The Occupational Safety and Health Administration (OSHA) requires employers to provide a safe workplace that is reasonably free of hazards. Despite layers of protections, incidents can still occur, so employers must also provide access to emergency medical care and keep appropriate first aid supplies on hand.
OSHA’s Medical Services and First Aid standard at 1910.151 may be a brief three paragraphs, but it packs in quite a bit of information. To clarify and expand on the requirements, the Agency also refers to Appendix A of the standard, letters of interpretation, its best practices guide, and even consensus standards like ANSI/ISEA Z308.1. To eliminate some confusion, let’s break down each of the standard’s paragraphs.
Readily Available Consultation
The standard begins by requiring the employer to ensure medical personnel are available for advice and consultation on matters of workplace health. In other words, have arrangements in place with medical professionals, such as a doctor or nurse, to provide guidance on training, safety program development, first aid procedures, or health-related issues.
Medical professionals can also be tapped for advice on including over-the-counter (OTC) medications in first aid kits. OSHA doesn’t address this in their standard, but the ANSI Z308.1 American National Standard requires OTCs if provided, be in a single dose, tamper evident packaging, and should not contain ingredients known to cause drowsiness.
Readily Available Care
Next, paragraph (b) requires adequately trained personnel to render aid to workers if there is no clinic or hospital nearby to treat injured employees. This can be accomplished by having trained personnel on site or by ensuring that emergency responders can arrive in a reasonable time. (NOTE: Some industries like logging (1910.266) and electric power generation (1910.269) specifically require having on-site first aid-trained personnel.)
Additionally, where serious incidents are likely, OSHA says that emergency care must be available within 3-4 minutes. Serious incidents are those that involve falls, suffocation, electrocution, or amputation. Where serious injuries are not likely, such as office settings, a response time of up to 15 minutes may be reasonable.
If an employer does rely on outside responders, like EMTs or an ambulance service, it’s imperative to first confirm they can meet company needs and response times. Additional service providers may be needed if outside responders have capacity limitations. If outside responders are utilized, emergency plans might be simply having employees call 911.
Responders need supplies, which is why OSHA requires adequate supplies to be provided and readily accessible. Neither OSHA or ANSI Z308.1 addresses the number of first aid kits a workplace should have, or where they should be placed. Rather, they expect employers to assess the workplace and consider past and potential injuries to determine supplies based on anticipated needs. A great place to begin is the company’s OSHA 300 Log. For example, if cuts are common, include bleeding control supplies; if burns are frequent, stock burn care materials. ANSI Z308.1, though not mandatory, is a great guide for small workplaces. It describes both Class A kits that contain basic items to care for common injuries and Class B kits which are better suited for populated, complex, or higher-risk workplaces.
Readily Available Drenching
Paragraph (c) requires suitable, immediate emergency use facilities for quick drenching or flushing of the eyes and body within any work area where a worker’s eyes or body may be exposed to corrosive materials. As with first aid kits, OSHA doesn’t stipulate the number of eyewash stations or safety showers required in a given workplace. Instead, the Agency expects the employer to perform a hazard assessment to determine the areas and level of potential risk to employees and provide the necessary protection based on those findings.
When determining whether eyewashes/showers are suitable given the circumstances of a particular worksite, OSHA may refer to the most recent ANSI Z358.1 consensus standard for enforcement. Here’s a summary of a few of the American National Standard’s recommendations for eyewashes and safety showers:
- Locate within 10 seconds of the exposure hazard, or within 55 feet.
- Deliver a minimum of 0.4 gallons of “tepid” (60-80 degrees F) flushing fluid per minute for 15 minutes at 30 psi.
- Activate in one second or less with a hands-free, stay-open valve.
- Able to flush both eyes simultaneously.
Inspect (for operation, cleanliness, etc.) and maintained per the manufacturer’s specifications and instructions. NOTE: OSHA doesn’t require inspections to be documented; however, it’s best practice to keep a record of inspections to demonstrate compliance. Tags are often used for this.
Train employees on the locations and use of eyewashes/showers.
Ready access to eyewash stations and safety showers also means that the path must be clear of obstructions and should be on the same level as the hazard. Some examples of obstructions could include doors, stairs, machinery, or stored materials.
Ready to Go?
Developing, implementing, and maintaining a solid first aid program requires an understanding of regulations and consensus standards. An effective program is the result of consistently evaluating first aid responders, training, supplies, equipment, and policies.
First aid programs should be reviewed periodically to ensure specific workplace needs are met. Equipment and supplies must be inspected and updated, as necessary. Training should be kept updated with current techniques and industry expertise. Remember, the end goal is to have trained responders and appropriate supplies ready to go should something unfortunate happen.
Guest Contributor: Cindy Pauley, Editor, J. J. Keller & Associates, Inc., Environmental, Health & Safety (EHS) Publishing Team
Cindy Pauley is an Editor for J. J. Keller & Associates, Inc. on the Environmental, Health & Safety (EHS) Publishing Team. She uses her years of safety program development and management experience in the oil and gas, chemical, manufacturing, construction, and agricultural industries to develop a wide variety of easily understandable content and to provide regulatory insight for J.J. Keller & Associates’ customers and partners. You may have seen Pauley’s articles in trade magazine or attended webcasts where she has partnered with colleagues to provide a wide array of compliance topics. She is also one of J.J. Keller & Associates’ subject matter experts who will help answer customers’ safety and health questions. Pauley’s background as a 9-1-1 dispatcher, American Red Cross disaster worker, and Search and Rescue volunteer equips her to assist customers with their emergency management and response challenges. She is both a Certified Occupational Safety Specialist (COSS) and a Certified Occupational Hearing Conservationist (COHC) with a Master of Arts (MA) and Bachelor of Applied Arts (BAA) from Central Michigan University.