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OSHA 1915.87

Medical services and first aid

Subpart F

22 Questions & Answers
10 Interpretations

Questions & Answers

Under 1915.87(a), what does 'readily accessible' mean for emergency medical services and first aid on a shipyard worksite?

Yes — emergency medical services and first aid must be available so workers can get care quickly without unreasonable delay. Under 1915.87(a) the employer must ensure emergency medical services and first aid are "readily accessible," which means supplies, trained personnel, or arrangements with outside providers are located and organized so they can be used promptly when an injury or illness occurs.

  • Use the employer-focused factors in 1915.87(c)(3) — site size/location, headcount, hazards, distance to hospitals — to decide how to meet accessibility.
  • Document procedures so responders know where supplies and trained providers are located and how to summon outside help.

(See 1915.87(a) and the factors in 1915.87(c)(3).)

Under 1915.87(b), who qualifies as the "healthcare professionals" the employer must make available for advice and consultation?

The employer must ensure that qualified healthcare professionals are available to give advice and consultation on workplace health matters. 1915.87(b) requires access to healthcare professionals but does not prescribe specific job titles; employers can use physicians, nurse practitioners, occupational health nurses, or other licensed clinicians who can advise on workplace health issues.

  • The professional should have the training and licensure to address the workplace health concern in question.
  • Keep a contact list and written plan so employees and supervisors know how to reach the healthcare professional promptly.

(See 1915.87(b).)

Under 1915.87(c)(1), when can an employer rely on outside emergency medical services instead of training first aid providers on-site?

You may rely on outside emergency medical services if they can reach your worksite within five minutes of a report of injury or illness and you can show that timely assistance will be available. 1915.87(c)(1)(ii) allows reliance on outside first aid providers (EMS) when they can reach the site within five minutes and the employer "must take appropriate steps to ascertain that emergency medical assistance will be readily available promptly."

  • Document contacts and response-time confirmation from local EMS (phone records, memoranda, or written agreements).
  • If you cannot reliably demonstrate the 5-minute EMS response, you must have an adequate number of trained on-site first aid providers per 1915.87(c)(1).

(See 1915.87(c)(1)(ii).)

Under 1915.87(c)(2), how quickly must a first aid provider be able to reach an employee with a serious injury?

A trained first aid provider must be able to reach an employee within five minutes of a report of a serious injury or illness. 1915.87(c)(2) specifically requires a first aid provider to reach an injured or ill employee within five (5) minutes for serious events like cardiac arrest, severe bleeding, suffocation, electrocution, or amputation.

  • Plan provider locations and communications so that this five-minute reach time is met during every shift.
  • Consider radios, spotters, or strategically positioned providers where worksites are large or spread out.

(See 1915.87(c)(2).)

Under 1915.87(c)(3), what factors must an employer use to determine how many employees need first aid training and where they should be located?

The employer must use the worksite size and location, number of employees, hazards present, and distance from hospitals/clinics/rescue squads to determine the number and placement of trained first aid providers. Those four factors are listed in 1915.87(c)(3).

  • Size/location: Large or spread-out worksites require more providers or staging areas.
  • Number of employees: More workers increase the probability of incidents and need for coverage.
  • Hazards present: High-risk tasks (e.g., hot work, heavy machinery) justify closer coverage and specialized training.
  • Distance to medical facilities: Remote sites need more on-site capability because external help may take longer.

(See 1915.87(c)(3).)

Under 1915.87(c)(4) and (c)(5), what training and certification must first aid providers maintain?

First aid providers must be trained to render first aid including CPR, and they must maintain current first aid and CPR certifications from recognized organizations. 1915.87(c)(4) requires training including CPR, and 1915.87(c)(5) requires maintaining current certifications such as from the Red Cross, American Heart Association, or an equivalent organization.

  • Keep copies of certification cards and training records on file and available for inspection.
  • Use refresher training and recertification schedules to ensure credentials do not lapse.

(See 1915.87(c)(4) and 1915.87(c)(5).)

Under 1915.87(d)(1)–(d)(6), what are the employer's responsibilities for first aid supplies and inspections?

The employer must provide and maintain adequate first aid supplies that are readily accessible, properly located and sized for the site hazards, stored in weatherproof containers, kept dry/sterile/serviceable, replenished as needed, and inspected at sufficient intervals. Those duties are set out in 1915.87(d)(1)–(d)(6).

  • Placement and quantity must reflect the site's size, workforce, hazards, and distance to medical facilities (1915.87(d)(2)).
  • Use weatherproof containers (1915.87(d)(3)) and check items for sterility and serviceability (1915.87(d)(4)).
  • Replenish supplies promptly (1915.87(d)(5)) and inspect at suitable intervals to ensure readiness (1915.87(d)(6)).

