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First Aid Requirements

Workplace First Aid Supplies for General Industry in California

The provision of adequate workplace first aid supplies is an important obligation for every California employer. However, mistakes and misinformation on this topic are prevalent.  Most employers are not in compliance with Cal/OSHA requirements for workplace first aid supplies, and the contents in most workplace kits don't reflect current best practices endorsed by medical professionals. This article provides an overview of common mistakes in workplace first aid programs, references to relevant Cal/OSHA regulations, and guidance on effective program development.

What is the Purpose of Workplace First Aid Supplies
For employers who do not have medically trained staff responsible for treatment of ill or injured employees (such as an onsite nurse, paramedic, or EMT), workplace first aid supplies will be used by employees with no first aid training, or only minimal education from a workplace first aid class. As such, first aid supplies should be either ”self help” items for minor injuries, or emergency supplies for life-threatening problems requiring 911. Anything that falls between those two categories should involve consultation with a medical professional, usually at your contracted occupational health clinic. 

What Problems Exist in Workplace First Aid Kits
Most standardized first aid kits or fill lists provided by workplace first aid distributors are not created with assistance from emergency medical professionals. They often include items that are:
  • obsolete by current prehospital EMS standards, such as alcohol wipes for cleaning open wounds, or supplies that contain latex.

  • beyond the scope of what is appropriate for layperson first aid, such as splints, tissue adhesives, or hemostatic powders.

  • not first aid supplies or don’t make sense, such as plastic eye cups, bulk cotton tipped swabs, or plastic tongs.

  • redundant, such as several varieties of topical disinfectants, wound treatments, or burn treatments.

  • unnecessary, such as gel burn dressings when adequate running water for flushing exists, or hand sanitizer where there are plumbed sinks, soap, and water. 

  • ineffective, such as tiny vials of eye flushing solution, or short and narrow elastic bands intended for use as emergency tourniquets.

  • dangerous, such as over the counter medications that can cause allergic reactions, interact dangerously with certain other medications, or worsen a preexisting condition.
Why is Workplace First Aid Such a Challenging Topic
First aid is emergency pre-hospital medicine. It is certainly very simplified emergency medicine, but at the core, it draws from the principles, research, and practices of the medical field. However, managers involved in workplace first aid programs typically have no background in emergency medicine. Even the most highly-experienced safety professionals usually have no training or formal education in medicine, and such information is not a standardized part of any of the common occupational safety and health degree or credential programs. Second, most vendors, distributors, and manufacturers of workplace first aid supplies do not have medical professionals on their staff, and have no specific knowledge of emergency medicine. The design, selection, and distribution of products is generally guided by profitability and marketability, at the cost of usefulness or suitability of the supplies. 

What Does Cal/OSHA Require
All public and private sector workplaces in the state fall under the jurisdiction of Cal/OSHA. For the scope of this article, we will address the regulations for General Industry, which are found in the California Code of Regulations, §3400: Medical Services and First Aid:
"Employer shall ensure the ready availability of medical personnel for advice and consultation on matters of industrial health or injury ... there shall be adequate first-aid materials, approved by the consulting physician, readily available for employees on every job."

Despite a clear and unambiguous requirement for physician consultation and approval for workplace first aid supplies, most employers are unaware of this standard. There are several reasons for this. First, some employers don't understand that they are subject to Cal/OSHA regulations, rather than Federal OSHA standards from 29 CFR 1910. This is a basic principle of safety compliance, but can be overlooked if the person in charge of a company safety program lacks a formal safety background. Second, most first aid distributors are either unaware of or ignore this requirement, and instead emphasize "OSHA required items" or standardized fill lists. This increases the number of items they can charge for in first aid kits, and masks their lack of medical expertise.

Even under the Federal OSHA requirement in 29 CFR 1910.151, there is no such thing as a required item. The standard merely states that "adequate first aid supplies shall be readily available." The best way to ensure those first aid supplies are adequate is to work with your consulting medical professional (the one that is already required for consultation and advice on other health matters, and for the treatment of workplace injuries). 

What Is the Purpose of the ANSI/ISEA Z308.1 Recommended Fill Lists
Under Federal OSHA standards (which have little relevance to California employers), Appendix A to 29 CFR 1910.151 is a non-mandatory standard which states that "an example of the minimal contents of a generic first aid kit is described in American National Standard (ANSI) Z308.1...".

The mention of ANSI Z308.1 is merely a reference to one example of a workplace first aid kit list. A future article will address the significant problems with the ANSI Z308.1 list. It is worth noting that the rest of Appendix A emphasizes that the ANSI list is adequate only for "small worksites", that "Employers should assess the specific needs of their worksite periodically and augment the first aid kit appropriately", and that "Consultation from the local fire/rescue department, appropriate medical professional, or local emergency room may be helpful to employers...". The emphasis remains on consulting with experts to ensure first aid supplies are specific to the industry and worksite.

How Can Employers Provide Better First Aid Supplies
To comply with the Cal/OSHA requirement and to provide suitable supplies for workers, the best place to start is with a workplace safety consultant knowledgeable in emergency medicine who is willing to assist in recommending kit contents and first aid products specific to your workplace. Your affiliated occupational health clinic may (especially if they offer urgent care services) also have a physician with experience in emergency medicine that can be a valuable resource for getting formal approval. Nurses or physicians' assistants specializing in emergency care, or prehospital emergency professionals such as paramedics and EMTs can have a good background to work in conjunction with a physician to design a workplace first aid program that is effective and compliant. 

Employers may find the process of developing a first aid program burdensome, particularly the need to customize the program to their specific industry, and to obtain physician approval for the contents. Put into context, when most humans will spend half their waking hours in the workplace, often under hazardous conditions, first aid supplies made available to them should be selected and approved by experts in that field. 

Keep in mind that most industries will not require especially expensive or specialized first aid kit contents. The initial investment in program development can also reduce long-term supply costs and simplify procurement. A professionally developed first aid program will also help companies avoid common first aid items that increase liability and decrease safety because they are ineffective, dangerous, or unsuited for use by laypersons. 

Companies may be pleasantly surprised to discover that the list of supplies recommended by experts may be minimal, with an emphasis on a few high-quality, versatile items that are safe and easy to use. A simple and easy-to-access first aid kit, along with training in first aid skills, is a winning combination for California employers. 

Author: Carlo Emami is a credentialed Emergency Medical Technician and Wilderness Emergency Medical Technician. He is part of the team at Safewest that provides workplace first aid program consulting, supplies, and training to employers in San Diego and Southern California. 

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