Thursday, December 20, 2012

First Aid Program Fundamental Part 7: Elements of a First-Aid Training Program

There are a number of elements to include when planning a firstaid training program for a particular  workplace. These recommendations are based on the best practices and evidence available at the time this guide was written. Statistical information is available from BLS to help assess the risks for specific types of work.
Program elements to be considered are:
1.Teaching Methods
Training programs should incorporate the following principles:
Basing the curriculum on a consensus of scientific evidence where available;
Having trainees develop “hands-on” skills through the use of mannequins and partner practice;
Having appropriate first-aid supplies and equipment available;
Exposing trainees to acute injury and illness settings as well as to the appropriate response through the use of visual aids;
Including a course information resource for reference both during and after training;
Allowing enough time for emphasis on commonly occurring situations;
Emphasizing skills training and confidence-building over classroom lectures;
Emphasizing quick response to first-aid situations.
2. Preparing to Respond to a Health Emergency
The training program should include instruction or discussion in the following:
Prevention as a strategy in reducing fatalities, illnesses and injuries;
Interacting with the local EMS system;
Maintaining a current list of emergency telephone numbers (police, fire, ambulance, poison control) accessible by all employees;
Understanding the legal aspects of providing first-aid care, including Good Samaritan legislation, consent, abandonment, negligence, assault and battery, State laws and regulations;
Understanding the effects of stress, fear of infection, panic; how they interfere with performance; and what to do to overcome these barriers to action;
Learning the importance of universal precautions and body substance isolation to provide protection from bloodborne pathogens and other potentially infectious materials. Learning about personal protective  equipment -- gloves, eye protection, masks, and respiratory barrier devices. Appropriate management and disposal of blood-contaminated sharps and surfaces; and awareness of OSHA’s Bloodborne Pathogens  standard.
3. Assessing the Scene and the Victim(s)
The training program should include instruction in the following:
Assessing the scene for safety, number of injured, and nature of the event;
Assessing the toxic potential of the environment and the need for respiratory protection;
Establishing the presence of a confined space and the need for respiratory protection and specialized training to perform a rescue;
Prioritizing care when there are several injured;
Assessing each victim for responsiveness, airway patency (blockage), breathing, circulation, and medical  alert tags;
Taking a victim’s history at the scene, including determining the mechanism of injury;
Performing a logical head-to-toe check for injuries;
Stressing the need to continuously monitor the victim;
Emphasizing early activation of EMS;
Indications for and methods of safely moving and rescuing victims;
Repositioning ill/injured victims to prevent further injury.

Tuesday, December 11, 2012

First Aid Program Fundamental Part 6: First Aid Courses

First-Aid Courses

 Training for first aid is offered by the American Heart Association, the American Red Cross, the National  Safety Council, and other nationally recognized and private educational organizations. OSHA does not teach first-aid courses or certify first-aid training courses for instructors or trainees.
First-aid courses should be individualized to the needs of the workplace. Some of the noted program elements may be optional for a particular plant or facility. On the other hand, unique conditions at a specific worksite may necessitate the addition of customized elements to a first-aid training program.

Elements of a First-Aid Training Program

There are a number of elements to include when planning a firstaid training program for a particular workplace. These recommendations are based on the best practices and evidence available at the time this guide was written. Statistical information is available from BLS to help assess the risks for specific types of work. Program elements to be considered are:

To be continued...

Friday, November 30, 2012

First Aid Program Fundamental Part 5: Automated External Defibrillators

With recent advances in technology, automated external defibrillators (AEDs) are now widely available, safe, effective, portable, and easy to use. They provide the critical and necessary treatment for sudden cardiac arrest (SCA) caused by ventricular fibrillation, the uncoordinated beating of the heart leading to collapse and death. Using AEDs as soon as possible after sudden cardiac arrest, within 3-4 minutes, can lead to a 60% survival rate.3 CPR is of value because it supports the circulation and ventilation of the victim until an electric shock delivered by an AED can restore the fibrillating heart to normal.
All worksites are potential candidates for AED programs because of the possibility of SCA and the need for timely defibrillation. Each workplace should assess its own requirements for an AED program as part of its first-aid response.
A number of issues should be considered in setting up a worksite AED program: physician oversight; compliance with local, state and federal regulations; coordination with local EMS; a quality assurance program; and a periodic review, among others. The OSHA website at www.osha.gov or the websites of the
American College of Occupational and Environmental Medicine at www.acoem.org, the American Heart Association at www.americanheart. org, the American Red Cross at www.redcross.org, Federal Occupational Health at www.foh.dhhs.gov, and the National Center for Early Defibrillation at www.early-defib.org can provide additional information about AED program development.

Tuesday, November 20, 2012

First Aid Program Fundamentals Part 4: First-Aid Supplies

It is advisable for the employer to give a specific person the responsibility for choosing the types and amounts of first-aid supplies and for maintaining these supplies. The supplies must be adequate, should reflect the kinds of injuries that occur, and must be stored in an area where they are readily available for emergency access. An automated external defibrillator (AED) should be considered when selecting first-aid supplies and equipment.
A specific example of the minimal contents of a workplace firstaid kit is described in American National Standards Institute ANSI Z308.1 - 2003, Minimum Requirements for Workplace First Aid Kits. The kits described are suitable for small businesses. For large operations, employers should determine how many first-aid kits are needed, and if it is appropriate to augment the kits with additional first-aid equipment and supplies.
Employers who have unique or changing first-aid needs should consider upgrading their first-aid kits. The employer can use the OSHA 300 log, OSHA 301 reports or other records to identify the first-aid supply needs of their worksite. Consultation with the local fire and rescue service or emergency medical professionals may be beneficial. By assessing the specific needs of their workplaces, employers can ensure the availability of adequate first-aid supplies. Employers should periodically reassess the demand for these supplies and adjust their inventories.

