First Aid in the Workplace

This information is brought to you by
Primary First Aid LLC

Answers to the most Frequently asked questions:

Q: Who is OSHA?

A: OSHA, the Occupational Safety and Health Administration, is a division of the United States Department of Labor, and is charged with enforcing the Occupational Safety and Health Act. The “Act” requires first aid supplies be readily available for employees while on the job.

Specifically, #29 CFR, 1910.151(b) says: “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.”

Q: What does OSHA have to say about the necessity of first aid kits in the workplace?

A: "First aid supplies are required to be readily available under paragraph § 1910.151(b)." An example of the minimal contents of a generic first aid kit is described in American National Standard Institute (ANSI) Z308.1 ‘Minimum Requirements for Workplace First-Aid Kits.’

The contents of the kit listed in ANSI standard should be adequate for small work-sites. When larger operations or multiple operations are being conducted at the same location, employers should determine the need for additional first aid kits at each work-site, additional types of first aid equipment, supplies, additional quantities, and types of supplies.

Q: What is “Near Proximity”?

A: OSHA has defined ‘Near Proximity’ as: “In areas where incidents or accidents resulting in suffocation, severe bleeding, or other life threatening injury or illness could be possible, a 3 to 4 minute EMS response time from time of injury to time of administering first aid, is required. In other circumstances, i.e., where a life threatening injury is unlikely, a 15-minute response time is acceptable. If employees work in areas where public emergency transportation is not available, the employer must make provision for acceptable emergency transportation.”

Q: What are the minimum requirements for workplace first aid kits?

A: The ANSI (American National Standards Institute) Z308.1-1998 standards call for the following minimum contents:

  •    (1)    Absorbent Compress 32 sq. in. minimum
  •    (16)  1” x 3” Adhesive Bandages
  •    (1)    Adhesive Tape, 5 yards
  •    (10)  Antiseptic Applications
  •    (6)    Burn Treatment Applications
  •    (2)    Pair Medical Exam Gloves
  •    (4)    Sterile Pad, 3” x 3”
  •    (1)    Triangular Bandage, 40” x 40” x 56”

The ANSI standard also states: “This standard anticipates that additional first aid products will be included to augment the kit based on the specific hazards existing in a particular work environment.”

“The choice of first aid supplies should be made in consultation with a health care professional or by a person competent in first aid and cognizant of the hazards found in the particular work environment.”

The ANSI standard Z308.1-2003 recommends oral analgesics in single-dose tamper-evident packages be included in first aid cabinets.

Q: Besides complying with OSHA requirement, are there any other compelling reasons to have a workplace first aid kit?

A: Minor day to day accidents, injuries and employee discomforts play a major role in reducing productivity. By furnishing first aid and employee comfort items, the employer provides a means for employees to deal with the problem and quickly get back to productive and effective work.

Additionally, studies have repeatedly shown that employees who are suffering from the effects of discomforts (headache, upset stomach, cough, sore throat, etc) or pain from a minor accident or injury are more likely to be involved in more serious and possibly catastrophic accidents. Employers find that a well-stocked first aid kit ultimately improves employee morale, minimizes down time, improves workplace productivity, and reduces workers comp. claims, while at the same time satisfying OSHA requirements.

Q: Where should workplace first aid kits be located?

A: First aid supplies must be readily available. This is generally considered to mean every floor in every building and separate kits for clean room, food manufacturing and/or food preparation areas. Employees should not have to travel more than 100 feet to secure adequate supplies.

Q: Can you lock a first aid kit?

A: The readily available requirement makes locking a kit impractical. Back up supplies can be locked up, but the primary supply of appropriate and necessary supplies must be ‘readily available’, which means not having to search for a supervisor with a key.

Q: What kind of training is required for employees?

A: Per OSHA letter of interpretation: “Training of individuals in first aid in the United States as carried out through a variety of mechanisms”. The American Red Cross, through its many local chapters, offers standard and Advanced First Aid courses. The National Safety Council provides educational materials to train individuals in basic first aid knowledge and skills. Private training programs to train people in first aid. It is hoped that this guideline will help establish the essentials of training programs that should be considered in fulfilling OSHA First Aid requirements.

GENERAL COMPONENTS OF A FIRST AID TRAINING PROGRAM

  1. Trainees should develop “hands on” skills through the use of mannequins and trainee partners during their training.

  2. Trainees should be exposed to acute injury and acute illness settings as well as the appropriate response to those settings through the use of visual aids, such as video tape and slides.

  3. Training should include a course workbook which discusses first aid principles and first aid responses to settings that require first aid intervention.

  4. Assessment of successful completion of the first aid training program should include instructor observed demonstration of acquired skills and written performance assessments.

  5. Training duration should allow enough time for particular emphasis on first aid situations likely encountered in your particular workplace.

  6. Basic Adult Cardiopulmonary Resuscitation (CPR) training should be included in the first aid training program.

  7. Periodic review and demonstration of first aid skills and knowledge should be done at least as frequently as every three years.

  8. Trainees should be provided with adequate instruction on the need for use of Universal Precautions. This should include:

    1. The use of universal precautions for infectious diseases such as AIDS and hepatitis B.
    2. A copy of the OSHA standard for blood borne pathogens or information on how to obtain a copy.
    3. The meaning of universal precautions, which body fluids are considered potentially infectious, and which are regarded as hazardous.
    4. The necessity of keeping gloves readily available and the appropriate use of gloves and other protective equipment.
    5. The appropriate disposal of any sharp items or instruments or other items requiring special disposal measures such as blood-stained material.
    6. The appropriate management of blood spills.

