Create a comprehensive workplace First Aid Policy compliant with OSHA 29 CFR 1910.151, ANSI/ISEA Z308.1-2021, and state-specific OSHA requirements. Covers first aid responder designations, kit locations, AED provisions, emergency procedures, training requirements, OSHA recordkeeping, and Good Samaritan protections.
What Is a First Aid Policy?
A workplace First Aid Policy is a formal written document that establishes an employer's procedures for providing first aid care to employees who are injured or become ill at work. The policy identifies trained first aid responders, specifies the location of first aid equipment and supplies, describes emergency procedures, and sets out the employer's obligations under federal and state occupational safety and health regulations.
In the United States, workplace first aid is governed primarily by the Occupational Safety and Health Act of 1970 (29 U.S.C. 651 et seq.) and its implementing regulations. OSHA regulation 29 CFR 1910.151 requires employers to ensure the availability of medical services and first aid. Under subsection (b), in the absence of a nearby infirmary, clinic, or hospital, employers must have adequately trained personnel and readily available first aid supplies. The OSHA General Duty Clause (Section 5(a)(1)) further requires employers to maintain a workplace free from recognized hazards.
The ANSI/ISEA Z308.1-2021 standard, published by the International Safety Equipment Association, specifies the minimum requirements for workplace first aid kits, including the types and quantities of supplies that must be included. OSHA references this standard in its compliance guidance.
Many states operate their own OSHA-approved state plans that may impose additional or more stringent first aid requirements. For example, California's Cal/OSHA has specific regulations for first aid in construction (8 CCR 1512) and general industry. Washington State's DOSH requires written first aid plans for certain industries. Employers must comply with both federal OSHA requirements and any applicable state-specific requirements.
When Do You Need a First Aid Policy?
A workplace First Aid Policy is needed by every employer in the United States, regardless of size or industry. Under OSHA's General Duty Clause, all employers have an obligation to provide a safe workplace, and having a written first aid policy is a fundamental component of meeting that obligation. While OSHA does not explicitly require a written first aid policy for all employers, having one demonstrates compliance with the requirement to provide adequate first aid training, supplies, and procedures.
The policy is particularly important for employers in high-hazard industries such as construction, manufacturing, warehousing, and healthcare, where the risk of workplace injuries is elevated. Construction employers must comply with 29 CFR 1926.50, which requires first aid supplies and trained personnel on every construction site. Manufacturing employers face specific hazards that may require specialized first aid training, such as chemical exposure response or bloodborne pathogen protocols under 29 CFR 1910.1030.
The policy should be established before operations begin and should be reviewed and updated at least annually, or whenever there is a significant change in workplace conditions, workforce size, or the results of a workplace hazard assessment. A new policy or revision is also needed when an incident reveals deficiencies in current first aid provision.
Having a written policy also provides important protection in the event of an OSHA inspection or investigation following a workplace injury. An OSHA compliance officer will typically ask to see the employer's first aid policy, training records, and incident documentation as part of any inspection.
What to Include in Your First Aid Policy
A comprehensive workplace First Aid Policy must address several essential elements to comply with OSHA requirements and protect both employees and the employer.
The legal framework section should identify the applicable federal and state regulations, including OSHA 29 CFR 1910.151, the General Duty Clause, and any state-specific OSHA requirements. The scope should define who is covered by the policy, including employees, contractors, and visitors.
First aid responder designations are critical. The policy should list all trained first aid responders by name and certification status. Under 29 CFR 1910.151(b), employers must have adequately trained personnel available during all working hours when a medical facility is not in near proximity.
First aid equipment and supplies must be identified by location and must meet or exceed the ANSI/ISEA Z308.1-2021 standard. The policy should describe the inspection and replenishment schedule for first aid kits.
AED provisions, where applicable, should identify the location of each AED, the maintenance schedule, and the applicable state AED law and Good Samaritan protections.
Emergency procedures should describe the step-by-step process for responding to a medical emergency, including calling 911, identifying the nearest hospital emergency room, and the OSHA reporting requirements for fatalities and serious injuries under 29 CFR 1904.39.
Training requirements should specify the certifying organization, the certification renewal schedule, and the employer's commitment to fund training. OSHA recordkeeping requirements under 29 CFR 1904 should be addressed, including the maintenance of the OSHA 300 Log and the five-year retention period.
Responsibilities should be clearly assigned to the employer, first aid responders, and all employees. The policy review schedule and the designated policy owner should be identified.