Friday, November 9, 2012

First Aid Program Fundamentals Part 3: OSHA Requirements

Sudden injuries or illnesses, some of which may be life-threatening, occur at work. The OSHA First Aid standard (29 CFR 1910.151) requires trained first-aid providers at all workplaces of any size if there is no "infirmary, clinic, or hospital in near proximity to the workplace which is used for the treatment of all injured employees."

In addition to first-aid requirements of 29 CFR 1910.151, several OSHA standards also require training in cardiopulmonary resuscitation (CPR) because sudden cardiac arrest from asphyxiation, electrocution, or exertion may occur. CPR may keep the victim alive until EMS arrives to provide the next level of medical care. However, survival from this kind of care is low, only 5-7%, according to the American Heart Association. The OSHA standards requiring CPR training are:
1910.146 Permit-required Confined Spaces
1910.266 Appendix B: Logging Operations – First-Aid and CPR Training
1910.269 Electric Power Generation, Transmission, and Distribution
1910.410 Qualifications of Dive Team
1926.950 Construction Subpart V, Power Transmission and Distribution

If an employee is expected to render first aid as part of his or her job duties, the employee is covered by the requirements of the Occupational Exposure to Bloodborne Pathogens standard (29 CFR 1910.1030). This standard includes specific training requirements.

A few of the medical emergency procedures mentioned in this guide as first aid may be considered medical treatment for OSHA recordkeeping purposes. The OSHA Recording and Reporting Occupational Injuries and Illnesses regulation (29 CFR 1904) provides specific definitions of first aid and medical treatment. If a medical emergency procedure which is considered by 29 CFR 1904 to be medical treatment is performed on an employee with an
occupational injury or illness, then the injury or illness will be regarded as recordable on the OSHA 300 Log.

Tuesday, November 6, 2012

First Aid Program Fundamentals Part 2: The Risks

Risks: Injuries, Illnesses and Fatalities

There were 5,703 work-related fatalities in private industry in 2004. In that same year there were 4.3 million total workplace injuries and illnesses, of which 1.3 million resulted in days away from work.

Occupational illnesses, injuries and fatalities in 2004 cost the United States’ economy $142.2 billion, according to National Safety Council estimates. The average cost per occupational fatality in 2004 exceeded one million dollars. To cover the costs to employers from workplace injuries, it has been calculated that each and every employee in this country would have had to generate $1,010 in revenue in 2004.2

Sudden cardiac arrest (SCA) may occur at work. According to recent statistics from the American Heart Association, there are 250,000 out-of-hospital SCAs annually. The actual number of SCAs that happen at work are unknown. If an employee collapses without warning and is not attended to promptly and  effectively, the employee may die. Sudden cardiac arrest is caused by abnormal, uncoordinated beating of the heart or loss of the heartbeat altogether, usually as a result of a heart attack. Workplace events such as electrocution or exposure to low oxygen environments can lead to SCA. Overexertion at work can also trigger SCA in those with underlying heart disease. The outcome of occupational illnesses and injuries depends on the severity of the injury, available first-aid care and medical treatment. Prompt, properly administered first aid may mean the difference between rapid or prolonged recovery, temporary or permanent disability, and even life or death.

Assess the Risks and Design a First-Aid Program Specific for Worksite

 Obtaining and evaluating information about the injuries, illnesses and fatalities at a worksite are essential first steps in planning a first-aid program. Employers can use the OSHA 300 log, OSHA 301 forms, their Workers’ Compensation insurance carrier reports or other records to help identify the first-aid needs for their businesses. For risk assessment purposes, national data for injuries, illnesses and fatalities may be obtained from the Bureau of Labor Statistics (BLS) website at www.bls.gov/iif. The annual data, beginning in 2003, are grouped by the North American Industrial Classification System (NAICS) that assigns a numeric
code for each type of work establishment. Prior to 2003, the Standard Industrial Classification (SIC) system was used to categorize the data instead of NAICS.

 Employers should make an effort to obtain estimates of EMS response times for all permanent and temporary locations and for all times of the day and night at which they have workers on duty, and they should use that information when planning their first-aid program. When developing a workplace first-aid program, consultation with the local fire and rescue service or emergency medical professionals may be helpful for response time information and other program issues. Because it can be a workplace event, SCA should be considered by employers when planning a first-aid program.

It is advisable to put the First-Aid Program policies and procedures in writing. Policies and procedures should be communicated to all employees, including those workers who may not read or speak English. Language barriers should be addressed both in instructing employees on first-aid policies and procedures
and when designating individuals who will receive first-aid training and become the on-site first-aid providers.

Tuesday, October 30, 2012

First Aid Program Fundamentals Part 1

First aid is emergency care provided for injury or sudden illness before emergency medical treatment is available. The first-aid provider in the workplace is someone who is trained in the delivery of initial medical emergency procedures, using a limited amount of equipment to perform a primary assessment and intervention while awaiting arrival of emergency medical service (EMS) personnel. A workplace first-aid program is part of a comprehensive safety and health management system that includes the following four essential elements1:
  • Management Leadership and Employee Involvement
  • Worksite Analysis
  • Hazard Prevention and Control
  • Safety and Health Training
  • The purpose of this guide is to present a summary of the basic elements for a first-aid program at the workplace. Those elements include:
  • Identifying and assessing the workplace risks that have potential to cause worker injury or illness.
  • Designing and implementing a workplace first-aid program that:
    • Aims to minimize the outcome of accidents or exposures
    • Complies with OSHA requirements relating to first aid
    • Includes sufficient quantities of appropriate and readily accessible first-aid supplies and first-aid equipment, such as bandages and automated external defibrillators.
    • Assigns and trains first-aid providers who:
      • receive first-aid training suitable to the specific workplace
      • receive periodic refresher courses on first-aid skills and knowledge.
  • Instructing all workers about the first-aid program, including what workers should do if a coworker is injured or ill. Putting the policies and program in writing is recommended to implement this and other program elements.
  • Providing for scheduled evaluation and changing of the first-aid program to keep the program current and applicable to emerging risks in the workplace, including regular assessment of the adequacy of the first-aid training course.
This guide also includes an outline of the essential elements of safe and effective first-aid training for the workplace as guidance to institutions teaching first-aid courses and to the consumers of these courses.
To be continued...

