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OSHA 1910SubpartK

Medical and first aid requirements

Subpart K

11 Questions & Answers

Questions & Answers

Under 1910.151, are employers required to make medical personnel available for their workplace?

Yes. Employers must ensure that medical personnel are available to provide advice and consultation on occupational health matters when needed, as stated in 1910.151.

  • The standard requires availability of medical services or consultation; it does not prescribe a specific staffing model, so employers may use on-site medical staff, contract providers, or arrangements with nearby clinics depending on workplace size and hazards.
  • Employers should document how workers can access medical advice (on-call provider, occupational clinic, etc.) and make that information available to employees.

Under 1910.151(b), must an employer designate trained first-aid personnel if there is no infirmary, clinic, or hospital nearby?

Yes. If an infirmary, clinic, or hospital is not in near proximity to the workplace, the employer must adequately designate and train one or more persons to render first aid, as required by 1910.151.

  • The standard uses the phrase "adequately designated and trained," which means training should match the kinds of injuries likely at the workplace and provide enough personnel to respond for the number of employees and shift patterns.
  • Employers should maintain evidence of training (course content and dates) and ensure coverage for all shifts and remote or temporary worksites when appropriate.

Under 1910.151, what does OSHA require about first-aid supplies in the workplace?

OSHA requires that suitable first-aid supplies be readily available to employees, as stated in 1910.151.

  • The rule does not list specific items or quantities; "suitable" means the kit and supplies must be appropriate for the hazards and number of employees. Employers should assess workplace risks (e.g., chemicals, cutting tools, heat) and stock kits accordingly.
  • Employers commonly follow recognized consensus standards or medical advisors to choose kit contents, and should replace used or expired items promptly.

Under 1910.151, when must employers provide eye wash or drench shower facilities?

Employers must provide suitable facilities for quick drenching or flushing of the eyes and body within the work area for immediate emergency use where employees' eyes or bodies may be exposed to injurious corrosive materials, as required by 1910.151.

  • This requirement applies specifically when corrosive or similarly injurious materials are present that could contact eyes or skin.
  • "Suitable facilities" means equipment that allows immediate flushing; employers should evaluate hazards to determine the appropriate type (eyewash station, drench shower) and ensure unobstructed access.

Under 1910.151, how quickly must employees be able to reach an eyewash or drench shower?

The standard requires eyewash and drench shower facilities to be provided "within the work area for immediate emergency use," but it does not set a specific time or distance, as stated in 1910.151.

  • Because OSHA uses the term "immediate," employers should ensure unobstructed, easy access so flushing can begin without delay after exposure.
  • Employers commonly apply industry guidance (medical and consensus standards) to determine acceptable travel times or distances and to ensure facilities are ready for use at all times.

Under 1910.151, can an employer rely solely on local emergency medical services instead of training on-site first-aid personnel?

Not always. If an infirmary, clinic, or hospital is not in near proximity, the employer must designate and train on-site personnel to render first aid rather than relying solely on external emergency services, as required by 1910.151.

  • If nearby medical facilities are easily and quickly accessible ("near proximity"), an employer may rely on them for certain needs; however, employers should evaluate response times and worksite hazards to determine whether on-site trained personnel are necessary.
  • For remote worksites or situations with likely immediate injuries (chemical exposures, severe trauma), employers should plan for on-site first-aid capability.

Under 1910.151, does OSHA require employers to provide CPR or AED training?

No. Subpart K (1910.151) does not specifically require CPR or AED training; it requires employers to provide access to medical personnel, designate trained first-aid providers when appropriate, and have suitable first-aid supplies, as stated in 1910.151.

  • While not mandated by this specific standard, CPR and AED training are commonly recommended best practices—especially where delayed EMS response is likely or where medical emergencies (cardiac events) are a realistic hazard.
  • Employers should perform a hazard assessment and consult medical advisors to decide whether CPR/AED training and equipment are appropriate for their workplace.

Under 1910.151, are employers required to keep records of first-aid treatments provided at the workplace?

Subpart K (1910.151) does not itself require employers to keep records of first-aid treatments; it focuses on availability of medical services, trained personnel, and first-aid supplies, as stated in 1910.151.

  • Separate OSHA recordkeeping rules (29 CFR part 1904) address when injuries and illnesses must be recorded on OSHA logs. Minor first-aid treatments meeting the first-aid definition in 1904 may not be recordable, but more serious treatments are. Employers should consult the recordkeeping standard to determine what must be logged.

Under 1910.151, what should an employer do about first-aid for temporary or remote worksites?

The same basic requirements apply: if a temporary or remote worksite does not have an infirmary, clinic, or hospital in near proximity, the employer must designate and train persons to render first aid and provide suitable first-aid supplies on site, per 1910.151.

  • Employers must assess the specific hazards and the site's remoteness to determine the number of trained responders, supplies needed, and whether additional measures (e.g., rescue plans, communication systems) are required.
  • For remote worksites, employers often expand supplies and responder training because external emergency medical response times may be long.

Under 1910.151, can individual employees keep personal first-aid kits instead of the employer providing workplace kits?

Personal first-aid kits can supplement workplace provisions, but they do not replace the employer's duty to provide suitable first-aid supplies that are readily available to all employees, as required by 1910.151.

  • The employer remains responsible for ensuring that adequate, appropriate, and accessible supplies exist for the workforce as a whole.
  • If employees carry personal kits, the employer should still evaluate whether overall coverage meets workplace needs and should maintain communal or site kits where appropriate.

Under 1910.151, who determines what "adequately trained" means for workplace first-aid providers?

The employer is responsible for ensuring that designated first-aid providers are "adequately trained"—meaning training must be sufficient for the hazards and expected injuries in the workplace—per 1910.151.

  • Employers should consult medical personnel, safety professionals, or reputable training organizations to develop appropriate training content and frequency.
  • Training records and periodic retraining help demonstrate adequacy; employers should tailor training (e.g., chemical burns, heavy machinery trauma) to likely workplace incidents.