  9. Trainees should receive instruction in the principles and performance of:

    1. Bandaging of the head, shoulder, arm, leg, wrist, elbow, foot, ankle, fingers, toe, and knee.
    2. Splinting of the arm, elbow, clavicle, fingers, hand, forearm, ribs, femur, lower leg, ankle, knee, foot, and toes.
    3. Moving and rescuing victims including one and two person lifts, ankle and shoulder pulls, and the blanket pull.

Q: What is the procedure for partially used eye wash?

A: The Food and Drug Administration (FDA) requires a warning label be affixed to all eye wash bottles: “Do not use if safety seal is broken or missing”.

Since the eye is the most porous membrane in the body, and most germs enter the body through the eyes coupled with the fact that we only get one set of eyes, it doesn’t pay to take any chances. Sterility is only assured until the bottle is opened and cross-contamination could easily occur on subsequent applications. Product tampering is also a concern. Many first aid suppliers are now offering a twist off, single use application bottle in which the top can not be replaced after the initial use. This bottle will insure that product tampering and cross-contamination issues are minimized.

Q: Are kits necessary for company vehicles?

A: In order to insure ready availability of first aid supplies to all employees while on the job, company vehicles must include first aid kits. Obviously, the variety and quantity of supplies included will be less substantial than an office or shop kit. On vehicles for interstate commerce, a rubber dust gasket is required for protection of the supplies from the elements.

Q: Is emergency oxygen required in the workplace?

A: More than 500,000 people die each year of coronary artery disease. A substantial percentage of these people die while on the job. Emergency oxygen is a critical component of emergency response in cases of heart attack or shock. Time is of the essence as the chances for a heart attack survival are 92% if oxygenated air is induced via rescue breathing within 2 minutes of attack, yet dissipate to only 10% if 6 minutes elapse. With EMS response rates ranging from 6-9 minutes on the quick end to 20-30 minutes in rural areas, it makes good sense to have emergency oxygen available on site to maximize the chance of survival from heart attack and/or the symptoms of shock.

Q: Should business consider Automatic External Defibrillators (AED’s) for the workplace?

A: Yes, for the same reasons business should consider emergency oxygen systems. With EMS response rates of up to 10+ minutes in many urban locations, lay-person automatic external defibrillators make a lot of sense. Analyzing irregular (shockable) heart rhythms and shocking the heart back into a normal rhythm is automatic, making AED’s an increasingly important component of an effective business first aid response center.

Q: What’s the story on “Blood Borne Pathogens”? Does the typical business need to worry about compliance?

A: For the most part, industrial facilities would only have a couple of groups of employees that may need training under OSHA’s Blood Borne Pathogens Standard, including:

  1. Health professionals employed by the company.
  2. Employees who are designated first aid responders.

If through the normal course of an employees’ job function he or she could reasonably be expected to come into contact with potentially infectious bodily fluids (blood, urine, vomit, etc:), compliance with the Blood Bourne Pathogens Standard is required.

Q: Are MSDS’s necessary for the products in a workplace first aid kit?

A: First aid items provided for employees personal consumption while on the job are considered drugs or cosmetics and as such are subject to Federal Food, Drug and Cosmetic Act compliance. Items subject to regulation under this act are not regulated as a chemical substance under the Toxic Substances Control Act as specifically stated in 15 USC 2602 (2) (B) (vi).

In plain English: MSDS’s are not required for first aid items provided for employee’s personal use on the job. Most first aid manufactures will however provide MSDS’s for first aid items upon request.

Q: Are employers liable for potential incidents involving Over-The-Counter (OTC) medications in a first aid kit?

A: ANSI says: “Any additional over-the-counter drug product included in a first aid kit should be packaged in a single dose, tamper evident, packaging with full labeling as required by FDA regulations, and should contain no ingredients which are known to cause drowsiness.”

If an employer complies with this standard and does not prescribe or dispense OTC medications to adult employees, then there is no liability. Liability becomes a concern when an employer (or agent of the employer) evaluates a patient’s symptoms and recommends a particular OTC medication for the symptom relief (prescribing), or physically delivers or administers the medication (dispensing). Making OTC’s available at no cost to adult employees in a fashion consistent with ANSI standard eliminates employer liability.

Q: What’s the story on eye wash stations? Are they mandatory?

A: Yes. The code of Federal Regulations, Title 29, Parts 1901 to 1910, contains OSHA regulations. Part 1910.151© states: “Where the eyes or body of any person may be exposed to injurious corrosive chemicals, suitable facilities for quick drenching or flushing or the eyes and body shall be provided within the work area for immediate use.”

Q: What are “suitable facilities”?

A: The answer is found in ANSI Z358.1 Standard for Emergency Shower and Eyewash Equipment, the definitive standard for meeting OSHA requirements for suitable emergency eyewash devices. Highlights of the standard for primary devices are as follows:

  • Place within 10 seconds of hazards, within 10ft of strong caustics or acids.
  • Flush both eyes simultaneously.
  • Protect nozzles from airborne contaminants.
  • Maintain a minimum flushing rate of 0.4 gallons per minute for 15 minutes (preserved buffered saline solution is recommended.
  • Use “stay open” valves to keep hands free to open eyelids.
  • Activation in one second or less.
  • Identify location with a highly visible sign.
  • Ensure that the location is readily accessible and free of obstructions.

Q: Can I use a faucet mounted eye wash unit?

A: ANSI recommends that tepid (65º-90º F) solution be used to flush eyes. Since it would be extremely difficult to activate a faucet system with one hand in one second or less and insure tepid temperature water, the faucet mounted eye stations do not typically meet the ANSI requirements. Plumbed in, or self contained stations are most practical.

Q: How often must self contained eye wash stations be serviced?

A: ANSI recommends that employers follow manufactures recommendations in cleaning and refilling self contained eye wash stations. Most manufactures recommend 3-6 month service intervals, although there are some systems on the market which allow 24 month service intervals.