Friday, March 28, 2014

Minimum Requirements for Logging Standard

29 CFR 1910.266 App A

The following list sets forth the minimally acceptable number and type of first-aid supplies for first-aid kits required under paragraph (d)(2) of the logging standard. The contents of the first-aid kit listed should be adequate for small work sites, consisting of approximately two to three employees. When larger operations or multiple operations are being conducted at the same location, additional first-aid kits should be provided at the work site or additional quantities of supplies should be included in the first-aid kits:
1. Gauze pads (at least 4 x 4 inches).
2. Two large gauze pads (at least 8 x 10 inches).
3. Box adhesive bandages (band-aids).
4. One package gauze roller bandage at least 2 inches wide.
5. Two triangular bandages.
6. Wound cleaning agent such as sealed moistened towelettes.
7. Scissors.
8. At least one blanket.
9. Tweezers.
10. Adhesive tape.
11. Latex gloves.
12. Resuscitation equipment such as resuscitation bag, airway, or
pocket mask.
13. Two elastic wraps.
14. Splint.
15. Directions for requesting emergency assistance.
[59 FR 51672, Oct. 12, 1994; 60 FR 47022, Sept. 8, 1995]

Thursday, March 20, 2014

General Clarification of 29 CFR 1910.151 (Medical Services and First Aid)

April 18, 2002

Mr. John M***

Dear Mr. M***:

Thank you for your November 21, 2001 letter to the Occupational Safety and Health Administration's (OSHA's) Directorate of Compliance Programs. You requested clarification of OSHA standard 29 CFR 1910.151 (Medical Services and First Aid). This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any questions not delineated within your original correspondence. Your questions have been restated below for clarity. We apologize for the delay in your response.

Question 1: How does the ANSI standard Z308.1-1998 relate to 29 CFR 1910.151(b)? In a non-industrial workplace (for example, a corporate office) where employees perform administrative duties and there are no specific employment-related injuries anticipated, would a kit matching the ANSI standard be sufficient for compliance with 29 CFR 1910.151(b)?

Reply: Paragraph (b) of 29 CFR 1910.151 requires that in the absence of an infirmary, clinic, or hospital near the workplace, a person or persons must be adequately trained to render first aid. Adequate first aid supplies must be readily available.

ANSI standards become mandatory OSHA standards only when, and if, they are adopted by OSHA; ANSI Z308.1,
Minimum Requirements for Workplace First Aid Kits, was not adopted by OSHA. However, ANSI Z308.1 provides detailed information regarding the requirements for first aid kits; OSHA has often referred employers to ANSI Z308.1 as a source of guidance for the minimum requirements for first aid kits.

The contents of the first aid kit listed in ANSI Z308.1 should be adequate for a small worksite, like the one you describe in your letter. However, larger or multiple operations should consider the need for additional first aid kits, additional types of first aid equipment, and first aid supplies in larger quantities. You may wish to consult your local fire and rescue department, an appropriate medical professional, your local OSHA area office, or a first aid supplier for assistance in putting together a first aid kit which suits the needs of your workplace. You should also periodically assess your kit and increase your supplies as needed.

Question 2: Are there any specific interpretations for the term “readily available”?

Reply: The term “readily available” is not defined in the standard. However, responding in a timely manner can mean the difference between life and death. Therefore, the person who has been trained to render first aid must be able to quickly access the first aid supplies in order to effectively provide injured or ill employees with first aid attention. The first aid supplies should be located in an easily accessible area, and the first aid provider generally should not have to travel through several doorways, hallways and/or stairways to access first aid supplies.

Question 3: Can an employer use the interpretation for “near proximity” (the 3-4 minute and 15 minute standards) for determining the quantity and location for first aid supplies?

[For the response to this question, please see the
01/16/2007 Letter to Mr. Brogan for OSHA's current policy on "near proximity."]

Question 4: Is there a standard for placing first aid kits and/or cabinets based on employee numbers, density, or geography?

Reply: 29 CFR 1910.151(b) does not specifically address the placement of first aid kits and/or cabinets based on employee numbers, density, or geography. Therefore, it is the employer's responsibility to assess the particular needs of the workplace and tailor first aid kits and their placement to the specific needs of the workplace.

Question 5: What “measuring stick” would an OSHA compliance officer use to determine acceptable first aid supplies for compliance with 29 CFR 1910.151(b)?

Reply: OSHA compliance officers take into consideration a variety of factors when assessing compliance with 29 CFR 1910.151(b). The factors that you mention above are some of the things that a compliance officer evaluates when assessing a first aid kit. We cannot provide a list of “exact requirements” which will apply for every workplace; each workplace must be evaluated on a case-by-case basis, taking into account the types of injuries and illnesses that are likely to occur at that workplace.

Question 6: Other than inspection of a site for specific hazards, are there quantitative measurements such as employee-to-kit ratios, time frames within which employees should be able to access supplies, etc.?

Reply: Please see our response to Question 4.

Friday, March 14, 2014

Training every year?

March 18, 1996

Mr. G***
Washington, D.C.

