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OSHA 1915.87AppA

First aid kits and AEDs

Subpart F

18 Questions & Answers
10 Interpretations

Questions & Answers

Under 1915.87AppA, what minimum first aid kit content guidance should I use for a small shipyard worksite?

Use the ANSI kit described in [ANSI/ISEA Z308.1-2009] as a reasonable minimum for small worksites. The appendix to the shipyard standard explains that first aid supplies should be "adequate and readily accessible" and gives the ANSI/ISEA Z308.1-2009 list as an example of minimal contents; see 1915.87AppA and the incorporation rule at 1915.5.

  • Employers should treat the ANSI list as a baseline for small sites and increase quantities or add items for specific hazards or larger operations.
  • Periodically review injury logs (for example OSHA 300/301) to decide if kits need augmentation, as recommended in 1915.87AppA.

Under 1915.87(a) and 1915.87AppA, how do I decide how many first aid kits a shipyard should have?

You must provide enough first aid kits so that supplies are adequate and readily accessible for the size and hazards of your operations. The appendix says employers should determine the need for additional kits, types of equipment, and quantities when larger or multiple operations are at the same worksite; see 1915.87(a) and 1915.87AppA.

  • Use workplace injury records (OSHA 300/301) and consultations with medical providers or local emergency services to estimate number and placement of kits, as advised in 1915.87AppA.
  • Consider work area size, number of employees on different shifts, and response time to emergency care when locating kits.

Under 1915.87AppA, what should I do if first aid tasks are likely to expose employees to blood or other potentially infectious materials?

Provide appropriate personal protective equipment (PPE) with the first aid supplies and train employees on its use. The appendix directs employers to comply with the Occupational Exposure to Bloodborne Pathogens standard and to supply PPE such as gloves, gowns, face shields, masks, and eye protection when exposure is reasonably anticipated; see 1915.87AppA and 1910.1030(d)(3).

  • Keep appropriate-size disposable gloves in kits and replace them after use.
  • Include face/eye protection and cleanup supplies for handling contaminated materials per 1910.1030(d)(3).

Under 1915.87AppA, are employers required to provide automated external defibrillators (AEDs) in shipyard workplaces?

No—providing AEDs is not mandatory under the appendix, but if provided employers must follow the recommendations for placement, training, and maintenance. The appendix is non-mandatory guidance that says employers who provide AEDs should designate and train users, locate AEDs to allow use within three to five minutes, follow manufacturers' specifications for use, and inspect, test, and maintain AEDs as specified; see 1915.87AppA.

  • If you choose to deploy AEDs, document who is trained and a maintenance schedule that follows the manufacturer's instructions, as recommended in 1915.87AppA.

Under 1915.87AppA, how close should an AED be to an injured worker to be effective?

Locate AEDs so they can be retrieved and used within three to five minutes of an accident or injury. The appendix specifically recommends AEDs be placed to allow use within a three- to five-minute response time to improve survival; see 1915.87AppA.

  • Map AED locations to expected incident locations and ensure clear access routes and signage to meet the recommended response time.

Under 1915.87AppA, who should be authorized to use AEDs at the workplace?

Employers should designate specific employees to use AEDs and provide them training so they know how to use the device correctly. The appendix recommends designating and training AED users even though some devices are designed for use without training; see 1915.87AppA.

  • Keep training records and ensure backups are trained to cover shifts and absences.

Under 1915.87(d) and 1915.87AppA, what does "readily accessible" mean for first aid supplies?

"Readily accessible" means first aid supplies are stored so employees can get them promptly when needed without unnecessary delay. The standard requires supplies to be adequate and readily accessible under 1915.87(d) and the appendix explains placement should reflect the size and complexity of operations; see 1915.87AppA.

  • Consider travel time, barriers (locked rooms), and multiple work areas when locating kits.
  • Ensure kits are marked and employees know their locations.

Under 1915.87AppA, how often should I reassess first aid kit contents for a shipyard operation?

Reassess first aid kit contents periodically and whenever operations, workforce size, or injury patterns change. The appendix advises employers to periodically assess specific worksite needs and augment first aid kits appropriately, using injury reports or consultation with healthcare professionals as needed; see 1915.87AppA.

  • Reassess after incidents that reveal missing items, after seasonal or project changes, and at scheduled intervals (for example quarterly or semiannually) based on your workplace risk profile.

Under 1915.87AppA and 1915.5, can I rely on ANSI/ISEA Z308.1-2009 in meeting OSHA first aid requirements?

