First Aid and Medical Services

OSHA’s core first-aid requirement is short — three sentences in 29 CFR 1910.151 — but it carries more weight than its length suggests, and it interacts with several other standards.

This page is not legal advice. Check the standards that apply to your industry and any State Plan requirements.

1910.151 — Medical services and first aid

The standard requires three things:

(a) The employer must ensure medical personnel are available for advice and consultation on matters of workplace health.

(b) 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, and adequate first-aid supplies must be readily available.

(c) Where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing must be provided in the work area for immediate emergency use.

What “near proximity” means in practice

The standard does not define a distance, and this is the most commonly misread part of it. OSHA’s interpretation letters have consistently pointed to response time, not mileage:

For workplaces where a serious injury is unlikely, a reasonable expectation is emergency medical services arriving within roughly 15 minutes
For workplaces where serious or life-threatening injury is likely — such as those involving powered machinery, elevated work, or hazardous chemicals — a response time of 3 to 4 minutes is the benchmark

If EMS cannot reliably meet that, you need trained first-aiders on site. In practice, most employers train their own regardless: relying on ambulance response times as your entire first-aid provision is a fragile position to defend after an incident.

Training content and refreshers

OSHA does not mandate a specific course or provider in 1910.151, but its guidance and the widely accepted standard of care point to training that covers:

Assessing the scene and the casualty
CPR and use of an AED
Bleeding control
Shock, burns, fractures, and head or spinal injury
Sudden illness — including cardiac events, stroke, and diabetic emergencies
Universal precautions against bloodborne pathogens

Certification typically expires after two years, and CPR skills degrade quickly — many providers now recommend more frequent skills refreshers between full certifications.

There is no OSHA-mandated ratio of first-aiders to employees in general industry. Determine what is adequate for your workplace based on shift patterns, site layout, the hazards present, and the realistic time for help to arrive. Cover every shift — a single trained first-aider who works days does not cover a night shift.

First-aid supplies

1910.151 requires “adequate” supplies without listing them. ANSI/ISEA Z308.1 is the widely used consensus standard and is what OSHA guidance points to. It defines two classes of kit — Class A for common workplace injuries, Class B for higher-risk environments — and minimum contents for each.

Check kits regularly and after use. A quarterly or monthly Inspection with a checklist is the straightforward way to make that routine and evidenced.

Eyewash and drenching facilities

Where anyone may be exposed to injurious corrosive materials, 1910.151(c) requires drenching or flushing facilities in the work area for immediate emergency use.

ANSI/ISEA Z358.1 is the referenced consensus standard. Its key parameters:

Reachable within 10 seconds of the hazard, along an unobstructed path on the same level
Capable of delivering flushing fluid for a 15-minute continuous flush
Tepid flushing fluid — roughly 16–38°C (60–100°F)
Weekly activation of plumbed units, and annual inspection against the full standard

Weekly eyewash activation is a classic recurring inspection: quick, easily forgotten, and a common inspection finding when undocumented.

Bloodborne pathogens — 1910.1030

Anyone who provides first aid may come into contact with blood. If you have employees with reasonably anticipated occupational exposure to blood or other potentially infectious materials, 1910.1030 applies and requires:

A written Exposure Control Plan, reviewed and updated annually
Universal precautions and appropriate PPE
Hepatitis B vaccination offered free of charge — within 10 working days of assignment for those with anticipated exposure
Post-exposure evaluation and follow-up
Training at assignment and annually thereafter
A sharps injury log where applicable

There is a specific concession for designated first-aiders in workplaces where providing first aid is collateral to their main job: the hepatitis B vaccine may be offered after an exposure incident rather than pre-emptively, provided you have a written policy meeting OSHA’s conditions.

Note that needlestick and sharps injuries contaminated with another person’s blood are privacy-concern cases on the OSHA 300 log — the employee’s name must not appear.

Emergency action plans — 1910.38 requires procedures for reporting emergencies and, where relevant, rescue and medical duties. See Emergency Action Plans.
Medical records — first-aid records that constitute employee medical records are subject to access and retention rules under 1910.1020, and to ADA confidentiality. See US Privacy.
Recordkeeping — whether treatment counts as “first aid” or “medical treatment” determines whether a case goes on your 300 log. OSHA’s definition is a closed list — see OSHA Recordkeeping.

How SteadyOn helps

Requirement	SteadyOn module
First-aid and CPR certification records	Training Courses + Enrollments, with expiry dates
Knowing who your current first-aiders are	Roles — create a First Aider role, assign people, and add a course requirement
Spotting certifications about to lapse	Enrollment expiry dates surface on the dashboard and in BRAG status
First-aid kit checks	Inspections — a recurring template
Weekly eyewash activation	Inspections — a recurring template
Exposure Control Plan and first-aid policy	Documents
Recording first-aid treatment given after an incident	Incidents — investigation notes
Evidence of a systematic approach	The Log page + per-entity Log tab

A practical setup: create a First Aider role, add your first-aid/CPR course as a requirement of that role, and enrol the people who hold it. SteadyOn then shows you at a glance who is qualified, whose certification is expiring, and whether you still have cover on every shift.

Where to go next

Emergency Action Plans and Fire Prevention
OSHA Recordkeeping — the first aid vs medical treatment distinction
State Plans and Cal/OSHA — some states set specific first-aider ratios