Workplace First Aid and AED Requirements Under OSHA

OSHA first aid requirements come primarily from 29 CFR 1910.151, which obligates most employers to keep adequate first aid supplies readily available, ensure at least one trained responder is on site when medical help isn’t nearby, and provide eyewash or drench facilities wherever employees work with corrosive chemicals. Related rules under 29 CFR Part 1904 govern how injuries get recorded and reported, and 29 CFR 1910.1030 controls what happens when a first aid responder is exposed to blood. The rule text is short. The obligations underneath it are not.

First Aid Kits and Supplies

29 CFR 1910.151(b) requires adequate first aid supplies to be readily available whenever employees are on site.1eCFR. 29 CFR 1910.151 – Medical Services and First Aid The regulation does not itemize contents. OSHA instead points to the ANSI/ISEA Z308.1-2021 voluntary consensus standard, which defines two kit classes.

A Class A kit covers common workplace injuries such as cuts, abrasions, minor burns, and eye irritation. It includes adhesive bandages, antiseptic, a breathing barrier, a burn dressing, a cold pack, exam gloves, and a triangular bandage, among other items. A Class B kit contains those same items in greater quantities, plus a splint and a tourniquet, and is intended for higher-risk environments where severe bleeding, crushing injuries, or fractures are more likely.

Picking the right class means looking honestly at your worksite. Review injury logs, note the equipment employees operate, and account for exposures like chemicals or heat. The regulation’s non-mandatory Appendix A encourages periodic assessment and adding supplies beyond the minimum where conditions warrant it.1eCFR. 29 CFR 1910.151 – Medical Services and First Aid

Inspect kits at least monthly and immediately after any incident where supplies were used. Replace expired items, especially ointments and cold packs. Place kits where employees can reach them quickly, without locked doors or stairs in the way. Multiple buildings or floors each need their own accessible kit. Construction sites work under a tighter version: 29 CFR 1926.50 requires kits to be checked before being sent to each job and at least weekly on site, with used items replaced promptly.2eCFR. 29 CFR 1926.50 – Medical Services and First Aid

Eyewash and Drench Stations

When employees work with corrosive chemicals, 29 CFR 1910.151(c) requires facilities for quickly drenching or flushing the eyes and body within the immediate work area.3Occupational Safety and Health Administration. Medical Services and First Aid The same requirement applies on construction sites under 29 CFR 1926.50(g).2eCFR. 29 CFR 1926.50 – Medical Services and First Aid

OSHA does not define “within the immediate work area” in feet or seconds. The widely referenced ANSI/ISEA Z358.1 standard fills that gap: eyewash units should be reachable within 10 seconds of travel, on the same level as the hazard, along an unobstructed path. Units must deliver at least 0.4 gallons per minute for a full 15 minutes of flushing. For strong acids and caustics, ANSI recommends placing the station adjacent to the hazard.

Plumbed stations suit permanent facilities because they provide unlimited water. Portable self-contained units work at remote or temporary sites but need regular maintenance so the flushing fluid does not expire or become contaminated. Tepid water, generally 60°F to 100°F, is recommended so workers can tolerate a full 15-minute flush.

Trained First Aid Responders

If no infirmary, clinic, or hospital is close enough to treat injured employees quickly, at least one person on site must be adequately trained to render first aid.1eCFR. 29 CFR 1910.151 – Medical Services and First Aid OSHA interprets “near proximity” as emergency care reaching the victim within three to four minutes of a life-threatening incident like severe bleeding or cardiac arrest.4Occupational Safety and Health Administration. Clarification of “In Near Proximity” and OSHA’s Discretion That is an aggressive timeline, and most workplaces that are not literally next door to a hospital will need their own trained responders.

Construction is more explicit. Under 29 CFR 1926.50(c), a person with a valid first aid certificate from the American Red Cross or equivalent training must be available at the worksite when no physician or medical facility is reasonably accessible.2eCFR. 29 CFR 1926.50 – Medical Services and First Aid The construction standard also requires transportation arrangements or a communication system for contacting ambulance services before work begins.

If you run multiple shifts, you need a trained responder on every shift. Training typically comes from the American Red Cross, the American Heart Association, or the National Safety Council and covers CPR, wound management, and AED use. Expect roughly $60 to $150 per employee for certification courses.

Recertification Frequency

OSHA does not set a specific recertification interval, even under standards that explicitly require first aid capability such as the permit-required confined spaces standard (1910.146) and the logging operations standard (1910.266).5Occupational Safety and Health Administration. Frequency of Refresher Training for First Aid and CPR OSHA’s own best practices guide recommends CPR and AED retraining at least annually, and most certifying organizations issue cards that expire after two years. Keep current certificates on file. An inspector will ask for them.

AEDs and Federal Liability Protection

No OSHA regulation specifically requires employers to install AEDs. The General Duty Clause in Section 5(a)(1) of the OSH Act still requires every employer to keep the workplace free from recognized hazards likely to cause death or serious physical harm.6Occupational Safety and Health Administration. OSH Act of 1970 Sudden cardiac arrest kills roughly 350,000 Americans each year outside hospitals, and survival rates drop by about 10% for every minute without defibrillation. In workplaces with high-voltage equipment, extreme physical exertion, or large employee populations, cardiac arrest starts to look like a recognized hazard.

New AEDs from FDA-approved manufacturers currently run about $1,500 to $3,000, plus a mounted cabinet, signage, replacement electrode pads every two to five years, and periodic battery replacements.