Tuesday, October 23, 2012

Guidelines regarding eye wash and body flushing facilities required for immediate emergency use in electric storage battery charging and maintenance areas.

OSHA Instruction STD 1-8.2 March 8, 1982 of Compliance Programming
Subject: 29 CFR 1910.151(c), Medical Services and First Aid; 29 CFR 1926.50 and 51, Medical Service and First Aid, and Sanitation, Respectively; Applicable to Electric Storage Battery Charging and Maintenance Areas
A. Purpose. This instruction provides guidelines regarding eye wash and body flushing facilities required for immediate emergency use in electric storage battery charging and maintenance areas.
B. Scope. This instruction applies OSHA-wide.
C. Action. OSHA Regional Administrators/Area Directors shall ensure that OSHA field staff apply the requirements the subject standards to electric storage battery charging areas as set forth in E. of this instruction.
D. Federal Program Change. This instruction describes a Federal program change which affects State programs. Each Regional Administrator shall:
1. Ensure that this change is forwarded to each State designee.
2. Explain the technical content of the change to the State designee as requested.
3. Ensure that State designees are asked to acknowledge receipt of the Federal Program change in writing, within 30 days of notification, to the Regional Administrator. This acknowledgment should include a description either of the State's plan to implement the change or of the reasons why the change should not apply to that State.
4. Review policies, instructions and guidelines issued by the State to determine that this change has been communicated to State program personnel. Routine monitoring activities (accompanied inspections and case file reviews) shall also be used to determine if this change has been implemented in actual performance.
OSHA Instruction STD 1-8.2 March 8, 1982 Office of Compliance Programming
E. Guidelines. OSHA field staff will evaluate the potential circumstances for employee exposure to electrolyte(s) in electric storage battery handling, charging and maintenance areas.
1. The safety or health compliance officer shall document the following observations in the case file:
a. Employee use of personal protective equipment.
b. Type and chemical concentration of electrolyte(s).
c. Special guards and/or precautions intended to provide for employee protection from electrolyte exposure.
d. Based upon employee job functions, record the extent and type of probable employee exposure to electrolyte(s).
e. Note the availability and location of eye wash and body flushing equipment/facilities (An arrangement, which includes a hose equipped with a proper face and body wash nozzle, shall also be noted.)
2. The compliance officer and Area Director shall evaluate the data documented in E.1. Where potential employee exposure to hazardous storage battery electrolyte(s) exists, the circumstances and extent of exposure shall determine the application of the following alternatives:
a. The use of effective personal protective equipment in combination with an eye wash and body flushing station in near proximity to the work area(s), shall be deemed to provide adequate minimum protection for employees.
b. In areas where the extent of possible exposure to electrolyte is small, (i.e., such as auto garages, service stations and in certain industrial and construction situations), a specially designated pressure controlled and identified water hose equipped with a proper face and body wash nozzle which will provide copious amounts of low velocity potable water, or an
2
OSHA Instruction STD 1-8.2 MARCH 8, 1982 Office of Compliance Programming
appropriate portable eye wash device containing not less than one gallon of potable water which is readily available and mounted for use, is considered to provide minimum employee protection when proper personal protective equipment is used.
c. In addition to emergency eye and/or face wash procedures, the employer shall ensure that adequate provisions have been established for the emergency care of employees exposed to eye or face contact with electrolytes.
d. At construction sites and in commercial and manufacturing facilities at locations where powered industrial trucks are parked for overnight storage and routine battery recharging only, no need for emergency facilities exists unless potential exposure to electrolyte is substantiated. Where exposure is possible (i.e., servicing batteries) the provisions of E.2.b and E.2.e. should be evaluated for applicability.
e. At construction sites and in commercial manufacturing facilities where batteries (such as industrial truck batteries) are serviced and handled, proper plumbed eye wash and body drenching equipment shall be available immediately adjacent to the work station(s) and within the work area regardless of the personal protective equipment required and used.
3. Where employee exposure to hazardous electric storage battery electrolyte(s) exists and minimum protection measures are not provided, citations shall be issued as appropriate for violations of:
a. 29 CFR 1910.151(b) or 29 CFR 1926.50(c), a person or persons adequately trained to render first aid shall be readily available 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.
3
OSHA Instruction STD 1-8.2 March 8, 1982 Office of Compliance programming
b. 29 CFR 1910.151(c) and as adopted by 29 CFR 1926.51, where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use.
c. 29 CFR 1910.132(a) or 29 CFR 1926.28(a), personal protective equipment for eyes, face, head, and extremities, protective clothing and protective shields and barriers, shall be provided, used and maintained in a sanitary and reliable condition wherever it is necessary by reason of chemical hazards encountered in a manner capable of causing injury or impairment in the function of any part of the body through absorption, inhalation or physical contact.
F. Background. 29 CFR 1910.151 (c) , Medical Services and First Aid, needs clarification regarding its applicability to the hazards of electric storage battery charging areas and the potential exposure of employees to electrolyte(s). There is a clear need to identify the extent and suitability of minimum acceptable eye wash and body quick drenching facilities which are available to potentially exposed employees. 1. The extent of potential employee exposure varies with workplace situations such as:
a. Employee functions.
b. Type of electrolyte(s) and concentration.
c. Type and size of batteries.
d. Facility layout.
e. Personal protective equipment used.
2. The need for eye wash and body quick drenching equipment varies with the factors noted in F.1. Therefore, judicious enforcement of the standard
4
OSHA Instruction STD 1-8.2 March 8, 1982 Office of Compliance Programming
should provide for an evaluation of the contributing factors relative to the potential hazardous exposure, and should permit appropriate minimum assurances for adequate first aid and subsequent treatment.
3. Various forms of eye wash equipment are available today. Many are of the portable or self contained wall mounted type which are limited in the quantity of water available for eye wash purposes, and usually do not provide for body drenching. This equipment may be used for compliance with 29 CFR 1910.151(c) only when it is not economically feasible to provide plumbed equipment and/or where the potential employee exposure to electrolyte(s) is determined to be slight.
4. Eye wash equipment should provide copious low velocity flow of portable water at a suitable temperature, generally between 60 degrees F and 105 degrees F.
Thorne G. Auchter Assistant Secretary DISTRIBUTION: National, Regional and Area Offices All Compliance Officers State Designees NIOSH Regional Program Directors
5

