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OSHA 1910.151

Medical services and first aid

Subpart K

20 Questions & Answers
10 Interpretations

Questions & Answers

Under 1910.151(a), what does "ready availability of medical personnel" require employers to provide for plant health advice and consultation?

Under 1910.151(a) the employer must ensure employees have ready access to medical personnel for advice and consultation on matters of plant health.

  • "Ready availability" means the employer must make arrangements so that qualified medical professionals (for example, a physician, nurse, or other licensed provider) can be contacted and consulted promptly when health questions or concerns about workplace exposures arise.
  • This can be accomplished by on-site staff, an on-call arrangement, or an outside clinic/provider as long as timely consultation is assured for the workplace hazards and work schedules.

Cited authority: 1910.151(a).

Under 1910.151(b), when does an employer need a trained first aider on site instead of relying on a nearby infirmary or hospital?

Under 1910.151(b) the employer must provide a person or persons adequately trained to render first aid when there is no infirmary, clinic, or hospital in near proximity to the workplace that is used for treating all injured employees.

  • If a nearby medical facility is actually used for treating employees and can accept patients promptly, the employer may not need an on-site first aider.
  • If that facility is not available for all shifts or would not provide timely treatment for the workplace hazards, the employer must ensure trained first aid personnel and adequate first aid supplies are readily available.

Cited authority: 1910.151(b).

Under 1910.151(b), how should an employer decide whether an infirmary/clinic/hospital is in "near proximity" and therefore can replace on-site first-aid-trained personnel?

Under 1910.151(b) the employer must evaluate whether a nearby infirmary, clinic, or hospital is actually available and used for treating all injured employees; if not, trained first-aid personnel are required.

  • Consider travel time, emergency vehicle access, time of day/shift coverage, and whether the facility will accept and treat work injuries promptly.
  • Also consider the nature and severity of workplace hazards—high-risk workplaces need faster access to care.
  • If reliance on an external facility would delay treatment or is uncertain for any shift, the employer should provide trained first aiders on site.

Cited authority: 1910.151(b).

Under 1910.151(b), what does "adequately trained to render first aid" mean for the person or persons the employer must provide?

Under 1910.151(b) the employer must ensure the designated person(s) have adequate training to render first aid appropriate to the workplace hazards.

  • Adequate training means the person can recognize and provide initial, potentially life‑saving care (for example, control bleeding, treat for shock, manage airway emergencies) and knows how to summon emergency medical services.
  • Employers commonly use accredited first-aid/CPR courses (Red Cross, OSHA-authorized providers, or equivalent) and should tailor training to the specific hazards present.
  • Training must be refreshed as needed to maintain competence and account for any changes in workplace hazards or staffing.

Cited authority: 1910.151(b).

Under 1910.151(b), what are the expectations for "adequate first aid supplies" in the workplace?

Under 1910.151(b) the employer must make adequate first aid supplies readily available.

  • "Adequate" means the supplies should match the nature and scale of workplace hazards (e.g., burn dressings where thermal or chemical burns are a risk; eye irrigation for splash hazards).
  • Supplies should be organized, maintained, and easily accessible during all shifts; employers should replace used or expired items promptly.
  • Employers should document where supplies are kept and ensure employees and trained first aiders know how to access them.

Cited authority: 1910.151(b).

Under 1910.151(c), when must employers provide eyewash and body-drenching facilities?

Under 1910.151(c) the employer must provide suitable facilities for quick drenching or flushing of the eyes and body where the eyes or body of any person may be exposed to injurious corrosive materials.

  • The requirement applies whenever corrosive materials are present in a way that could expose workers (for example, splashes, spills, or spray operations).
  • Facilities must be located within the work area so they are available for immediate emergency use.

Cited authority: 1910.151(c).

Under 1910.151(c), what practical features make an eyewash or drench facility "suitable" for emergency use?

Under 1910.151(c) a "suitable" eyewash or drench facility is one that provides immediate, effective flushing for the type of corrosive hazard present.