Employers who worry about lawsuits should read the Cardiac Arrest Survival Act (42 U.S.C. § 238q). A person who uses an AED on someone in a perceived medical emergency is immune from civil liability for any harm resulting from the attempt.7GovInfo. 42 U.S. Code 238q – Liability Regarding Emergency Use of Automated External Defibrillators The employer that acquired the device is also protected, provided it notified local emergency responders of the device’s location, maintained and tested the device properly, and trained the employee who used it. That immunity disappears if the harm resulted from willful misconduct, gross negligence, or reckless indifference to the victim’s safety, and it does not cover licensed healthcare professionals acting within the scope of their employment. Most states have their own Good Samaritan laws that add another layer of protection, with the specifics varying by state.

Bloodborne Pathogen Exposure After First Aid

When first aid involves contact with blood or other potentially infectious materials, 29 CFR 1910.1030 applies. Employers whose workers face occupational exposure to bloodborne pathogens must develop a written exposure control plan, update it at least annually, and make it available to employees.8Occupational Safety and Health Administration. Bloodborne Pathogens The rule covers obvious healthcare settings and any workplace where designated first aid responders might encounter blood.

If an employee is exposed through a needlestick, a splash to the eyes, or contact with an open wound, the employer must provide a confidential medical evaluation and follow-up at no cost. Required steps include:

  • Documenting how the exposure happened and the surrounding circumstances.
  • Identifying the source individual if feasible and testing their blood for hepatitis B and HIV with their consent.
  • Collecting blood from the exposed employee for HBV and HIV testing. If the employee consents to a blood draw but not HIV testing, the sample must be preserved for at least 90 days.
  • Providing post-exposure prophylaxis when medically indicated, plus counseling and evaluation of any reported illnesses.

The employer must give the treating healthcare professional a copy of the regulation, a description of the employee’s duties, the exposure circumstances, the source individual’s test results if available, and the employee’s relevant medical records including vaccination status. Within 15 days of the evaluation, the employer must provide the employee with a copy of the healthcare professional’s written opinion.8Occupational Safety and Health Administration. Bloodborne Pathogens

Recording and Reporting Injuries

The line between “first aid” and “medical treatment” under OSHA’s rules controls whether an injury ends up on your official logs. Under 29 CFR 1904.7, if the treatment given falls on OSHA’s first aid list, the injury generally is not recordable. If it goes beyond that list, it is.9Occupational Safety and Health Administration. 1904.7 – General Recording Criteria

OSHA classifies these as first aid: non-prescription medications at non-prescription strength, tetanus shots, cleaning or flushing surface wounds, bandages and butterfly closures (but not sutures or staples), hot and cold therapy, non-rigid supports like elastic wraps, temporary splints used only for transport, drilling a nail to relieve pressure, eye patches, removing foreign bodies from the eye by irrigation or cotton swab, removing splinters with tweezers, finger guards, massage, and drinking fluids for heat stress. Prescription medications, sutures, rigid immobilization devices, and physical therapy are medical treatment and trigger a recordable entry.

The 300 Log, 301 Report, and 300A Summary

Employers subject to OSHA recordkeeping must maintain three linked forms under 29 CFR Part 1904. The OSHA 300 Log is a running list of every recordable injury and illness for the calendar year. For each entry, complete an OSHA 301 Incident Report with details on what happened and what treatment was provided. At year end, compile the log into an OSHA 300A Summary and post it in a conspicuous location from February 1 through April 30 of the following year, even if you had zero recordable injuries.10eCFR. 29 CFR Part 1904 – Recording and Reporting Occupational Injuries and Illnesses Certain employers must also submit their data electronically through OSHA’s Injury Tracking Application.

Small Employer Partial Exemption

If your company had 10 or fewer employees at all times during the previous calendar year, you are partially exempt from these recordkeeping requirements and do not need to maintain the 300 Log, 301 Reports, or the 300A Summary unless OSHA or the Bureau of Labor Statistics tells you in writing to do so.11Occupational Safety and Health Administration. 1904.1 – Partial Exemption for Employers With 10 or Fewer Employees Even the smallest employer must still report fatalities and severe injuries on the timelines below.

Severe Injury Reporting Deadlines

Regardless of company size, certain incidents require direct notification to OSHA on a tight timeline:

  • Fatality: report within 8 hours of learning about the death.
  • Inpatient hospitalization: report within 24 hours.
  • Amputation: report within 24 hours.
  • Loss of an eye: report within 24 hours.

The clock starts when the employer or any of the employer’s agents learns about the incident, not when it occurs.12Occupational Safety and Health Administration. 29 CFR 1904.39 – Reporting Fatalities, Hospitalizations, Amputations, and Losses of an Eye Reports go by phone to the nearest OSHA area office or through OSHA’s online reporting portal.

Penalties

OSHA adjusts its maximum penalties annually for inflation. As of January 15, 2025:13Occupational Safety and Health Administration. OSHA Penalties

  • Serious violation: up to $16,550 per violation.
  • Other-than-serious violation: up to $16,550 per violation.
  • Posting requirement violation: up to $16,550 per violation.
  • Failure to abate: up to $16,550 per day beyond the abatement deadline.
  • Willful or repeated violation: up to $165,514 per violation.

A missing first aid kit or an expired eyewash station can draw a serious or other-than-serious citation. Penalties escalate when OSHA finds a pattern: an employer previously cited for inadequate supplies who has not fixed the problem can face a willful or repeated classification pushing a single violation past $165,000. Failure-to-abate penalties compound daily. Maximums apply per violation, so a single inspection can produce multiple citations — missing kits in three areas, no trained responder, and unmaintained eyewash stations could easily generate five separate charges.