Tuesday, October 16, 2012

Appendix A to § 1910.151 -- First aid kits (Non-Mandatory)

First aid supplies are required to be readily available under paragraph § 1910.151(b). An example of the minimal contents of a generic first aid kit is described in American National Standard (ANSI) Z308.1-1998

ANSI's first aid standard has been fundamentally changed, from a design-based standard to a new performance-based standard. All products are now required to meet specific performance criteria. Kits in compliance will contain specific numbers of required items to treat major and minor wounds, minor burns and eye injuries.
Kits are now classified into three types:
Type I
Intended use: stationary, indoor settings, in a controlled environment
Potential for damage of kit contents: minimal
Requirements: minimum fill requirements; means for mounting in fixed position.
Typical applications: general indoor use, offices, manufacturing facilities
Type II
Intended use: portable, indoor settings, in a controlled environment
Potential for damage of kit contents: minimal
Requirements: minimum fill requirements; carrying handle; subjected to a drop test
Typical applications: general indoor use, offices, manufacturing
Type III
Intended use: portable use outdoors and in mobile industries
Potential for damage of kit contents: significant
Requirements: moisture-resistant, corrosion-resistant, carrying handle; minimum fill requirements; means for mounting in fixed position; subjected to conditioning and drop tests
Typical applications: general outdoor use, mobile industries
Fill Requirements:
Item Unit Minimum
Quantity
Absorbent Compress 32 sq. in. (81.3 sq. cm) 1
Adhesive Bandages 1" x 3" (2.5 x 7.5 cm) 16
Adhesive Tape 5 yd. (457.2 cm) 1
Antiseptic 0.5 g (0.14 fl. oz) 10
Burn Treatment 0.5 g (0.14 fl. oz) 6
Medical Exam Gloves Pair 2
Sterile Pad 3" x 3" (7.5 x 7.5 cm) 4
Triangular Bandage 40" x 40" x 56" (101 x 101 x 142 cm) 1

 The contents of the kit listed in the ANSI standard should be adequate for small worksites. When larger operations or multiple operations are being conducted at the same location, employers should determine the need for additional first aid kits at the worksite, additional types of first aid equipment and supplies and additional quantities and types of supplies and equipment in the first aid kits.

In a similar fashion, employers who have unique or changing first-aid needs in their workplace may need to enhance their first-aid kits. The employer can use the OSHA 300 log, OSHA 301 log, or other reports to identify these unique problems. Consultation from the local fire/rescue department, appropriate medical professional, or local emergency room may be helpful to employers in these circumstances. By assessing the specific needs of their workplace, employers can ensure that reasonably anticipated supplies are available. Employers should assess the specific needs of their worksite periodically and augment the first aid kit appropriately.

If it is reasonably anticipated that employees will be exposed to blood or other potentially infectious materials while using first aid supplies, employers are required to provide appropriate personal protective equipment (PPE) in compliance with the provisions of the Occupational Exposure to Blood borne Pathogens standard, § 1910.1030(d)(3) (56 FR 64175). This standard lists appropriate PPE for this type of exposure, such as gloves, gowns, face shields, masks, and eye protection.

Wednesday, October 10, 2012

First Aid Training and Maintenance of Medical Records

February 5, 2007

Dear Mr. Sutherland:

Thank you for your letter to the Occupational Safety and Health Administration (OSHA). Your letter asked for clarification of the requirements for provision of first aid training to employees as well as on the maintenance of medical records under OSHA's bloodborne pathogens standard, 29 CFR 1910.1030. We apologize for the delay in addressing your concerns. This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any question not delineated within your original correspondence. Your question is restated below, followed by OSHA's response.

Scenario: The facility, a clinical laboratory, is located an average of four minutes away from a fire department that provides first aid assistance.

Question 1: Would it be acceptable under 29 CFR 1910.151(b) in Subpart K, "Medical and First Aid," for the facility to rely on the fire department and avoid having employees trained in first aid to address emergency situations on site?

Response 1: The OSHA standard at 29 CFR 1910.151(b) 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 . . . ." The primary requirement addressed by this standard is that an employer must ensure prompt first aid 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 to the worksite. The basic purpose of this standard is to assure 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.

One option this standard provides employers is to ensure that a member of the workforce has been trained in first aid. This option is, for most employers, a feasible and low-cost way to protect employees, as well as putting the employer in compliance with the standard. The other option for employers is to rely upon the reasonable proximity of an infirmary, clinic, or hospital. OSHA has consistently taken the view that the reasonable availability of a trained emergency service provider, such as fire department paramedics or EMS responders, would be equivalent to the "infirmary, clinic, or hospital" specified by the literal wording of the standard. Emergency medical services can be provided either onsite or by evacuating the employee to an off-site facility in cases where that can be done safely.

An employer who contemplates relying on assistance from outside emergency responders as an alternative to providing a first-aid trained employee must take a number of factors into account. The employer must take appropriate steps prior to any accident (such as making arrangements with the service provider) to ascertain that emergency medical assistance will be promptly available when an injury occurs. While the standard does 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. This interpretation generally has been upheld by the Occupational Safety and Health Review Commission, an independent tribunal that decides OSHA cases, and by federal courts.

