EMERGENCY RESPONSE TOOLS CORP.

OSHA reference: Appendix A to § 1910.151 -- First aid kits (Non-Mandatory)

First aid supplies are required to be readily available under paragraph § 1910.151(b). An example of the minimal contents of a generic first aid kit is described in American National Standard (ANSI) Z308.1-1978 "Minimum Requirements for Industrial Unit-Type First-aid Kits." The contents of the kit listed in the ANSI standard should be adequate for small worksites. When larger operations or multiple operations are being conducted at the same location, employers should determine the need for additional first aid kits at the worksite, additional types of first aid equipment and supplies and additional quantities and types of supplies and equipment in the first aid kits.

In a similar fashion, employers who have unique or changing first-aid needs in their workplace may need to enhance their first-aid kits. The employer can use the OSHA 200 log, OSHA 101's or other reports to identify these unique problems. Consultation from the local fire/rescue department, appropriate medical professional, or local emergency room may be helpful to employers in these circumstances. By assessing the specific needs of their workplace, employers can ensure that reasonably anticipated supplies are available. Employers should assess the specific needs of their worksite periodically and augment the first aid kit appropriately.

If it is reasonably anticipated that employees will be exposed to blood or other potentially infectious materials while using first aid supplies, employers are required to provide appropriate personal protective equipment (PPE) in compliance with the provisions of the Occupational Exposure to Blood borne Pathogens standard, § 1910.1030(d)(3) (56 FR 64175). This standard lists appropriate PPE for this type of exposure, such as gloves, gowns, face shields, masks, and eye protection.

[63 FR 33450, June 18, 1998]

First Aid 29 CFR 1910.151 and
Summary of Z308.1-1998

Document Number: 208
In 1998 the Medical Services and First Aid regulation, 29 CFR 1910-151, was revised. The revision states, "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." The revised regulation eliminated the statement, ". . . first aid supplies approved by the consulting physician shall be readily available." In addition to the regulation was Appendix A--a non-mandatory guideline. This appendix demonstrates an example of the minimal contents of generic first aid kits according to the American National Standards Institute (ANSI) Z308.1-1978, Minimum Requirements for Industrial Unit-Type First Aid Kits.* The contents listed in Z308.1-1978 should be adequate for small worksites. The employer is responsible for determining the need for additional first-aid kits, quantities and the types of supplies at the worksite for large/larger worksites.

*Note: The new non-mandatory Appendix A refers to ANSI Z308.1-1978 "Minimum Requirements for Industrial Unit-type First-aid Kits". Since Appendix A was added, ANSI has updated Z308.1-1978 the 1998 standard. OSHA is expected to revise Appendix A to reference the updated ANSI Z308.1-1998 after determining that it is as effective as the earlier standard.

Classification of First Aid Kits
Under the new ANSI standard, Z308.1-1998, kits are divided into three different categories or classifications. Kits must also meet the performance and testing requirements set by the standard.

Type I:
Intended for use in stationary, indoor applications where kit contents have minimal potential for damage. These kits are not intended to be portable and should have a means for mounting in a fixed position. Some applications for Type I first-aid kits are: general indoor use, office use or in a light manufacturing facility. First aid cabinets would fall into this classification.

Type II:
Intended for use in portable indoor applications. Kit contents should have minimal potential for damage. These kits should be equipped with carrying handle(s) and be subjected to a drop test (See ANSI Z 308.1-1998 for drop test information). Some applications for Type II first-aid kits are general indoor use, office or manufacturing environments.

Type III:
Intended for portable use in mobile industries and/or outdoor applications. Kits should be moisture resistant, equipped with a carrying handle, have the means for being mounted in a fixed position, and should also be corrosion resistant. Type III kits must meet specific performance requirements. (Please see Section 5.4.4 of ANSI Z308.1-1998 for testing requirements). Typical applications for Type III first aid kits would be the transportation industry or construction jobs.

Note: In addition to the above minimum contents, a kit should have optional items added, based upon specific workplace hazards. The selection of additional supplies should be made by consulting with a health care professional or a person competent in first aid who is knowledgeable of the hazards found in that specific workplace. The optional items shall meet specifications stated in Section 5.3 of ANSI Z308.1-1998.

Marking and Labeling
All first aid contents meeting the "Minimum Requirements of Basic Fill Contents" shall be marked with, at the least, ANSI Z308.1-1998 designation. Each complete first-aid kit meeting the requirements of ANSI Z308.1-1998 must have a label on the back or outside of the kit with the information listed in the box below. All labeling should be legible and permanent and should be written with, at the least, a 6-point font.

Minimum Requirements for Unit First Aid Kits
Section 6 of the ANSI Z308.1-1998 standard discusses minimum requirements of unit first aid kits. Unit first-aid kits are kit in which the contents are packaged in uniform-size boxes that contain one or more applications of first-aid supplies. In unitized First Aid Kits, packaging must meet the specific requirements for dimensions, physical stability, marking and labeling. Please see ANSI Z308.1-1998 for packaging requirements.

Packages must also be color coded, using the follow guidelines:
Blue: Antiseptic;
Yellow: Bandages;
Red: Burn Treatment;
Orange: Personal Protective Equipment;
Green: Miscellaneous.

Please Note: The information contained in this publication is intended for general information purposes only. This publication is not a substitute for review of the applicable government regulations and standards, and should not be construed as legal advice or opinion. Readers with specific questions should refer to the cited regulation or consult with an attorney.