  • Practical features include: immediate activation without tools, hands‑free operation when possible, adequate flow to flush eyes/body, location within the work area to permit prompt use, and clear access (no obstructions).
  • Employers should match the facility type (eyewash station, combination eye/face wash, emergency shower) to the exposure risks and ensure regular inspection and maintenance so the device is ready when needed.

Cited authority: 1910.151(c).

Under 1910.151(c), how close must an eyewash or drench facility be to workers who handle corrosive materials?

Under 1910.151(c) the eyewash or drench facility must be provided "within the work area for immediate emergency use," meaning it must be close enough that an exposed worker can begin flushing without delay.

  • Employers should place facilities so response to an exposure is immediate; distance or travel time must not cause a harmful delay.
  • Factors to consider include the severity of the corrosive, layout of the work area, and whether PPE or other controls might slow access; if in doubt, place the facility closer.

Cited authority: 1910.151(c).

Under 1910.151(b), can an employer rely solely on calling 911 or EMS instead of providing on-site first aid training and supplies?

Under 1910.151(b) an employer may rely on external medical facilities if a nearby infirmary/clinic/hospital is actually used for treating all injured employees and can do so promptly; otherwise the employer must provide trained first aiders and supplies on site.

  • If EMS response or hospital access would cause delays that could worsen common workplace injuries, on-site trained first aid personnel and supplies are required.
  • The employer must assess response times, facility availability for work injuries, and the severity of workplace hazards before deciding to rely solely on external emergency services.

Cited authority: 1910.151(b).

Under 1910.151(a), does "medical personnel" have to be a physician, or can nurses or other licensed professionals meet the requirement for consultation and advice?

Under 1910.151(a) the standard does not require a specific professional title; employers must ensure ready availability of medical personnel qualified to provide advice and consultation on plant health.

  • A physician, registered nurse, physician assistant, occupational health nurse, or other health professional may fulfill the requirement if they are qualified to advise on the workplace health issues at hand.
  • The key is that the provider can give timely, competent medical advice tailored to the workplace hazards.

Cited authority: 1910.151(a).

Under 1910.151, are employers required to provide medical examinations or full medical services on site, or can they limit their obligation to advice and first aid arrangements?

Under 1910.151(a) and 1910.151(b), employers are required to ensure ready availability of medical personnel for advice and consultation and to provide trained first aiders and supplies when no nearby facility treats employees; the standard does not mandate a full on-site medical clinic in every workplace.

  • Employers must assess hazards and available local medical resources; where on-site services are necessary (because of distance, severity of hazards, or specific workplace needs), the employer must provide them.
  • The obligation is performance-based: ensure timely medical advice and initial care, not necessarily an on-site hospital.

Cited authority: 1910.151(a) and 1910.151(b).

Under 1910.151(c), do employers need to maintain and test eyewash and drenching equipment, and why?

Under 1910.151(c) employers must provide suitable facilities for quick drenching or flushing where corrosive exposures are possible; maintaining and testing that equipment is necessary to ensure it will work in an emergency.

  • Regular inspection, flushing, and maintenance help ensure adequate flow and cleanliness so the equipment is ready for immediate use.
  • Employers should keep records of inspections and repairs and train employees on the location and use of the equipment to avoid delays during an exposure.

Cited authority: 1910.151(c).

Under 1910.151(b), how many employees should be trained in first aid to meet the "adequately trained" requirement?

Under 1910.151(b) the employer must provide an adequate number of trained first aiders based on workplace size, shift patterns, and hazards; the standard does not prescribe a numeric minimum.

  • Employers should ensure at least one trained person is available on every shift and that coverage accounts for breaks, vacations, and multiple work areas.
  • High‑hazard or large sites may need multiple trained responders and a documented plan for ensuring coverage at all times.

Cited authority: 1910.151(b).

Under 1910.151(b), does the standard itself require employers to keep written records of first aid training or first aid incidents?

No, 1910.151(b) requires trained personnel and adequate supplies but does not itself require written training records or incident logs.

  • Employers often keep training documentation and incident records as good practice and to demonstrate compliance, but any specific recordkeeping requirements would come from other OSHA standards or employer policies.

Cited authority: 1910.151(b).

Under 1910.151(c), do employers handling corrosive gases or chemicals that can create oxygen-deficient atmospheres need to consider respiratory hazards before first aid responders enter the area?