(See 1915.87(d)).

Under 1915.87(e), when are quick-drenching and flushing facilities required and where should they be located?

Quick-drenching and flushing facilities are required whenever there is potential for splashes that could cause an acute or serious injury, and they must be located for immediate emergency use close to the operation. 1915.87(e) mandates these facilities where splashes from hazardous substances may cause acute harm and requires them to be close to the work area for immediate use.

  • Identify operations with splash hazards (acids, caustics, solvents) and install eyewash/showers within the “immediate” vicinity so a worker can reach them without delay.
  • Ensure the facilities provide suitable flow and are maintained in working order.

(See 1915.87(e).)

Under 1915.87(f), when is an employer exempt from providing basket stretchers on a vessel or vessel section?

An employer is not required to provide basket stretchers if emergency response services already have basket stretchers or equivalents that meet the standard's requirements and are available. The rule states the employer isn't required to provide them where emergency response services have basket stretchers or equivalents that meet paragraph (f) requirements. See 1915.87(f).

  • If relying on outside services, confirm those services have compliant stretchers and that they can reach affected areas reliably.
  • Keep documentation of any agreement or verification showing the outside response meets 1915.87(f)(2)–(4).

(See 1915.87(f).)

Under 1915.87(f)(2), what equipment and features must a basket stretcher or equivalent have?

Each basket stretcher or equivalent must have permanent lifting bridles for attaching to hoisting gear rated at least 5,000 pounds, restraints to hold the injured person securely during movement, and a blanket or other suitable covering. Those requirements are listed in 1915.87(f)(2)(i)–(iii).

  • Bridles must permit attachment to hoisting gear capable of lifting at least 5,000 lb (1915.87(f)(2)(i)).
  • Use appropriate restraints (straps, harnesses) to secure the patient during lifting or transport (1915.87(f)(2)(ii)).
  • Keep a blanket or other covering with each stretcher (1915.87(f)(2)(iii)).

(See 1915.87(f)(2).)

Under 1915.87(f)(3)–(4), how must basket stretchers and related equipment be stored and inspected?

Basket stretchers and related equipment must be stored in a clearly marked location to prevent damage and protect against environmental conditions, and they must be inspected at intervals that keep them safe and serviceable, but at minimum once a year. 1915.87(f)(3)–(4) require clear marking, protected storage, and inspections at least annually to ensure serviceability.

  • Store stretchers off the deck if possible and under cover to avoid corrosion or UV damage.
  • Keep inspection records showing dates, findings, and corrective actions; annual inspection is the minimum frequency (1915.87(f)(4)).

(See 1915.87(f)(3) and 1915.87(f)(4).)

Under 1915.87(c)(1)(i), what qualifies as an on-site clinic or infirmary that can substitute for trained first aid providers on each shift?

An on-site clinic or infirmary that has first aid providers available during each workshift satisfies the requirement to have an adequate number of trained first aid employees. 1915.87(c)(1)(i) allows an on-site clinic or infirmary with first aid providers on duty during every workshift to meet this requirement.

  • The clinic/infirmary must actually be staffed with personnel who can render first aid during each shift, not merely be present as a room or equipment.
  • Keep staffing schedules and clinic hours available to demonstrate continuous coverage.

(See 1915.87(c)(1)(i).)

How should employers document that outside EMS can reach a shipyard worksite within five minutes as allowed in 1915.87(c)(1)(ii)?

Employers should document EMS response-time assurances with written agreements, memoranda, or records (calls, emails) showing local EMS can reach the worksite within five minutes and that steps were taken to verify prompt availability. 1915.87(c)(1)(ii) requires the employer to demonstrate outside first aid providers can reach the site within five minutes and to "take appropriate steps" to ascertain prompt availability.

  • Get written confirmation from EMS, maintain call logs, and periodically re-confirm response times, especially if site location or operations change.
  • Keep these documents with your safety program records to show compliance during inspections.

(See 1915.87(c)(1)(ii).)

Under 1915.87(d)(3) and (d)(4), what are acceptable practices to keep first aid supplies dry, sterile, and serviceable?

Store first aid supplies in weatherproof containers, keep them sealed and off wet surfaces, rotate stock before expiration, and replace any broken or contaminated items so supplies remain dry, sterile, and serviceable. 1915.87(d)(3) requires weatherproof containers and 1915.87(d)(4) requires keeping supplies dry, sterile, and serviceable.

  • Use sealed first aid cabinets or waterproof kits in exposed locations and store them off the deck/floor.
  • Check expiration dates and sterility of dressings and replace as needed.

(See 1915.87(d)(3) and 1915.87(d)(4).)

How does OSHA view bleeding control kits and training in light of the "First aid and bleeding control" letter of interpretation (2019-06-19) when applying 1915.87 requirements?

