Friday, June 21, 2013

Electric Power Generation, Transmission, and Distribution.

Medical Services and First Aid

First Aid Requirements

The "269" standard requires employers to comply with the medical services and first aid provisions in 1910.151, which requires that:
  • Someone in the workplace is trained in first aid if no medical facilities exist in near proximity.
  • First aid supplies are readily available. First aid kit
  • Quick-drenching or flushing facilities are provided for immediate emergency use where the eyes or body of a person may be exposed to injurious corrosive materials.
In addition, 1910.269(b)(2) requires that field crews have first aid kits placed in weatherproof containers if the contents of the kits could be exposed to the weather.

Inspection and availability of first aid kits. First aid kits in vehicles or at company facilities must be placed in locations where they will be readily available when needed. 1910.151, Appendix A provides guidance on first aid kit contents and how to assess the needs of the work place, including exposure to Blood Borne Pathogens. Additionally, the contents of first aid kits must be inspected at least annually to ensure that the items are useable and all required items are present in the kits (1910.269(b)(3)).

While the standard does not specifically cover documenting the results of first aid kit inspections, some companies have initiated inspection documentation procedures in which staff inspect the contents of first aid kits at regular intervals and enter the inspection date and the inspector's initials on an inspection tag inside the kit.

Monday, June 17, 2013

Written test required?

Mr. Michael J. N***
Portland, Oregon

Dear Mr. N***:

Thank you for your letter of July 14, addressed to Dr. Ralph E. Yodaiken, Senior Medical Advisor for the Occupational Safety and Health Administration (OSHA). Your letter was forwarded to me for response. In your letter you asked for a written clarification whether successful completion of a first aid course may be demonstrated by means other than a written knowledge test.

According to 29 CFR 1910.151(b), a person or persons shall be adequately trained to render first aid. To be in compliance with this standard, employers must ensure that the trained person or persons have the ability to read medical documentation, including Material Safety Data Sheets, labels on medication and antidotes, and Med-Alert bands which could be referenced to render proper first aid to injured employees in the workplace. We believe that these abilities can best be demonstrated by means of a written test. It is, however, the ability to read the necessary information that is critical to compliance, not the means by which that ability is tested. Thus, lack of a written test does not, by itself, establish a violation of the standard if that ability can be demonstrated in some other fashion.

We appreciate you interest in employee safety and health. If we can be of further assistance, please do not hesitate to contact us.

Patricia K. Clark, Director
Directorate of Compliance Programs

Friday, June 7, 2013

CPR Training for employees in various locations?

Questions: You wrote that you teach first aid, including CPR, in the Winchester, VA, area. You have been asked by several employers what OSHA's standards are for first aid, including CPR and bloodborne pathogens. Your clients are employed at various workplaces, including, but not limited to, doctors' offices, construction companies, daycare facilities, and retirement homes. Does everyone have to be trained in first aid, including CPR and bloodborne pathogens? What if there is a career rescue squad within five miles of the workplace?

Replies: OSHA's standard for first aid training in general industry, 29 CFR 1910.151(b), provides:

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. Adequate first aid supplies shall be readily available.
In the construction industry, 29 CFR 1926.50(c) provides:
In the absence of an infirmary clinic, hospital, or physician, that is reasonably accessible in terms of time and distance to the worksite, which is available for the treatment of injured employees, a person who has a valid certificate in first-aid training from the U.S. Bureau of Mines, the American Red Cross, or equivalent training that can be verified by documentary evidence, shall be available at the worksite to render first aid.
The primary requirement addressed by these standards is that an employer must ensure prompt first aid treatment 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 of the worksite. The basic purpose of these standards 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 these standards provide 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 putting the employer clearly in compliance with the standards. OSHA recommends, but does not require, that every workplace include one or more employees who are trained and certified in first aid, including CPR.

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 standards. Emergency medical services can be provided either on-site or by evacuating the employee to an off-site facility in cases where that can be done safely.

However, the requirements that emergency medical services must be "reasonably accessible" or "in near proximity to the workplace" are stated only in general terms. 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 standards do 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, an interpretation that has been upheld by the Occupational Safety and Health Review Commission 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. OSHA exercises discretion in enforcing the first aid requirements in particular cases. 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.

The first aid training standards at 29 CFR 1910.151 and 1926.50(c) generally apply throughout the industries that they cover. Other standards which apply to certain specific hazards or industries make employee first aid training mandatory, and reliance on outside emergency responders is not an allowable alternative. For example, see 29 CFR 1910. 266(i)(7) (mandatory first aid training for logging employees), and 29 CFR 1910.269(b) (requiring persons trained in first aid at work locations in the electric power industry).

The bloodborne pathogens standard at 29 CFR 1910.1030(g)(2) requires employers to provide training to any employees who have occupational exposure to blood or other potentially infectious materials, such as employees assigned medical or first aid duties by their employers. The standard at 29 CFR 1910.1030(b) defines "occupational exposure" as "reasonably anticipated skin, eye, mucous membrane, or parenteral contact with blood or other potentially infectious materials that may result from the performance of an employee's duties." If an employee is trained in first aid and identified by the employer as responsible for rendering medical assistance as part of his/her job duties, that employee is covered by the bloodborne pathogens standard.

You may find these standards on OSHA's website, by following the link to "standards" and searching for "first aid," "bloodborne pathogens," "logging," etc. In addition, because you serve clients in Virginia, we should refer you to the standards of the Virginia Department of Labor and Industry (DOLI), which administers an OSHA-approved occupational safety and health plan. Virginia's general industry and construction first aid standards are the same as those of federal OSHA. However, Virginia may interpret its first aid standards more stringently than federal OSHA interprets its standards. Thus, we recommend that you also contact that agency.

Tuesday, June 4, 2013

5 Reasons to Get CPR Training

OSHA has developed a PowerPoint Presentation regarding the necessity of emergency preparedness in remote work zones.  The following is a snippet of information regarding cardiopulmonary resuscitation (CPR):
5 Reasons to Get CPR Training:
  1. By the time someone needs CPR they are dead.
  2. Being helpless in a crisis situation is a horrible feeling. When the victim is a friend or coworker you will want to know how you can help.
  3. CPR training teaches you how to handle a situation where you need to take control and give commands.
  4. CPR training teaches you how to use a defibrillator.
  5. CPR training will teach you how to keep yourself safe in an emergency situation.
Being trained in CPR is crucial for anyone. More trained citizens means a safer and faster acting community.
Many organizations offer CPR training. National Safety Council and the Red cross are a couple of examples.
The key aims of first aid can be summarized in three key points:
  • Preserve life
  • Prevent further harm
  • Promote recovery
First aid training also involves the prevention of initial injury and responder safety, and the treatment phases.