Monday, June 30, 2014

Medical and First Aid

It is a requirement of OSHA that employees be given a safe and healthy workplace that is reasonably free of occupational hazards. However, it is unrealistic to expect accidents not to happen. Therefore, employers are required to provide medical and first aid personnel and supplies commensurate with the hazards of the workplace. The details of a workplace medical and first aid program are dependent on the circumstances of each workplace and employer. The intent of this page is to provide general information that may be of assistance. If additional information is required, an Occupational Health Professional should be contacted.
Medical and first aid services are addressed in specific standards for the general industry, shipyard employment, marine terminals, longshoring, and the construction industry.

OSHA Standards

This section highlights OSHA standards, directives (instructions for compliance officers), and standard interpretations (official letters of interpretation of the standards) related to medical and first aid.
Note: Twenty-five states, Puerto Rico and the Virgin Islands have OSHA-approved State Plans and have adopted their own standards and enforcement policies. For the most part, these States adopt standards that are identical to Federal OSHA. However, some States have adopted different standards applicable to this topic or may have different enforcement policies.
General Industry (29 CFR 1910)
Shipyard Employment (29 CFR 1915)
  • 1915.87, Medical services and first aid
Marine Terminals (29 CFR 1917)
  • 1917.26, First aid and lifesaving facilities
Longshoring (29 CFR 1918)
  • 1918.97, First aid and lifesaving facilities (see appendix V of this part)
Construction Industry (29 CFR 1926)
  • 1926.23, First aid and medical attention

  • 1926.50, Medical services and first aid

Wednesday, June 25, 2014

Using ANSI Z358.1 as guidance to comply with 1910.151(c)

March 28, 2002

Mr. Scott K***
Independence, Ohio

 Dear Mr. K***:

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 and shower 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.

Wednesday, June 18, 2014

"Working alone" as in 1910.269

February 22, 1999

Regional Administrator

[Directorate of Enforcement Programs]

SUBJECT: Request for Interpretation of OSHA Standard 29 CFR 1910.269

In response to your memorandum of October 13, 1998, with reference to the inspection at the Little Goose Hydroelectric Dam facility operated by the Department of the Army, Walla Walla District, Corps of Engineers, the following interpretation of the applicable Occupational Safety and Health Administration (OSHA) Standards is submitted.

The facility is covered under 29 CFR 1910.269, Electric Power Generation, Transmission, and Distribution Standard. The interpretation of OSHA Standards with reference to the three specific situations requested by you is as follows:

Question No. 1: Does the OSHA Standard above require, at all shifts, that an employee in a generating station be reached by another employee or a second person, trained in cardio-pulmonary resuscitation (CPR) and first aid, within 4 minutes?

Reply: No, not in all circumstances. OSHA Standard 29 CFR 1910.269(b)(1)(ii) requires that for fixed work locations such as generating stations, the number of trained persons available shall be sufficient to ensure that each employee exposed to electric shock can be reached within 4 minutes by a trained person. However, where the existing number of employees is insufficient to meet this requirement (at a remote substation, for example), all employees at the work location shall be trained. In the rulemaking, OSHA clarified that this provision was required only for employees exposed to the hazards of electrical shock when they perform work on or associated with exposed lines or equipment energized at 50 volts or more. This does not pertain to employees working near insulated electrical equipment, as the exposure to electrical shock hazard is minimal.

Question No. 2: Does the OSHA Standard prohibit an employee from working alone in a generating station where emergency medical response service (EMRS) can not respond to a work-related accident within 4 minutes?

Reply: Yes, with respect to the working alone issue, OSHA Standard 29 CFR 1910.269 prohibits an employee from working alone if the duties of the employee in the hydroelectric dam generating station fall into one of the categories in paragraph 1910.269(l)(1)(i) and are not exempted by paragraph 1910.269(l)(1)(ii). The working alone issue is not dependent upon first aid/CPR response and the preceding reply addresses the 4 minute response time issue.

Question No. 3: In facilities, other than generating stations, where a hazard may or may not include electrical shock, do we permit "working alone" where EMRS can not respond within 4 minutes to an accident resulting in a critical injury, or within 15 minutes to an accident resulting in a serious non life-threatening injury?

Reply: In facilities other than Electric Power Generation, Transmission and Distribution that fall outside of the scope of OSHA Standard 29 CFR 1910.269, there is no general OSHA Standard that deals with the situation of an employee "working alone" except in specific situations such as emergency response, interior structural firefighting, or working in permit required confined spaces. Again, the working alone requirement is not dependent on medical treatment response time.

In summary, an employee must be accompanied by another employee if the duties of the night shift operator in the hydroelectric dam station fall into one of the categories in paragraph 1910.269(l)(1)(i) and are not exempted by paragraph 1910.269(l)(1)(ii). The CPR and first aid provisions, contained in paragraph 1910.269(b)(1) are dependent upon the type of electrical work performed by employee(s) and not the working alone issue. If an employee could be expected to be exposed to electric shock (at or beyond the 50 volt threshold hazard limit) in the course of performing his or her duties, then these requirements for field work and fixed work locations apply. In all general industry work situations, the medical services and first aid requirements set forth in paragraph[s] 1910.151[(b) and 1910.151(c)] apply. That existing section includes provisions for available medical personnel, first aid training and supplies and facilities for drenching or flushing of the eyes and body in the event of exposure to corrosive materials.

Wednesday, June 11, 2014

Logging Industry First Aid Kit List

• Part Number: 1910
• Part Title: Occupational Safety and Health Standards
• Subpart: R
• Subpart Title: Special Industries
• Standard Number: 1910.266 App A
• Title: First-aid Kits (Mandatory).

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]