Sheila Dunn, D.A. and Sarah E. Alholm, M.A.S.
This is the first in a series of Featured Articles that cover OSHA compliance in the medical setting. Contributing authors, Sheila Dunn, D.A. and Sarah Alholm, M.A.S., answer common questions regarding first aid requirements for the medical workplace.
What should a workplace first aid kit contain?
OSHA's regulation 1910.151 (Medical services and first aid) refers to American National Standard (ANSI) Z308.1-2003, "Minimum Requirements for Workplace First Aid Kits.” According to OSHA, the kit recommended by ANSI should be adequate for small facilities; however, each individual employer should determine whether additional types or quantities of first aid equipment and supplies are needed. Consider the specific hazards and emergencies likely to occur at your facility and be sure the kit contains items necessary to handle them.
Other tips:
- Store first aid kits in a readily accessible location.
- Inspect kits regularly (monthly is recommended) for completeness and to remove any expired or expended material.
- Periodically (monthly is recommended) consider whether the mix of first aid items needs updating, especially if new procedures could create additional hazards.
- Over-the-counter (OTC) drug products should be in single-dose, tamper- evident packaging.
- OTC drugs should not include ingredients known to cause drowsiness.
- Even though ANSI doesn't require it, we think every kit needs a single use, disposable CPR barrier
Lastly, OSHA's 2006 Best Practices Guide "Fundamentals of a Workplace First-Aid Program" recommends an automated external defibrillator (AED) should be considered when selecting first aid supplies and equipment.
Is a medical employer required to provide first aid/CPR training?
OSHA’s first aid standard does not exempt medical practices from this requirement. In the regulation (29 CFR 1910.151(b)), OSHA requires that employers have medical personnel "readily available" for advice and consultation. If there is no nearby (within a 15 minute drive) infirmary, clinic, or hospital that is used for treating all injured employees, then one or more person on every shift in each facility must be adequately trained to render first aid.
Persons who render first aid must have a "valid" certificate in first aid training from the American Red Cross, or equivalent documented training.
Would an online first aid/CPR training that gives a certificate with no actual "hands-on" practice meet OSHA requirements?
In a nutshell, no. OSHA's "Best Practices Guide:
Fundamentals of a Workplace First-Aid Program
" specifies five items regarding acceptable teaching methods:
- Trainees should develop "hands-on" skills through the use of manikins and trainee partners during their training.
- Trainees should be exposed to acute injury and illness settings as well as the appropriate response to those settings through the use of visual aids, such as videotape and slides.
- Training should include a course workbook which discusses first aid principles and responses to settings that require interventions.
- Training duration should allow enough time for particular emphasis on situations likely encountered in particular workplaces.
- An emphasis on quick response to first aid situations should be incorporated throughout the program.
Since the first item OSHA mentions when discussing teaching methods is developing "hands-on" skills, an online only program wouldn’t meet with OSHA's muster.
About the authors:
Dr. Sheila Dunn, president and CEO of Quality America, Inc., holds a doctoral degree in clinical laboratory science. Sarah Alholm, an occupational safety professional, is the OSHA product manager at Quality America.
Read more about medical OSHA compliance:
Material Safety Data Sheets: An Overview