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. Since your facility is an average of 4 minutes from the fire department and thus possibly more than 4 minutes away from the fire station in reality, you may not rely on its emergency service providers to fulfill your obligation under the standard if such serious injuries are possible at your workplace. As a matter of enforcement discretion, OSHA recognizes that a somewhat longer response time of up to 15 minutes may be reasonable in workplaces, such as offices, where the possibility of such serious work-related injuries is more remote. If that is the case in your workplace, you are allowed to rely on the fire department, which is an average of 4 minutes away from your workplace.

Question 2: Is it acceptable for the employer to provide training on first aid, including CPR, as well as first aid supplies, to employees who are not officially responsible for performing first aid, including CPR, and who would be responding on a voluntary basis?

Response 2: The OSHA standard, 1910.151(b), does not prohibit employers from providing first aid training to employees, even when the employees will not be expected to respond in workplace emergencies. However, if the company does not plan to designate employees as first aid responders, then OSHA would recommend that employees who participate in company-provided first aid training (including CPR) should be made aware of the company's plan for addressing all workplace medical emergencies.

Question 3: Under 29 CFR 1910.1030, may a company use employee numbers in place of social security numbers in the company's medical record file when the company only maintains declination forms, dates of vaccination, titer results, and dates of treatment? All other medical records and information regarding employee's medical examinations are maintained by the healthcare professional where treatment is provided.

Response 3: Section 1910.1030(h)(1)(ii)(A) of the bloodborne pathogens standard requires that employee medical records shall include the name and social security number of the employee.

Medical records must be ". . . provided upon request for examination and copying to the subject employee, to anyone having written consent of the subject employee, to the Director of the National Institute of Occupational Safety and Health [NIOSH] and to the Assistant Secretary of Labor [OSHA]."

if a company chooses to keep a second set of records which are identified by employee numbers in place of social security numbers, it may do so. However, whenever a record is requested by an employee, a designated employee representative, or representatives of the OSHA or NIOSH, the employer must assure access to the records containing the employee's social security number within a reasonable time, place, and manner.

Thank you for your interest in occupational safety and health. We hope this provides the clarification you were seeking. OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. 


Sincerely,

Richard E. Fairfax
Directorate of Enforcement Programs

Thursday, May 24, 2012

Fundamentals of a Workplace First Aid Program: First Aid Supplies & AEDs

First Aid Supplies

It is advisable for the employer to give a specific person the responsibility for choosing the types and amounts of first-aid supplies and for maintaining these supplies. The supplies must be adequate, should reflect the kinds of injuries that occur, and must be stored in an area where they are readily available for emergency access. An
automated external defibrillator (AED) should be considered when selecting first-aid supplies and equipment.
A specific example of the minimal contents of a workplace firstaid kit is described in American National Standards Institute ANSI Z308.1 - 2003, Minimum Requirements for Workplace First Aid Kits. The kits described are suitable for small businesses. For large operations, employers should determine how many first-aid kits are needed, and if it is appropriate to augment the kits with additional first-aid equipment and supplies. Employers who have unique or changing first-aid needs should consider upgrading their first-aid kits. The employer can use the OSHA 300 log, OSHA 301 reports or other records to identify the first-aid supply needs of their worksite. Consultation with the local fire and rescue service or emergency medical professionals may be beneficial. By assessing the specific needs of their workplaces, employers can ensure the availability of adequate first-aid supplies. Employers should periodically reassess the demand for these supplies and adjust their inventories.

Automated External Defibrillators

With recent advances in technology, automated external defibrillators (AEDs) are now widely available, safe, effective, portable, and easy to use. They provide the critical and necessary treatment for sudden cardiac arrest (SCA) caused by ventricular fibrillation, the uncoordinated beating of the heart leading to collapse and death. Using AEDs as soon as possible after sudden cardiac arrest, within 3-4 minutes, can lead to a 60% survival rate.3 CPR is of value because it supports the circulation and ventilation of the victim until an electric shock delivered by an AED can restore the fibrillating heart to normal. All worksites are potential candidates for AED programs because of the possibility of SCA and the need for timely defibrillation. Each workplace should assess its own requirements for an AED program as part of its first-aid response. A number of issues should be considered in setting up a worksite AED program: physician oversight; compliance with local, state and federal regulations; coordination with local EMS; a quality assurance program; and a periodic review, among others. The OSHA website at www.osha.gov or the websites of the American College of Occupational and  Environmental Medicine at www.acoem.org, the American Heart Association at www.americanheart. org, the American Red Cross at www.redcross.org, Federal Occupational Health at www.foh.dhhs.gov, and the National Center for Early Defibrillation at www.early-defib.org can provide additional information about AED program development.

Tuesday, May 8, 2012

Safety Showers: Which ANSI standard does OSHA enforce?

Dear Mr. King:

Thank you for your letter to the Occupational Safety and Health Administration (OSHA). You requested an interpretation of 29 CFR 1910.151, Medical Services and First Aid, specifically, section (c) regarding, "suitable facilities for quick drenching or flushing of the eyes and body." Your question has been restated below for clarity. Please accept our apology for the delay in this response.

Background: Your company, a large manufacturer and distributor of sulfuric acid, requires the services of many third party terminals and distributors to assist with the handling of your product. You have specific criteria when acquiring a new terminal that it must meet before a contract is signed. One of these requirements is the need for safety showers that meet or exceed OSHA requirements; OSHA has quoted ANSI Z358.1-1990 in several letters of interpretation. However, there is a new ANSI Z358.1-1998 standard that goes into much more detail and would require some facilities to make a significant capital expenditure to comply.

Question: Which ANSI standard does OSHA enforce?

Answer: ANSI standards become mandatory OSHA standards only when, and if, they are adopted by OSHA; ANSI Z358.1 was not adopted by OSHA. In comparison with the OSHA standard at 29 CFR 1910.151(c), however, ANSI Z358.1 provides detailed information regarding the installation and operation of emergency eyewash andshower equipment. OSHA, therefore, has often referred employers to ANSI Z358.1 as a recognized source of guidance for protecting employees who are exposed to injurious corrosive materials.

