OSHA’s general industry standard at 29 CFR 1910.151 sets out the first aid and eyewash requirements every covered employer has to meet: arrange for medical consultation on plant health, keep a trained first aid responder and adequate supplies on site when no clinic or hospital is close by, and install suitable drenching or flushing equipment wherever workers may be exposed to injurious corrosive materials.1eCFR. 29 CFR 1910.151 – Medical Services and First Aid The rule itself runs only three paragraphs, but the compliance work sits in the ANSI standards it points to and in a handful of OSHA interpretation letters. Missing pieces get expensive fast. A serious citation currently maxes out at $16,550, and willful or repeat violations reach $165,514.
Medical Consultation Under Paragraph (a)
Every general industry employer has to ensure “the ready availability of medical personnel for advice and consultation on matters of plant health.”1eCFR. 29 CFR 1910.151 – Medical Services and First Aid This is an advisory relationship, not an emergency one. Someone with clinical training reviews the health hazards specific to your operation — chemical exposures, ergonomic risks, noise levels — and helps shape policy around them.
Most employers meet the requirement by retaining a local physician or an occupational health group. The consultant doesn’t have to be on site. What matters is that medical judgment is informing your safety program instead of being left to people without clinical training: evaluating whether particular tasks create long-term health risks, recommending surveillance protocols, and advising on chemical or biological exposure limits.
When You Need a Trained First Aid Responder
Paragraph (b) turns on one question: is an infirmary, clinic, or hospital in “near proximity” to the workplace? OSHA measures that phrase in minutes rather than miles. Where serious injuries are foreseeable — severe bleeding, cardiac arrest, falls from height, electrocution, or amputation — emergency medical services must be able to reach the scene within three to four minutes, because permanent brain damage or death can occur when oxygen or blood flow is cut off beyond that window.2Occupational Safety and Health Administration. Clarification of “In Near Proximity” and OSHA’s Discretion in Enforcing First Aid Requirements in Particular Cases
If EMS cannot consistently arrive within that time, at least one employee on every shift must hold current first aid and CPR certification from a recognized training organization. OSHA doesn’t name a specific certifier. The American Red Cross, American Heart Association, and National Safety Council are all widely accepted. Coverage has to match your working hours; training the day shift doesn’t help the night crew.
How Often to Recertify
The general industry rule does not set a specific retraining interval for first aid or CPR.3Occupational Safety and Health Administration. Frequency of Refresher Training for First Aid and CPR OSHA’s best practices guide recommends annual retraining for CPR and AED skills because those techniques degrade quickly without practice. Certain operation-specific standards do impose explicit retraining schedules, so check whether any apply to your work: permit-required confined spaces (1910.146), logging (1910.266), and electric power generation (1910.269).
Most certifying organizations issue cards valid for two years, which creates a natural recertification cycle. Lapsed cards are one of the easier violations for an inspector to spot. They just ask to see them.
AEDs Are Not Required
Automated external defibrillators are not required first aid supplies under 1910.151. OSHA has confirmed that the standard does not mandate AEDs as part of the “adequate first aid supplies” referenced in paragraph (b).4Occupational Safety and Health Administration. AEDs Are Not Required First Aid Supplies Where cardiac arrest is a realistic risk and EMS response exceeds a few minutes, adding one is a sensible measure even though the text doesn’t demand it.
First Aid Supplies and Kit Contents
Paragraph (b) requires “adequate first aid supplies” to be “readily available,” but the regulation itself lists nothing.1eCFR. 29 CFR 1910.151 – Medical Services and First Aid OSHA’s non-mandatory Appendix A points employers to ANSI/ISEA Z308.1 as a benchmark for minimum kit contents.5Occupational Safety and Health Administration. 1910.151 App A – First Aid Kits (Non-Mandatory) “Non-mandatory” means OSHA won’t cite you solely for deviating from ANSI, but meeting that standard is the straightforward way to demonstrate compliance.
Class A and Class B Kits
ANSI/ISEA Z308.1-2021 divides kits into two classes:
- Class A covers the most common workplace injuries: cuts, abrasions, minor burns, and eye irritation. Contents include adhesive bandages, adhesive tape, antibiotic and antiseptic applications, a breathing barrier, burn dressings, a cold pack, eye coverings, exam gloves, eye/skin wash, roller bandages, scissors, sterile pads, trauma pads, and triangular bandages.
- Class B is designed for larger, more complex, or higher-risk environments. Class B kits contain everything in Class A in greater quantities and add two items not found in Class A: a splint and a tourniquet.
Appendix A notes that the ANSI minimums should be “adequate for small worksites.” Larger facilities or those with unusual hazards need to go beyond the baseline. A plant handling chemicals that cause burns, for example, needs additional burn dressings and larger volumes of eye wash solution regardless of which class it starts from. Kit contents should track the hazards your workplace assessment identifies.
Placement and Maintenance
A well-stocked kit locked in a supervisor’s office does not meet the “readily available” standard. Kits belong in areas workers can reach quickly and need to be marked with recognizable signage. Large facilities generally need multiple kits so nobody is far from supplies when an injury happens. Inspect kits on a schedule to replace expired items and restock anything used. An inspector who opens a kit and finds empty slots or expired medications has an easy citation.