Yes—OSHA identifies the ANSI/ISEA Z308.1-2009 standard as an example of minimal first aid kit contents for workplace settings and that consensus standard is incorporated by reference through 1915.5; see 1915.87AppA.

  • Treat the ANSI list as a minimum for small worksites; expand contents for larger or specialized operations as recommended in 1915.87AppA.

Under 1915.87AppA, should first aid kit location decisions consider shift schedules and multiple crews?

Yes—first aid kits should be placed to ensure adequate coverage for all shifts, crews, and locations where work is performed. The appendix tells employers to consider larger or multiple operations and to determine the need for additional kits and supplies when those situations exist; see 1915.87AppA and the accessibility requirement in 1915.87(a).

  • Use crew sizes and response-time goals (e.g., three to five minutes for AEDs) to plan kit placement.

Under 1915.87AppA, do employers have to consult medical professionals when deciding what to stock in first aid kits?

While not strictly required, the appendix recommends consulting local fire/rescue, appropriate healthcare professionals, or local emergency rooms to help identify unique first aid needs. This consultation is encouraged to ensure that reasonably anticipated supplies are available; see 1915.87AppA.

  • Use such consultations especially when work involves uncommon hazards (chemical exposures, severe trauma risks) that may require specialized supplies.

Under 1915.87AppA, are employers required to keep records of AED training and maintenance?

The appendix recommends training designated AED users and inspecting, testing, and maintaining AEDs according to the manufacturer's specifications, which implies employers should document training and maintenance actions. See 1915.87AppA.

  • Maintain training rosters, dates, and maintenance logs so you can demonstrate compliance with the appendix guidance and readiness of AEDs.

Under 1915.87AppA, can employers place first aid kits inside locked offices or supply rooms if those areas are staffed?

First aid supplies must be readily accessible, so placing kits behind locked doors that delay access for injured employees or responders is not appropriate unless someone with immediate access is always present. The appendix requires supplies to be "adequate and readily accessible" under 1915.87(a) and 1915.87AppA advises placement based on operations and response needs.

  • If a locked area is used, ensure a responsible person with immediate access is always on site or provide an unlocked kit nearby to meet accessibility requirements.

Under 1915.87AppA, what extra supplies might I add for shipyard tasks that create a higher risk of cuts and burns?

For tasks with elevated risks of lacerations and burns, augment the baseline ANSI kit with extra bandages, sterile dressings, hemostatic agents, burn dressings or gels, and additional PPE for bloodborne pathogen protection. The appendix advises employers to enhance kits for unique or changing first aid needs and to use injury reports or professional consultation to identify those needs; see 1915.87AppA and 1915.87(a).

  • Include extra gloves, eye protection, and absorbent material if blood exposure is likely, per 1910.1030(d)(3).

Under 1915.87AppA, are employers required to use the OSHA 300 Log or 301 form to decide kit contents?

Employers are not required to use those specific forms for kit decisions, but the appendix suggests using the OSHA 300 Log, OSHA 301 Incident Report, or other reports to identify unique problems and help determine needed supplies. The appendix frames these forms as helpful tools for assessing workplace first aid needs; see 1915.87AppA.

  • Use whatever incident reporting and trending tools your workplace maintains to guide kit augmentations and placement.

Under 1915.87AppA, what training should employees receive before using an AED?

Employees designated to use AEDs should be trained so they know how to operate the device correctly and integrate AED use into CPR response; the appendix recommends training designated users even though some AEDs allow untrained use; see 1915.87AppA.

  • Training should cover recognizing cardiac arrest, activating emergency services, operating the AED per manufacturer's instructions, and infection control practices (see 1910.1030(d)(3)).
  • Keep training frequency and refresher schedules consistent with local EMS and AED manufacturer recommendations.

Under 1915.87AppA, how should AED maintenance and inspection be handled?

Inspect, test, and maintain AEDs in accordance with the manufacturer's specifications and document those activities. The appendix explicitly advises following manufacturers' specifications for inspection, testing, and maintenance of AEDs; see 1915.87AppA.

  • Create a maintenance log showing dates of battery and pad checks, software updates, and functional tests per the manufacturer's schedule.

Under 1915.87AppA, can employers rely on public AEDs (e.g., at a marina or pier) instead of workplace AEDs to meet response-time recommendations?

Employers can rely on nearby public AEDs only if those devices can be reached and used within the three- to five-minute recommendation and access is reliable; otherwise employers should consider providing on-site AEDs. The appendix recommends AEDs be located to permit use within three to five minutes and emphasizes ensuring availability and maintenance; see 1915.87AppA.

  • Evaluate travel time, access restrictions, and who will retrieve the public AED before deciding to rely on off-site devices.