Dear Senator G***:

Thank you for your letter of February 9, on behalf of your constituent, Mr. Norman Willis, regarding the Occupational Safety and Health Administration's (OSHA) first aid standard.

It is not a requirement of OSHA that cardiopulmonary resuscitation (CPR) and first aid training take place every year. The OSHA requirement 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." However, please be advised that an employer has the prerogative to require employee training which exceeds OSHA standards.

First aid training is primarily received through the American Red Cross, the National Safety Council, and private institutions. The American Red Cross offers standard and advanced first aid courses via their local chapters. After completion of the course and successful passing of the written and practical tests, trainees receive two certificates; one in adult CPR and the other in first aid. Basic adult CPR retesting should occur every year and first aid skills and knowledge should be reviewed every three years.

Monday, March 10, 2014

Saving Sudden Cardiac Arrest Victims in the Workplace

Automated External Defibrillators

OSHA 3185-09N 2003

Improving survival from sudden cardiac arrest.
There are 220,000 victims of sudden cardiac arrest per year in the United States; about 10,000 sudden cardiac arrests occur at work.

Waiting for the arrival of emergency medical system personnel results in only 5-7% survival.

Studies with immediate defibrillation have shown up to 60% survival one year after sudden cardiac arrest.

Automated external defibrillators
An automated external defibrillator (AED) is a medical device designed to analyze the heart rhythm and deliver an electric shock to victims of ventricular fibrillation to restore the heart rhythm to normal. Ventricular fibrillation is the uncoordinated heart rhythm most often responsible for sudden cardiac arrest.

Sudden cardiac arrest
Sudden cardiac arrest occurs when ventricular fibrillation takes place or when the heart stops beating altogether. Without medical attention, the victim collapses, loses consciousness, becomes unresponsive, and dies. Many victims have no prior history of heart disease and are stricken without warning.

Causes of sudden cardiac arrest

  • Heart attack
  • Electrocution
  • Asphyxiation (loss of consciousness and death caused by inadequate oxygen in the work environment, such as in a confined space).

Reasons for AEDs in the workplace
  • Workers may suffer sudden cardiac arrest while on the job.
  • Onsite AEDs save precious treatment time, and can improve survival odds because they can be used before emergency medical service (EMS) personnel arrive.
  • A heart rhythm in ventricular fibrillation may only be restored to normal by an electric shock.
  • The AED is compact, lightweight, portable, battery operated, safe, and easy to use.

Placement of AEDs
  • AEDs should be conveniently installed to ensure response within 3-5 minutes.
  • Areas where many people work closely together, such as assembly lines and office buildings.
  • Close to a confined space.
  • Areas where electric-powered devices are used.
  • Outdoor worksites where lightning may occur.
  • Health units where workers may seek treatment for heart attack symptoms.
  • Company fitness units and cafeterias.
  • Remote sites, such as off-shore drilling rigs, construction projects, marine vessels, power transmission lines, and energy pipe lines.

AED program cost
AEDs cost $1200-$3000 per device. Training, annual retraining, and administrative costs are additional.

AED training
Your workers can easily be trained to:

  • Recognize sudden cardiac arrest and notify EMS personnel,
  • Perform cardiopulmonary resuscitation (CPR),
  • Provide early defibrillation with an AED, and
  • Care for the victim until EMS personnel arrive.
For more information, visit the OSHA website at or the websites of the following organizations:
  • American Heart Association
  • American College of Occupational and Environmental Medicine
  • American Red Cross
  • Federal Occupational Health
  • National Center for Early Defibrillation
  • National Safety Council


From the American Heart Association
  • A 41-year-old worker at a manufacturer of heating and air-conditioning systems suffered a sudden cardiac arrest at work. After three shocks and CPR he was revived within 4 minutes. Fortunately, his company had AEDs and trained responders. By the time EMS personnel arrived, he had been resuscitated and was moved to a hospital. The employee survived.

  • A 62-year-old employee of a coatings, glass, and chemical manufacturer suffered a sudden cardiac arrest after walking up the stairs to her office. Employees in the next office heard her fall and notified the plant emergency response team. She was defibrillated and saved in less than 2 minutes. EMS personnel then arrived to transport her to the hospital. She sent a note to the company after her discharge from the hospital saying she had "no doubt that headquarters spent money wisely."

  • An employee at an automobile manufacturer was working on the production line when he suddenly collapsed, lost consciousness, and stopped breathing. Plant security responded, and after two shocks with an AED, the employee's heart responded and his pulse returned. He's alive today thanks to the fast actions of his co-workers and the company's emergency response plan, which included AED installation and training.

From the National Institute for Occupational Safety and Health
  • While standing on a fire escape during a building renovation, a 30-year-old construction worker was holding a metal pipe with both hands. The pipe contacted a high voltage line, and the worker instantly collapsed. About 4 minutes later, a rescue squad arrived and began CPR. Within 6 minutes the squad had defibrillated the worker. His heartbeat returned to normal and he was transported to a hospital. The worker regained consciousness and was discharged from the hospital within 2 weeks.


These devices have a proven track record of saving lives in public places as well as in the workplace. They can do the same for you and your employees. Please consider installing AEDs in your workplace.