OSHA REQUIREMENTS

1.  OSHA REQUIREMENTS FOR FIRST AID TRAINING ARE CONTAINED IN 29 CODE OF FEDERAL REGULATIONS 1910.   FOLLOWING IS A LETTER FROM OSHA INTERPRETING 29 CFR 1910:

March 23, 2007

Dear Mr. Bisland:

This is in response to your July 5, 2006 letter to the Occupational Safety and Health's Administration's (OSHA) Correspondence Control Unit, in which you requested an interpretation of "in near proximity" for 29 CFR 1910.151(b).

Paragraph 1910.151(b) of OSHA's general industry standard on medical services and first aid 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 OSHA construction standard at 29 CFR 1926.50(c) has a similar requirement.

OSHA stated in a letter of interpretation dated January 16, 2007 to Mr. Charles F. Brogan: "The primary requirement addressed by these first aid standards is that an employer must ensure prompt first aid treatment for injured employees, either by providing for the availability of a trained first aid provider at the worksite, or by ensuring that emergency treatment services are within reasonable proximity of the worksite." The employer must ensure that ". . . adequate first aid is available in the critical minutes between the occurrence of an injury and the availability of physician or hospital care for the injured employee."

The letter further explains: "While the first standards do not prescribe a number of minutes, OSHA has long interpreted the term 'near proximity' to mean that emergency care must be available within no more than 3-4 minutes from the workplace. Medical literature establishes that, for serious injuries such as those involving stopped breathing, cardiac arrest, or uncontrolled bleeding, first aid treatment must be provided within the first few minutes to avoid permanent medical impairment or death. Accordingly, in workplaces where serious accidents such as those involving falls, suffocation, electrocution, or amputation are possible, emergency medical services must be available within 3-4 minutes, if there is no employee on the site who is trained to render first aid."

OSHA does exercise discretion in enforcing the first aid requirements in particular cases. For example, OSHA recognizes that in workplaces, such as offices, where the possibility of such serious work-related injuries is less likely, a longer response time of up to 15 minutes may be reasonable.


2.  OSHA REQUIREMENTS FOR 29 CFR 1910

At a minimum, first-aid and CPR training shall consist of the following:

 1. The definition of first aid.
 2. Legal issues of applying first aid (Good Samaritan Laws).
 3. Basic anatomy.
 4. Patient assessment and first aid for the following:
   a. Respiratory arrest.
   b. Cardiac arrest.
   c. Hemorrhage.
   d. Lacerations/abrasions.
   e. Amputations.
   f. Musculoskeletal injuries.
   g. Shock.
   h. Eye injuries.
   i. Burns.
   j. Loss of consciousness.
   k. Extreme temperature exposure (hypothermia/hyperthermia)
   l. Paralysis
   m. Poisoning.
   n. Loss of mental functioning (psychosis/hallucinations, etc.).
   o. Artificial ventilation.
   p. Drug overdose.
 5. CPR.
 6. Application of dressings and slings.
 7. Treatment of strains, sprains, and fractures.
 8. Immobilization of injured persons.
 9. Handling and transporting injured persons.
 10. Treatment of bites, stings, or contact with poisonous plants or animals.