AED). In fact, if an AED is available in the employer’s facility and is used by someone who is not trained in its operation, the Good Samaritan laws of many states may not protect that person from a suit alleging injury or death. The minimum time requirement for a CPR first-aid course in general industry is usually an eight-hour course by a qualified instructor.

First-aid supply strategies
Containing the cost of initial and replacement supplies is vital to a cost-effective first-aid program. As an example, instead of having 20 supply cabinets located along corridor walls throughout your plant, you could supply your designated first responders who cover all three shifts with portable, soft-pack first-aid kits. Each responder would be responsible for keeping his or her own kit replenished, thereby providing tight control of supplies and avoiding the problem of empty (and more costly) wall units. More importantly, this allows the responder to bring first-aid to the victim more quickly, since it eliminates the time spent going to the nearest station. Portable eyewash, bloodborne pathogen cleanup kits and burn kits would remain on the walls.

For replenishment, each responder would select supplies required for incidents that may be most likely to occur in his or her area. Another person would be responsible for regularly inspecting a single main supply cabinet that is not locked, but is in a well-supervised area. Ordering bulk supplies also saves money.

Basic kits should be supplemented with more supplies for injuries that are most likely to occur in the employer’s particular industry. For example, where slips and falls are most likely, the supplies may include splints. If there is a potential for burns, kits should contain burn treatments and dressings.

In addition, AEDs are recommended at strategic locations throughout each facility. It is also helpful to have a CPR grab bag next to each AED that includes a resuscitator, suction device and medical gloves.

In an instance where first responders or employees may be exposed to blood or other infectious materials, personal protective equipment (PPE) must include, among other items listed under OSHA standard 29 CFR 1910.1030, medical gloves, gowns, masks and eye/face protection. Hand antiseptic, surface disinfectant, a solidifier, biohazard bag and small shovel help keep infectious material under control.

Strategic planning
In summary, industrial-strength first-aid requires strategic and common-sense planning of a program that meets or exceeds all applicable standards, quality training by expert instructors, and conscientious implementation and maintenance of the program.