OSHA would also take the ANSI standard into consideration when evaluating the adequacy of the protection provided by an employer. OSHA recognizes that there are differences between the 1990 and 1998 versions of ANSI Z358.1, and is planning to develop a compliance directive addressing this issue to ensure uniform and consistent enforcement of 29 CFR 1910.151(c). In the meantime, employers should assess the specific conditions in the workplace and determine whether compliance with the 1998 version of the ANSI Z358.1 will provide protection for employees that compliance with the 1990 version would not.

Thank you for your interest in occupational safety and health. If you have further questions, please feel free to contact the [Office of General Industry Enforcement] at (202) 693-1850.

Sincerely,


John L. Henshaw
Assistant Secretary

Wednesday, April 11, 2012

Is it mandatory for all workplaces to provide a first aid kit?

Title 29 CFR 1910.151(b) states: "In the absence of an infirmary, clinic, or hospital in near proximity to the workplace which is used for 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."

Employers may elect not to provide first aid services if all such services will be provided by a hospital, infirmary, or clinic in near proximity to the workplace. If the employer has persons who are trained in first aid, then adequate first aid supplies must be readily available for use. Therefore, employers are required to provide first aid supplies that are most appropriate to respond to incidents at their workplaces. OSHA allows employers to provide first aid supplies specific to the needs of their workplace.

Although we have provided our interpretation of the federal standard, twenty-six states, including California, operate their own OSHA-approved occupational safety and health programs. These State-plan States adopt and enforce their own standards, which may have different requirements from the federal standards regarding medical services and supplies. The California Department of Industrial Relations (Cal-OSHA) administers the state plan program.

Friday, January 27, 2012

CAL/OSHA First Aid Contents Requirement

The Federal OSHA Regulation 29 CFR 1910.151(B) states "Adequate first aid supplies shall be readily available." Cal/OSHA has a slightly different verbiage and regulation that is more stringent. "The minimum first-aid supplies shall be determined by an employer-authorized, licensed physician or in accordance with the following Table:

Type of Supply Required

by Number of Employees
Supplies for First Aid



over
Dressings in adequate quantities consisting of:
1-5
6-15
16-200
200
1. Adhesive dressings
X
X
X
X
2. Adhesive tape rolls, 1-inch wide
X
X
X
X
3. Eye dressing packet
X
X
X
X
4. 1-inch gauze bandage roll or compress

X
X
X
5. 2-inch gauze bandage roll or compress
X
X
X
X
6. 4-inch gauze bandage roll or compress

X
X
X
7. Sterile gauze pads, 2-inch square
X
X
X
X
8. Sterile gauze pads, 4-inch square
X
X
X
X
9. Sterile surgical pads suitable for




pressure dressings


X
X
10. Triangular bandages
X
X
X
X
11. Safety pins
X
X
X
X
12. Tweezers and scissors
X
X
X
X
* Additional equipment in adequate




quantities consisting of:




13. Cotton-tipped applicators


X
X
14. Forceps


X
X
15. Emesis basin


X
X
16. Flashlight


X
X
17. Magnifying glass


X
X
18. Portable oxygen and its




breathing equipment



X
19. Tongue depressors



X
Appropriate record forms
X
X
X
X
Up-to-date 'standard' or 'advanced'




first-aid textbook, manual or




equivalent
X
X
X
X

---------

*To be readily available but not necessarily within the first-aid kit."
§1512. Emergency Medical Services.(c)(1)
National Safety Compliance has a wide range of First Aid Kits to choose from, starting with small personal first aid kits to large 5-shelf First Aid Cabinets.

Friday, January 13, 2012

OSHA Interpretations regarding Safety Showers & Eye Washes

Question 1: We, as a company, have recommended to our customers that they comply with the requirements of ANSI Z358.1-2004, American National Standard for Emergency Eyewash and Shower Equipment. If a customer does so and the equipment is provided within the work area for immediate use by our own employees, have we made a reasonable effort to comply with 29 CFR 1910.151(c)?

Paragraph (c) of 29 CFR 1910.151 requires that suitable facilities for quick drenching or flushing be provided within the work area for immediate use if an employee's eyes or body may be exposed to corrosive materials. The OSHA standard does not set specifications for emergency eyewash and shower equipment, but we agree that equipment that complies with ANSI requirements would usually meet the intent of the OSHA standard. It should also be noted that, in addition to the requirement for emergency flushing and drenching facilities, there are also requirements for personal protective equipment (PPE) when employees are exposed to the hazards which corrosive chemicals present. PPE requirements are found in Subpart I, Personal Protective Equipment, of 29 CFR §1910 and may include, but are not limited to, protection for the eyes, face, and hands, as well as protective clothing. The purpose of PPE is to prevent injury, whereas the purpose of the eye wash or shower is to minimize injury, should that first line of defense fail.

Question 2: Deliveries often occur at night or when the retail location is closed. When our driver arrives at the facility under these circumstances, he or she must use a key to enter the facility and the unloading area. The quick drenching facilities are located in the unloading area. Does the necessity of a key violate the accessibility requirement of the ANSI standard?

Although OSHA often refers employers to ANSI Z358.1-2004 for guidance in the installation and operation of quick drenching and flushing equipment, OSHA does not interpret ANSI standards; OSHA may only provide interpretations of its own regulations. OSHA has its own requirements for the location and accessibility of quick drenching or flushing facilities. 29 CFR 1910.151(c) states that "[w]here the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use" (emphasis added). While the need to use a key to unlock a door to reach the quick drenching or flushing facilities would ordinarily pose a problem, it appears that in your case your employee would already be inside the unloading area where the quick drenching facilities are located and where presumably any exposure to the injurious corrosive materials would occur.

Question 3: Who is responsible for providing the quick drenching and flushing facilities?