Yes. While 1910.151(c) requires drenching/eyewash facilities for corrosives, employers must also consider atmospheric hazards (including oxygen‑deficient atmospheres) and protect responders accordingly.

  • For civilian employees, OSHA's respiratory protection rules apply to oxygen-deficient atmospheres; such atmospheres are considered immediately dangerous to life and health (IDLH) and require appropriate respiratory protection and rescue planning as discussed in the OSHA interpretation on oxygen‑deficient atmospheres: https://www.osha.gov/laws-regs/standardinterpretations/2024-07-16.
  • Employers should not send unprotected first-aid responders into an oxygen-deficient atmosphere; ensure responders have appropriate PPE and training, or wait for qualified rescue personnel.

Cited authority: 1910.151(c) and OSHA interpretation on oxygen‑deficient atmospheres (https://www.osha.gov/laws-regs/standardinterpretations/2024-07-16).

Under 1910.151, can telemedicine or remote consultation satisfy the "ready availability of medical personnel" requirement in 1910.151(a)?

Under 1910.151(a) remote medical consultation (for example, telemedicine) can satisfy the requirement if it provides timely, competent advice and consultation for workplace health issues.

  • Telemedicine is acceptable when it gives employees or on-site responders immediate access to qualified medical personnel for assessment and direction that addresses the workplace hazards and timing needs.
  • Employers must ensure the remote service is reliable, available when needed, and that on-site staff know how to contact and follow recommendations from the remote provider.

Cited authority: 1910.151(a).

Under 1910.151(b), are employers required to provide training in CPR and AED use as part of first aid training?

Under 1910.151(b) the employer must ensure trained persons can render adequate first aid; the standard does not list specific topics, so CPR and AED training are required only if they are needed given the workplace hazards and response times.

  • Where cardiac arrest is a foreseeable risk or EMS response would be delayed, CPR and AED training are good practice and often necessary to provide adequate on-site care.
  • Employers should assess workplace risks and ensure training content (CPR/AED inclusion) matches those risks.

Cited authority: 1910.151(b).

Under 1910.151(c), do employers who store corrosive materials in warehouses need to provide eyewash and drench facilities in the storage area?

Under 1910.151(c) employers must provide quick drenching or flushing facilities where eyes or body may be exposed to injurious corrosive materials, which includes storage areas if exposures (for example, spills or leaks) could harm workers.

  • If workers handle, transfer, inspect, or could be exposed to leaks or spills in the storage area, place suitable eyewash/flush facilities in that work area for immediate use.
  • If storage is completely sealed and workers never enter the immediate storage area, the need depends on whether employees could be exposed during normal operations or emergencies.

Cited authority: 1910.151(c).

Under 1910.151, may employers rely on employees with only basic first aid kits (no training) at remote job sites?

Under 1910.151(b) the employer must provide a person or persons adequately trained to render first aid where there is no nearby infirmary/clinic/hospital used for treating all injured employees, so simply providing kits without trained personnel will not meet the requirement when no nearby medical facility is available.

  • In remote work where medical facilities are not in near proximity or response would be delayed, employers should ensure both adequate first aid supplies and trained personnel are available on site or on every shift.

Cited authority: 1910.151(b).

Under 1910.151, does the presence of highly hazardous chemicals on site (for example, large quantities of flammable gases) change the employer's first-aid and medical consultation obligations?

Yes. Under 1910.151(a)–(c) employers must ensure medical advice/consultation and first‑aid arrangements that match workplace hazards, and the presence of highly hazardous chemicals may require enhanced medical planning and immediate-response capabilities.

  • For example, storage or handling of large quantities of hazardous chemicals (discussed in OSHA's PSM interpretation about flammable gases: https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06) increases the likelihood of serious incidents and supports the need for on-site trained medical personnel, specialized first-aid supplies, emergency decontamination, and coordination with emergency responders.
  • Employers should assess chemical hazards and ensure medical coverage, decontamination facilities, and responder PPE/training are appropriate for the risks.

Cited authority: 1910.151 and OSHA interpretation on PSM and flammable gas aggregation (https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06).