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
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.
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
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

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
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. 


Richard E. Fairfax
Directorate of Enforcement Programs