Every employer with employees exposed to the corrosive chemicals is responsible for the safety and health of their employees. A delivery company may comply with the requirement to provide quick drenching and flushing facilities in a number of ways. The delivery company may elect to provide self-contained, portable equipment on the delivery vehicle. A possibly more convenient option for compliance would be to use the facilities provided by the retail employer for the retail employees. We envision that, in the majority of cases, the retail employer will have employees similarly exposed to the corrosive chemicals and thus would be required to provide quick drenching and flushing facilities for their employees. The delivery and retail employers coordinate other elements of their business relationship, such as delivery time, location, and quantity; the coordination of safety and health responsibilities can and should be included in this process. If the retail employer does not provide these facilities or if facilities are provided but are not appropriately selected and located for immediate emergency use by the delivery employees, then the delivery employer would still be required to provide suitable quick drenching and flushing facilities for its employees. The delivery employer needs to evaluate the work process, assessing factors such as configuration of the work area, the corrosivity of the materials, and the potential created by the work process for the corrosive chemical to come into contact with the employee. The delivery employer would then train employees as to the hazards presented, select and require appropriate PPE, and provide suitable quick drenching and flushing facilities for immediate use by their employees.

Question 4: Are small businesses (e.g., retail stores) subject to 29 CFR 1910.151(c), if they handle corrosive liquid materials?

Yes. All employers, regardless of size, that have employees whose eyes or body may be exposed to injurious corrosive materials must provide quick drenching and flushing facilities.

Question 5: Is there a quantity of corrosive chemical that triggers the requirements of 29 CFR 1910.151(c)?

No, there is no threshold quantity of corrosive material that triggers the requirement. The determining factor for the application of the standard is the possible exposure of an employee to injury from contact with a corrosive material.

As you may know, a number of states administer their own occupational safety and health programs under plans approved and monitored by Federal OSHA. It is possible that some of your customers are located in these State Plan States. Therefore, employers in these states must comply with their own State's occupational safety and health requirements. As a condition of plan approval, States are required to adopt and enforce occupational safety and health standards and interpretations that are at least effective as those promulgated by Federal OSHA. However, some states may have different or more stringent requirements.

Thursday, January 5, 2012

Many companies required to post OSHA 300A Recordkeeping Report

February 1 is not far away which means many employers must have their 300A Recordkeeping Report of work-related fatalities, injuries and illnesses posted in the workplace. Below are some common questions regarding the 29 CFR 1904 Recording and Reporting Occupational Injuries and Illnesses:

Question 0-1. Why are employers required to keep records of work-related injuries and illnesses?

The OSH Act of 1970 requires the Secretary of Labor to produce regulations that require employers to keep records of occupational deaths, injuries, and illnesses. The records are used for several purposes.

Injury and illness statistics are used by OSHA. OSHA collects data through the OSHA Data Initiative (ODI) to help direct its programs and measure its own performance. Inspectors also use the data during inspections to help direct their efforts to the hazards that are hurting workers.

The records are also used by employers and employees to implement safety and health programs at individual workplaces. Analysis of the data is a widely recognized method for discovering workplace safety and health problems and for tracking progress in solving those problems.

The records provide the base data for the BLS Annual Survey of Occupational Injuries and Illnesses, the Nation's primary source of occupational injury and illness data.

Question 0-2. What is the effect of workers' compensation reports on the OSHA records?

The purpose section of the rule includes a note to make it clear that recording an injury or illness neither affects a person's entitlement to workers' compensation nor proves a violation of an OSHA rule. The rules for compensability under workers' compensation differ from state to state and do not have any effect on whether or not a case needs to be recorded on the OSHA 300 Log. Many cases will be OSHA recordable and compensable under workers' compensation. However, some cases will be compensable but not OSHA recordable, and some cases will be OSHA recordable but not compensable under workers' compensation.

Question 2-1. How can I get help to find my SIC Code and determine if I'm partially exempt from the recordkeeping rule?

You can access the statistics section of OSHA's internet home page, at http://www.osha.gov/oshstats/. Go to the website and choose SIC Manual and follow the directions. If you still cannot determine your SIC code, you can call an OSHA area office, or, if you are in a state with an OSHA-approved state plan, call your State Plan office. See the OSHA Office Directory.

Question 2-2. Do States with OSHA-approved State plans have the same industry exemptions as Federal OSHA?

States with OSHA-approved plans may require employers to keep records for the State, even though those employers are within an industry exempted by the Federal rule.

Question 2-3. Do professional sports teams qualify for the partial industry exemption in section 1904.2?

No. Only those industry classifications listed in Appendix A to Subpart B qualify for the partial industry exemption in section 1904.2. Professional sports teams are classified under Standard Industrial Classification (SIC) code 794, which is not one of the listed exempt classifications.

Question 4-1. Does an employee report of an injury or illness establish the existence of the injury or illness for recordkeeping purposes?

No. In determining whether a case is recordable, the employer must first decide whether an injury or illness, as defined by the rule, has occurred. If the employer is uncertain about whether an injury or illness has occurred, the employer may refer the employee to a physician or other health care professional for evaluation and may consider the health care professional's opinion in determining whether an injury or illness exists. [Note: If a physician or other licensed health care professional diagnoses a significant injury or illness within the meaning of Section 1904.7(b)(7) and the employer determines that the case is work-related, the case must be recorded.]

Question 5-1. If a maintenance employee is cleaning the parking lot or an access road and is injured as a result, is the case work-related?

Yes, the case is work-related because the employee is injured as a result of conducting company business in the work environment. If the injury meets the general recording criteria of Section 1904.7 (death, days away, etc.), the case must be recorded.

Question 5-2. Are cases of workplace violence considered work-related under the new Recordkeeping rule?

The Recordkeeping rule contains no general exception, for purposes of determining work-relationship, for cases involving acts of violence in the work environment. However, some cases involving violent acts might be included within one of the exceptions listed in section 1904.5(b)(2). For example, if an employee arrives at work early to use a company conference room for a civic club meeting and is injured by some violent act, the case would not be work-related under the exception in section 1904.5(b)(2)(v).

