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You might have band-aids and aspirin in your desk drawer, but do you
have all of the first aid supplies you need to comply with OSHA's
regulations? Find out what OSHA requires every business to have on
hand in case of workplace injuries.
[Creating HR Policies or Employee Handbook?]
Q: Are we required to provide first aid treatment to employees
injured in the workplace? If so, what type of aid?
A: Yes. The Occupational Safety and Health Act (OSH Act)
requires covered employers to have adequate first aid supplies
readily available. In addition, you must provide first aid whenever
outside medical assistance "in near proximity to the workplace" is
not accessible. The Act applies to private employers that engage in
business affecting commerce and have at least one employee.
The Occupational Safety and Health Administration (OSHA) regulations
do not specifically state what first aid supplies are necessary for
general businesses. But in an appendix to its rule, found in 29
C.F.R. §1910.151, the agency refers employers to the American
National Standard (ANSI) Z308.1-1978 as an example of the minimum
contents for a first aid kit. The standard has since been updated by
ANSI Z308.1-2003, and likely will be incorporated into the OSHA
regulations at a future date.
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References to "C.F.R." refer to the Code of Federal Regulations, the
official government publication for federal regulations.
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This latest standard suggests that kits should include a broad range
of products to treat major and minor wounds, minor burns, and eye
injuries. It recommends such products as absorbent compresses,
adhesive bandages, adhesive tape, antiseptic applications, burn
treatments and dressings, medical exam gloves, sterile pads, large
triangular bandages, analgesics (pain relievers), and
cardiopulmonary resuscitation (CPR) barriers.
(Copies of ANSI Z308.1-2003 are available from the International
Safety Equipment Association, the creator of the standard and a
trade association for companies that manufacture safety equipment,
1901 North Moore Street, Arlington, VA, 22209, telephone (703)
525-1695, Web site www.safetyequipment.org.)
OSHA indicates, in several of its Standard Interpretations letters,
that employers with "unique" or "changing" first aid needs should
have additional equipment and supplies necessary for injuries that
may occur at their particular worksites. The agency also recommends
that all employers assess their workplace to determine the type,
quantity, and location of first aid supplies needed.
This recommended assessment should consider the work processes that
might cause illness or injury, the types of accidents experienced in
the past, and employee exposure to particular hazards like falls,
dangerous machinery, or harmful chemicals. The agency further
suggests that employers consult with local fire and rescue
departments, medical professionals, or emergency room workers to
identify necessary supplies.
Whether assistance is in "near proximity" depends on medical service
provider response times. OSHA has determined in its Standards
Interpretations letters that, where life threatening or permanently
disabling injury or illness can be expected, a 3 to 4 minute
response time (from time of injury to time of administering first
aid) is required. In other circumstances, i.e., 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.
If a worksite involves the potential for life threatening injuries,
the designated first-aid personnel should also be trained in CPR.
Additional or specialized training may be necessary at worksites
with unique hazards, such as the potential for chemical burns.
OSHA has issued an Instruction Concerning Guidelines for First Aid
Training Programs (Directive No. CPL-2-2.53, 1/7/91), which can be
found on its Web site, http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=DIRECTIVES&p_id=1568&p_text_version=FALSE.
In addition, any employee who is designated to provide first aid
must be provided the protections of the OSH Act's bloodborne
pathogens standard.
Over half of the states operate complete plans that have either
adopted the OSHA first aid requirements or stricter ones.
Accordingly, you should also check applicable state law
requirements.
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Personnel
Policy Service, Inc.
