Trying to decipher the meaning of the many OSHA (Occupational Safety & Health Administration) codes and standards can be a daunting experience. This article will discuss the following OSHA standard 29 CFR paragraph 1910.151 of OSHA’s General Industry standard on medical services and first aid.
The employer shall ensure the ready availability of medical personnel for advice and consultation on matters of plant health.
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.
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.
I have encountered many questions concerning this standard. Let’s take a look at part (a). First off, allow me to explain the meaning of “plant health”. Plant health simply means the overall safety and health conditions of the employees of a given work place or “plant”. If this section is read as an individual rule, it appears that all employers must have someone on staff available to render first aid. This is not the case. In order to fully understand this section, it really must be combined with section (b). The primary requirement these combined sections are trying to convey is that a trained first aid provider must be available on the worksite when emergency services are not within a reasonable proximity. So what exactly is a reasonable proximity? The answer to this is a bit more difficult. An OSHA response to this question in a letter of interpretation dated January 16, 2007 to Mr. Charles F. Brogan says this:
“OSHA has long interpreted the term ‘near proximity’ to mean that emergency care must be available within no more than 3-4 minutes from the workplace. Medical literature establishes that, for serious injuries such as those involving stopped breathing, cardiac arrest, or uncontrolled bleeding, first aid treatment must be provided within the first few minutes to avoid permanent medical impairment or death. Accordingly, in workplaces where serious accidents such as those involving falls, suffocation, electrocution, or amputation are possible, emergency medical services must be available within 3-4 minutes, if there is no employee on the site who is trained to render first aid.”
However, according to my research OSHA may exercise some discretion dependent on the particular type of business. In workplaces where the likelihood of a serious work-related injury is minimal such as an office, a response time of up to 15 minutes may be reasonable.
Section (b) also states that adequate first aid supplies shall be readily available. When first read, this statement seems simple enough. Until, that is, you try to discover what OSHA deems adequate first aid supplies. This is where things can get really confusing! OSHA often refers employers to ANSI (American National Standards Institute) Z308.1 which provides detailed information regarding the requirements for first aid kits. Although OSHA does recommend the ANSI standard, it has not been adopted as a part of OSHA standards. That said, the ANSI Z308.1 is definitely an advisable minimum requirement. The complete standard must be purchased. It is not available for free and may not be copied. For the most part, what you need to know is that any first aid kit purchased from any reliable source will conform to ANSI Z308.1. Depending on the size of the kit and the work environment, they usually contain much more than the requirements. Following are some basic guidelines for first aid kits:
- Once items are used or the expiration dates have expired they will need to be replaced.
- Over the Counter Medications are not required and in some instances not recommended.
- All items that are provided must be in individually sealed packages or in a spray type container that can not become contaminated with normal use.
- Any items that are not packaged for individual use must be disposed of once opened.
Your first aid supplier should advise you on what is needed for your company based on the type of possible work related injuries and the number of employees. Beware, however, that some of these companies will try to sell you much more than what you need. I have even seen one that offers a “chill pill” which is actually a piece of candy.
When questions arise concerning section (c), OSHA refers employers to another ANSI standard (Z358.1-2004) but again has not adopted that standard. Basically, a station must provide enough solution to entirely flush the affected area preferably for a full fifteen minutes. While it may be recommended to provide smaller bottles of solution that are close at hand, the larger station mentioned above must be provided wherever corrosive materials are present.
Please note that the above are my interpretations of the federal OSHA standard. Several states including California and Arizona operate their own OSHA approved occupational safety and health organizations. These states may adopt and enforce their own standards which may differ from the federal standards.
Source by Betty Heim