Emergency Eyewash and Shower Requirements
Paragraph (c) requires “suitable facilities for quick drenching or flushing of the eyes and body” wherever workers’ eyes or skin may be exposed to injurious corrosive materials.1eCFR. 29 CFR 1910.151 – Medical Services and First Aid OSHA has clarified that corrosive materials are substances that cause visible tissue destruction or irreversible changes on contact, generally strong acids and strong bases. Sodium hydroxide and sulfuric acid are common examples.6Occupational Safety and Health Administration. Request to Provide List of Corrosive Materials
The trigger is not whether corrosives are in the building. It’s whether workers could be exposed. Sealed containers that will never be opened create no exposure risk. But if a pipe carrying a caustic solution has a sampling tap, or workers open drums of acid for mixing, the requirement applies at that work location.6Occupational Safety and Health Administration. Request to Provide List of Corrosive Materials
ANSI Z358.1 Performance Numbers
The regulation says “quick” and “immediate” but doesn’t quantify either. ANSI/ISEA Z358.1 fills in the specifics that most inspectors and safety professionals treat as the compliance benchmark:
- Travel distance: the station must be reachable within 10 seconds of the hazard, roughly 55 feet on a clear, level path.
- Flush duration and flow: eyewash units deliver at least 0.4 gallons per minute for 15 minutes; eye/face wash units, 3.0 gallons per minute for 15 minutes; emergency showers, 20 gallons per minute for 15 minutes.
- Water temperature: flushing fluid must be tepid, defined as 60°F to 100°F. Water that’s too cold discourages workers from flushing the full 15 minutes; water that’s too hot compounds tissue damage.
- Weekly activation: all plumbed units must be activated at least once a week to flush stagnant water from the lines and confirm the equipment works.
Accessibility is not negotiable. The path between the hazard and the station has to stay clear at all times. A worker who just took a chemical splash to the face cannot navigate around pallets or equipment. High-visibility signage and color markings help someone with impaired vision find the station.
Portable Bottles vs. Plumbed Stations
This is where employers get into trouble. A squeeze bottle of saline on a shelf does not satisfy paragraph (c) in most situations. OSHA’s enforcement directive states that portable or self-contained eyewash equipment may be used only when plumbed equipment is not economically feasible and the potential exposure is slight, such as an auto garage where battery contact is incidental. Where batteries are actively serviced, such as industrial truck batteries in a manufacturing or warehouse setting, OSHA requires proper plumbed equipment immediately adjacent to the work station regardless of what personal protective equipment workers use.7Occupational Safety and Health Administration. 29 CFR 1910.151(c), Medical Services and First Aid
Portable bottles also cannot deliver 15 minutes of continuous flushing at the flow rates ANSI Z358.1 requires. At best they supplement a plumbed station, giving a worker something to grab while moving toward the real fixture. They do not substitute for one.
Bloodborne Pathogen Duties That Come With Designating a Responder
Naming an employee your first aid responder pulls in obligations under OSHA’s bloodborne pathogen standard, 29 CFR 1910.1030, that many employers overlook. Anyone whose job duties include rendering first aid has “occupational exposure” to blood and other potentially infectious materials, which activates the full protections of that standard.8Occupational Safety and Health Administration. Training and Designation of First Aid Providers in General Industry
Even informal arrangements can trigger this. OSHA has said that an employee who routinely provides first aid with the employer’s knowledge counts as a de facto designated responder without any official title or written assignment.8Occupational Safety and Health Administration. Training and Designation of First Aid Providers in General Industry
Hepatitis B Vaccine
Employers must offer the Hepatitis B vaccine series to designated first aid providers at no cost, within 10 working days of their initial assignment to duties involving potential blood exposure. The employee can decline but has to sign a declination statement. If that employee later changes their mind, the vaccine still has to be made available.9Occupational Safety and Health Administration. 1910.1030 – Bloodborne Pathogens
Written Exposure Control Plan
Any employer with workers who have occupational exposure has to maintain a written Exposure Control Plan. The plan identifies which job classifications involve exposure, describes engineering controls and safe work practices, and lays out the procedure for evaluating an exposure incident. It must be reviewed and updated annually and be accessible to employees.9Occupational Safety and Health Administration. 1910.1030 – Bloodborne Pathogens For small employers whose only exposure comes from having a designated first aid responder, the plan does not need to be elaborate. It does need to exist in writing.
A Note on First Aid vs. Recordable Injuries
Complying with 1910.151 is separate from OSHA’s recordkeeping rules, but the two intersect. Under 29 CFR 1904.7, an injury treated with “first aid” as OSHA defines the term does not go on the OSHA 300 log. Once treatment crosses into “medical treatment beyond first aid,” the case becomes recordable. The professional status of the person providing care does not change the classification. A physician who cleans and bandages a wound has performed first aid; a coworker who applies a rigid splint has provided medical treatment. The treatment itself controls, not who delivers it.10Occupational Safety and Health Administration. 1904.7 – General Recording Criteria
Penalties
OSHA adjusts penalty amounts annually for inflation. As of 2026 the maximum penalty for a serious violation, which covers most 1910.151 deficiencies including missing first aid supplies, no trained responder, or a non-functional eyewash station, is $16,550 per violation. Willful or repeat violations reach $165,514 per violation. Failure to correct a cited condition can add $16,550 for each day past the abatement deadline.
Each distinct deficiency can generate a separate citation. A facility that lacks a trained first aid responder, has an expired first aid kit, and has a blocked eyewash station can face three serious citations in one inspection. Add workers’ compensation exposure, personal injury liability, and the public nature of OSHA citations, and the basics of 1910.151 are one of the cheaper investments in a safety program.