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HR MATTERS E-TIPS
This Week's Tip: OSHA First Aid Requirements Q&A
Published by Personnel Policy Service, Inc.
"Your Policy and Compliance Experts Since 1972"
 
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This Week's Tip: OSHA First Aid Requirements Q&A

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.
 
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This Week's Tip: OSHA First Aid Requirements Q&A

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.

 

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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, Osha.gov/pls/oshaweb. 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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Subscribers to the Personnel Policy Manual and HR Policy Answers on
CD can find more information on OSHA's first aid requirements in
Medical Procedures, Chapter 203, note 14.

Not a subscriber? You can buy this chapter and download it immediately.
View the table of contents here:
https://www.hrpolicyanswers.com/xstore/product.php?productid=61&cat=0&page=1
 
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YOU CAN TRUST PPS
Information provided in HR Matters E-Tips is researched and reviewed
by the HR experts at Personnel Policy Service as well as employment
law attorneys. However, it is not intended as legal advice. Readers are
encouraged to seek appropriate legal or other professional advice.

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Interested in using an article from HR Matters E-Tips on your Web site or
in a newsletter?

Please contact Robin Thomas, Managing Editor of Personnel Policy
Service, Inc., to request permission. You can contact her by email at
editor@ppspublishers.com or by telephone at 1-800-437-3735.

Please note that the information in every issue of HR Matters E-Tips is
the original, copyrighted work of Personnel Policy Service, Inc., and is
protected under U.S. copyright laws. As such, you may not reprint or
publish in any format any article or portion of article from HR Matters E-
Tips without the express permission of Personnel Policy Service, Inc.

Remember, too, we encourage you to pass along any issue of the E-Tips
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Special Reports
2004 FLSA Regulations: Understanding the Issues

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