Question 5-3. What activities are considered "personal grooming" for purposes of the exception to the geographic presumption of work-relatedness in section 1904.5(b)(2)(vi)?

Personal grooming activities are activities directly related to personal hygiene, such as combing and drying hair, brushing teeth, clipping fingernails and the like. Bathing or showering at the workplace when necessary because of an exposure to a substance at work is not within the personal grooming exception in section 1904.5(b)(2)(vi). Thus, if an employee slips and falls while showering at work to remove a contaminant to which he has been exposed at work, and sustains an injury that meets one of the general recording criteria listed in section 1904.7(b)(1), the case is recordable.

Question 5-4. What are "assigned working hours" for purposes of the exception to the geographic presumption in section 1904.5(b)(2)(v)?

"Assigned working hours," for purposes of section 1904.5(b)(2)(v), means those hours the employee is actually expected to work, including overtime.

Question 5-5. What are "personal tasks" for purposes of the exception to the geographic presumption in section 1904.5(b)(2)(v)?

"Personal tasks" for purposes of section 1904.5(b)(2)(v) are tasks that are unrelated to the employee's job. For example, if an employee uses a company break area to work on his child's science project, he is engaged in a personal task.

Question 5-6. If an employee stays at work after normal work hours to prepare for the next day's tasks and is injured, is the case work-related? For example, if an employee stays after work to prepare air-sampling pumps and is injured, is the case work-related?

A case is work-related any time an event or exposure in the work environment either causes or contributes to an injury or illness or significantly aggravates a pre-existing injury or illness, unless one of the exceptions in section 1904.5(b)(2) applies. The work environment includes the establishment and other locations where one or more employees are working or are present as a condition of their employment. The case in question would be work-related if the employee was injured as a result of an event or exposure at work, regardless of whether the injury occurred after normal work hours.

Question 5-7. If an employee voluntarily takes work home and is injured while working at home, is the case recordable?

No. Injuries and illnesses occurring in the home environment are only considered work-related if the employee is being paid or compensated for working at home and the injury or illness is directly related to the performance of the work rather than to the general home environment.

Question 5-8. If an employee's pre-existing medical condition causes an incident which results in a subsequent injury, is the case work-related? For example, if an employee suffers an epileptic seizure, falls, and breaks his arm, is the case covered by the exception in section 1904.5(b)(2)(ii)?

Neither the seizures nor the broken arm are recordable. Injuries and illnesses that result solely from non-work-related events or exposures are not recordable under the exception in section 1904.5(b)(2)(ii). Epileptic seizures are a symptom of a disease of non-occupational origin, and the fact that they occur at work does not make them work-related. Because epileptic seizures are not work-related, injuries resulting solely from the seizures, such as the broken arm in the case in question, are not recordable.

Question 5-9. This question involves the following sequence of events: Employee A drives to work, parks her car in the company parking lot and is walking across the lot when she is struck by a car driven by employee B, who is commuting to work. Both employees are seriously injured in the accident. Is either case work-related?

Neither employee's injuries are recordable. While the employee parking lot is part of the work environment under section 1904.5, injuries occurring there are not work-related if they meet the exception in section 1904.5(b)(2)(vii). Section 1904.5(b)(2)(vii) excepts injuries caused by motor vehicle accidents occurring on the company parking lot while the employee is commuting to and from work. In the case in question, both employees' injuries resulted from a motor vehicle accident in the company parking lot while the employees were commuting. Accordingly, the exception applies.

Question 5-10. How does OSHA define a "company parking lot" for purposes of Recordkeeping?

Company parking lots are part of the employer's premises and therefore part of the establishment. These areas are under the control of the employer, i.e. those parking areas where the employer can limit access (such as parking lots limited to the employer's employees and visitors). On the other hand, a parking area where the employer does not have control (such as a parking lot outside of a building shared by different employers, or a public parking area like those found at a mall or beneath a multi-employer office building) would not be considered part of the employers establishment (except for the owner of the building or mall), and therefore not a company parking lot for purposes of OSHA recordkeeping.

Question 5-11. An employee experienced an injury or illness in the work environment before they had "clocked in" for the day. Is the case considered work- related even if that employee was not officially "on the clock" for pay purposes?

Yes. For purposes of OSHA recordkeeping, injuries and illnesses occurring in the work environment are considered work-related. Punching in and out with a time clock (or signing in and out) does not affect the outcome for determining work-relatedness. If the employee experienced a work-related injury or illness, and it meets one or more of the general recording criteria under section 1904.7, it must be entered on the employer's OSHA 300 log.

Question 5-12. Is work-related stress recordable as a mental illness case?

Mental illnesses, such as depression or anxiety disorder, that have work-related stress as a contributing factor, are recordable if the employee voluntarily provides the employer with an opinion from a physician or other licensed health care professional with appropriate training and experience (psychiatrist, psychologist, psychiatric nurse practitioner, etc.) stating that the employee has a mental illness that is work-related, and the case meets one or more of the general recording criteria. See sections 1904.5(b)(2)(ix) and 1904.7.

Question 5-13. If an employee dies or is injured or infected as a result of terrorist attacks, should it be recorded on the OSHA Injury and Illness Log? Should it be reported to OSHA?

Yes, injuries and illnesses that result from a terrorist event or exposure in the work environment are considered work-related for OSHA recordkeeping purposes. OSHA does not provide an exclusion for violence-related injury and illness cases, including injuries and illnesses resulting from terrorist attacks.

Within eight (8) hours after the death of any employee from a work-related incident or the in-patient hospitalization of three or more employees as a result of a work-related incident, an employer must orally report the fatality/multiple hospitalization by telephone or in person to the OSHA Area that is nearest to the site of the incident. An employer may also use the OSHA toll-free central telephone number, 1-800-321-OSHA (1-800-321-6742).