OSHA recognizes uncontrolled bleeding as a serious hazard and supports employers' use of bleeding control training and kits as part of an adequate first aid program when hazards warrant it. The June 19, 2019 letter "First aid and bleeding control" explains employers must provide adequate training and supplies and that standards are performance-based; employers may adopt more stringent measures like Stop the Bleed kits and training to meet their obligations under standards such as 1915.87.

  • Evaluate workplace risks (e.g., operations that can cause traumatic amputations or major lacerations) and include hemorrhage control supplies and training where needed.
  • Maintain documentation of training, kit locations, and inspections to demonstrate adequacy.

(See 1915.87 and OSHA's 2019-06-19 letter).

Under 1915.87(d)(2), how should an employer size first aid kits for remote or high-hazard shipyard operations?

Size and stock first aid kits based on the worksite's size and location, number of employees, hazards, and distance from hospitals or rescue squads so that supplies are adequate for likely incidents and delays in external help. 1915.87(d)(2) requires employers to ensure placement, content, and amount are adequate for those factors.

  • For remote/high-hazard sites, include more advanced supplies (e.g., hemorrhage control, splints, AED access) and multiple kits positioned near high-risk tasks.
  • Coordinate with medical advisors or EMS to determine appropriate kit contents and quantities.

(See 1915.87(d)(2) and 1915.87(e) for related emergency facilities.)

Under 1915.87(c)(4), does first aid training need to include CPR for all first aid providers?

Yes — first aid providers must be trained to render first aid including cardiopulmonary resuscitation (CPR). 1915.87(c)(4) explicitly requires training in first aid that includes CPR.

  • Ensure CPR training is current and consistent with accepted providers (Red Cross, American Heart Association, or equivalent) as required by 1915.87(c)(5).

(See 1915.87(c)(4) and 1915.87(c)(5).)

Under 1915.87(f)(2)(i), what is the minimum rated lifting capacity required for hoisting gear used with basket stretchers?

The hoisting gear used with basket stretchers must be capable of lifting at least 5,000 pounds (2,270 kg). 1915.87(f)(2)(i) requires permanent lifting bridles that enable attachment to hoisting gear rated at a minimum of 5,000 lb.

  • Verify hoisting gear capacity and markings and keep inspection/maintenance records for lifting equipment used in rescue operations.

(See 1915.87(f)(2)(i).)

Under 1915.87, can employers rely on non-certified first aid training organizations if the training meets the standard's requirements?

Yes — employers can use any training organization as long as the training results in first aid providers who are adequately trained and maintain current certifications that are equivalent to recognized programs. 1915.87(c)(4)–(5) requires training including CPR and 1915.87(c)(5) requires current certifications such as from the Red Cross or American Heart Association or an equivalent organization.

  • If using an alternative provider, document how their curriculum and certification are equivalent.
  • Keep records of course content, instructor qualifications, and trainee completion to show adequacy.

(See 1915.87(c)(4) and 1915.87(c)(5).)

Under 1915.87, what recordkeeping is useful to show compliance with first aid provider and EMS availability requirements?

Keep records of first aid provider training and certification, staffing schedules, first aid kit locations and inspection logs, written agreements or confirmations with local EMS, and inspection/maintenance records for basket stretchers. These documents demonstrate compliance with provisions in 1915.87(c) and 1915.87(d).

(See 1915.87(c) and 1915.87(d).)

Under 1915.87, how often must employers inspect first aid supplies and what should those inspections include?

Employers must inspect first aid supplies at sufficiently frequent intervals to ensure they are adequate and serviceable; inspections should check quantities, expiration dates, sterility, container integrity, and replenish as needed. 1915.87(d)(6) requires inspection at intervals sufficient to ensure adequacy and serviceability, and 1915.87(d)(5) requires replenishment as necessary.

  • For many worksites, a monthly visual check plus a more detailed quarterly or semiannual inventory is practical; remote/high-hazard sites may require more frequent checks.
  • Record inspection dates, findings, and corrective actions to show compliance.

(See 1915.87(d)(5)–(6).)

Under 1915.87, must first aid providers be on every shift even if hazards are low and EMS response is near?

If the employer can demonstrate that either an on-site clinic/infirmary with first aid providers is present on every shift or that outside EMS can reach the site within five minutes, then dedicated first aid providers on every shift may not be required; otherwise employers must ensure adequate trained first aid providers each workshift. 1915.87(c)(1) allows two exceptions: (i) an on-site clinic/infirmary with providers on each workshift or (ii) demonstrated outside EMS within five minutes under 1915.87(c)(1)(i)–(ii).

  • If neither condition is met, employers must staff trained first aid providers for each shift based on the factors in 1915.87(c)(3).

(See 1915.87(c)(1).)