Tuesday, November 10, 2015

Common FAQs

October [5], 1992

Mr. David R. C***
Rockville, Maryland

Dear Mr. C***:

Thank you for your inquiry of July 24, addressed to the Office of Information and Consumer Affairs, Occupational Safety and Health Administration, requesting all available public information about 29 CFR 1910.151, First Aid Programs, and answers to some specific questions.

Copies of pertinent interpretations are enclosed for your information.

Your specific questions and our responses are as follows:

Question 1. Does 29 CFR 1910.151 apply to all employers? If not, to whom does it apply?

Response: Yes, it applies to all employers in general industry, regardless of size, except for state and local government entities and employers that fall under the jurisdiction of other Federal Agencies.

Question 2. What is meant by "plant health" in 29 CFR 1910.151[(a)]?

Response: "Plant health" in 29 CFR 1910.151[(a)] means the overall safety and health condition of the employees in the plant.

Question 3. What does an employer do if he has no "health room" or other provisions for first aid?

Response: [For the response to this question, please see the
 1/16/2007 letter to Mr. Brogan for OSHA's current policy on "near proximity."]

Question 4. What if an employer has 27 locations or offices and only one (the headquarters) has a health unit?

Response: The employer may seek assistance from outside first aid professionals that can meet the required response times, or the employer may provide his own adequately staffed and trained first aid staff that can meet the required response times for all locations.

Question 5. Does 29 CFR 1910.151 apply to small employers?

Response: The response to this question is the same as the response to question #1.

Question 6. Does it apply to offices?

Response: Yes, 29 CFR 1910.151 does apply to offices.

Question 7. Please explain the reference to sources of standards in [1910.151], specifically 41 CFR 50-204.6.

Response: 41 CFR 50-204.6 is a source standard from Title 41, Subtitle B, and it requires the availability of first aid to employees of employers granted public contracts from the Department of Labor. The language, for 29 CFR 1910.151 was derived from 40 CFR 50-204.6.

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


Roger A. Clark, Acting Director

Tuesday, October 20, 2015

1904.7 (b)(5)(ii) What is “first aid”?

For the purposes of Part 1904, "first aid" means the following:

(A) Using a nonprescription medication at nonprescription strength (for medications available in both prescription and non-prescription form, a recommendation by a physician or other licensed health care professional to use a non-prescription medication at prescription strength is considered medical treatment for recordkeeping purposes);
(B) Administering tetanus immunizations (other immunizations, such as Hepatitis B vaccine
or rabies vaccine, are considered medical treatment);
(C) Cleaning, flushing or soaking wounds on the surface of the skin;
(D) Using wound coverings such as bandages, Band-Aids™, gauze pads, etc.; or using
butterfly bandages or Steri-Strips™ (other wound closing devices such as sutures,
staples, etc. are considered medical treatment);
(E) Using hot or cold therapy;
(F) Using any non-rigid means of support, such as elastic bandages, wraps, non-rigid back
belts, etc. (devices with rigid stays or other systems designed to immobilize parts of the
body are considered medical treatment for recordkeeping purposes);
(G) Using temporary immobilization devices while transporting an accident victim (e.g.,
splints, slings, neck collars, back boards, etc.).
(H) Drilling of a fingernail or toenail to relieve pressure, or draining fluid from a blister;
(I) Using eye patches;
(J) Removing foreign bodies from the eye using only irrigation or a cotton swab;
(K) Removing splinters or foreign material from areas other than the eye by irrigation,
tweezers, cotton swabs or other simple means;
(L) Using finger guards;
(M) Using massages (physical therapy or chiropractic treatment are considered medical
treatment for recordkeeping purposes); or
(N) Drinking fluids for relief of heat stress.

(iii) Are any other procedures included in first aid?
No, this is a complete list of all treatments considered first aid for Part 1904 purposes.

Tuesday, October 13, 2015

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.

Monday, October 5, 2015

The Risks: Assess the risks and design a first-aid program specific for the worksite cont'd

Figure 3 reflects total injuries and illnesses by NAICS sector based on 2004 BLS data. Data that are more specific to businesses within these sectors may be obtained from the BLS website.

 The graph in Figure 4 shows the number of injuries and illnesses in private industry by the type of event or exposure responsible for them that resulted in days away from work in 2004. More detailed data may be found on the BLS website.

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, September 29, 2015

The Risks: Assess the risks and design a first-aid program specific for the 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.

The graphs that follow provide examples of fatality, injury and illness analyses that can be developed using BLS data. Figure 1 shows the distribution by NAICS sector of workplace fatalities that occurred in private industry in 2004, the most recent year for which data was available.

 The categories of events or exposures responsible for workplace fatalities in 2004 are shown in Figure 2. More detailed data are available from the BLS website.