OSHA First Aid Requirements: 29 CFR 1910.151

First Aid Training for Your Responders

The online course delivers the knowledge and a digital CPR card. Schedule hands-on practice on a mannequin as well; OSHA says online training alone does not meet 1910.151. See CPR, AED & First Aid Certification online for course details and the For Life option.

What 29 CFR 1910.151 Says

(a) The employer shall ensure the ready availability of medical personnel for advice and consultation on matters of plant health.

(b) In the absence of an infirmary, clinic, or hospital in near proximity to the workplace which is used for the treatment of all injured employees, a person or persons shall be adequately trained to render first aid. Adequate first aid supplies shall be readily available.

(c) Where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use.

Near Proximity Means 3–4 Minutes on Most Industrial Sites

The standard names no number of minutes. OSHA's interpretation letters of January 16 and March 23, 2007 read near proximity as emergency care within 3–4 minutes wherever falls, suffocation, electrocution or amputation are possible.

For offices, where serious injuries are less likely, OSHA has said a response of up to 15 minutes may be reasonable. A shop floor, warehouse or jobsite rarely qualifies for the longer window.

Some Standards Require CPR and First Aid by Name

OSHA recommends CPR as part of every first aid program. These standards make first aid or CPR training mandatory for covered work:

• 1910.146 — permit-required confined spaces (rescue and emergency services)
• 1910.266 — logging operations
• 1910.269 — electric power generation, transmission and distribution
• 1910.410 — qualifications of dive team
• 1926.950 — construction power transmission and distribution

In logging and electric power work, relying on outside responders is not an allowed alternative.

Online First Aid Training Needs Hands-On Practice

OSHA's August 2, 2012 letter to the Health and Safety Institute says online training alone would not meet these training standards. Bandaging and CPR are physical skills, and OSHA's best-practices guide calls for practice on mannequins and with a partner.

Use an online course to cover the material and issue the card, then have a qualified instructor run the skills session. AMC offers a Skills Webinar & Checklist with its CPR course.

First Aid Supplies and Eyewash

1910.151(b) requires adequate first aid supplies to be readily available, matched to the injuries your work can cause. Where corrosives are handled, 1910.151(c) requires a drench or flush station in the work area. If your crew includes an AED in the plan, see workplace AEDs.

OSHA First Aid Requirements FAQ

Does OSHA require first aid training?

Under 1910.151(b), yes, when no infirmary, clinic or hospital is in near proximity to the workplace. Construction has a similar rule at 1926.50(c).

What does near proximity mean?

OSHA has long read it as emergency care within 3–4 minutes where falls, suffocation, electrocution or amputation are possible. In offices, OSHA has said up to 15 minutes may be reasonable.

Is CPR training required by OSHA?

OSHA recommends CPR as part of a first aid program. Some standards require it, including 1910.146 permit-required confined spaces, 1910.266 logging and 1910.269 electric power.

Can first aid training be done online?

Not online alone. OSHA's 2012 interpretation letter says online-only training does not meet the first aid and CPR requirements of 1910.151, because the skills need hands-on practice.

What does 1910.151(c) require?

Where eyes or body may be exposed to injurious corrosive materials, the employer must provide suitable facilities for quick drenching or flushing within the work area.