First aid and injury reporting

Under 1918.97(a), employers must require each employee to report every work-related injury, no matter how minor, to the employer.

• This means you should have a clear process so injured workers know who to tell and how to report an injury immediately. See the Injury reporting requirement in 1918.97(a).
• Keep records and follow any additional reporting rules (for serious injuries) in OSHA recordkeeping regulations as applicable.

Under 1918.97(b), employers must have a first aid kit at or near each vessel being worked and must make at least one person holding a valid first aid certificate available while work is in progress. See the First aid requirement in 1918.97(b).

• The standard gives the Red Cross certificate as an example, but allows other equivalent organizations.
• OSHA's interpretation notes that OSHA does not itself certify training programs and that required first-aiders must be "adequately trained" under related standards; employers may rely on recognized first-aid courses and should ensure training matches workplace hazards (see OSHA's First aid and bleeding control interpretation).

Under 1918.97(c), the contents of each first aid kit must be determined by a person who is certified in first aid and familiar with the hazards of marine cargo handling operations. See the First aid kits requirement in 1918.97(c).

• That person should evaluate the specific tasks and hazards (cuts, crushing, bleeding, cold exposure, etc.) and specify sterile, individually sealed items as required by the standard.
• Employers can document who made the determination and update contents when hazards change.

Yes. Under 1918.97(c), first aid kits must be weatherproof and must contain individual sealed packages for each item that must be kept sterile. See the First aid kits requirement in 1918.97(c).

• This protects sterility in marine environments where moisture and salt can damage supplies.
• Make sure kits are stored where they won’t be exposed to rain or seawater, or use weatherproof enclosures.

Under 1918.97(b), a first aid kit must be available at or near each vessel being worked. See the First aid location requirement in 1918.97(b).

• "At or near" means the kit must be close enough for prompt access during normal operations; employers should assess response times and position kits accordingly.
• If multiple vessels are worked in different spots, provide kits for each location rather than relying on one distant kit.

Yes. 1918.97 states the contents shall be checked at intervals that allow prompt replacement of expended items. See the inspection/stocking expectation in 1918.97.

• The standard does not prescribe a fixed frequency, so employers should set inspection intervals based on usage and hazards (for example, weekly, monthly, or after each operation that used kit items).
• Keep a log of inspections and restocking actions to show the employer’s compliance and readiness.

Under 1918.97(d)(1), for each vessel being worked at least one Stokes basket stretcher, or an equivalent, must be available and permanently equipped with bridles for attachment to hoisting gear. See the Stretcher requirement in 1918.97(d)(1).

• "Equivalent" means a device that provides the same safe patient-carry capability for the work being performed; employers should document equivalency.
• The stretcher must be ready for hoisting and vertical removal if needed.

Under 1918.97(d)(5), lifting bridles must be capable of lifting 1,000 pounds (454 kg) with a safety factor of five (i.e., have a lifting capability of 5,000 pounds). See the Lifting bridle strength requirement in 1918.97(d)(5).

• Employers must maintain bridles in operable condition and provide bridles for vertical patient lifts at container berths.
• Document inspections and repairs, and replace bridles that show wear, corrosion, or damage.

Yes. Under 1918.97(d)(5), stretchers used for vertical lifts must have foot plates. See the Vertical-lift stretcher feature in 1918.97(d)(5).

• Foot plates help secure the patient and improve stability during vertical hoisting.
• Ensure any stretcher used for vertical lifts is rated for that use and maintained per 1918.97(d)(6).

Under 1918.97(d)(4), stretchers must have at least four sets of effective patient restraints in operable condition. See the Patient restraint requirement in 1918.97(d)(4).

• Restraints must be functional and inspected regularly so they work reliably during hoisting or movement.
• Replace or repair any restraint that shows fraying, broken buckles, or other damage.

Under 1918.97(d)(6), stretchers must be maintained in operable condition and their struts, braces, and wire mesh inspected for damage; damaged stretchers must not be used until repaired. See the Stretcher maintenance requirement in 1918.97(d)(6).

• Create and follow a written inspection checklist and schedule; check for cracks, loose rivets, sharp edges, and secure mesh.
• Tag out and remove any stretcher from service if defects are found and record repairs.

Under 1918.97(d)(7), permanently located stretchers outdoors must be mounted to prevent damage and protected from the elements; if concealed from view, enclosures must be marked to indicate the location of the lifesaving equipment. See the Permanent stretcher location requirement in 1918.97(d)(7).

• Use weatherproof cabinets or coverings and corrosion-resistant mounting hardware.
• Clearly mark enclosures so workers can quickly find stretchers and lifesaving equipment in an emergency.

Under 1918.97(e)(1), there must be at least one U.S. Coast Guard approved 30-inch life-ring with no less than 90 feet of line attached in the vicinity of each vessel being worked, plus at least one ladder that reaches from the top of the apron to the water surface. See the Life-ring and ladder requirement in 1918.97(e)(1).

• Ensure life-rings are Coast Guard approved and that the attached line is in good condition and wound so it can be quickly thrown.
• Keep the ladder accessible and in good repair so a person in the water can reboard safely.

Under 1918.97(e)(2), when working a barge, scow, raft, lighter, log boom, or carfloat alongside a ship, a U.S. Coast Guard approved 30-inch life-ring with at least 90 feet of line must be provided either on the floating unit itself or aboard the ship in the immediate vicinity of each floating unit being worked. See the Floating-unit life-ring requirement in 1918.97(e)(2).

• Place life-rings so they are immediately accessible to the work area on either platform.
• Inspect life-ring line and hardware regularly and replace when worn.

Under 1918.97(f), telephone or an equivalent means of communication must be readily available at the worksite. See the Communication requirement in 1918.97(f).

• "Equivalent means" can include radios, cell phones, or other systems that allow prompt contact with emergency services or on-site responders.
• Test and maintain communication devices so they work during emergencies.

Yes. Under 1918.97(b), the standard allows at least one person holding a valid first aid certificate "such as is issued by the Red Cross or other equivalent organization" to be available. See the First aid certificate language in 1918.97(b).

• OSHA does not itself certify first-aid programs or instructors; employers should use well-recognized, competent training providers and ensure the training adequately covers the workplace hazards (see OSHA's First aid and bleeding control interpretation).
• Keep training records and ensure seasonal refresher training as hazards or tasks change.

1918.97 does not specify a precise response time for a first aider to reach an injured worker; it requires that a certified first aider be available when work is in progress and that first aid kits be at or near each vessel being worked. See the availability requirement in 1918.97(b) and the general instruction to locate kits at or near each vessel.

• OSHA’s 2019 First aid and bleeding control interpretation explains OSHA expects employers to ensure first aid capability and that training and placement are sufficient for prompt care; employers should assess specific workplace conditions to set practical response goals and ensure coverage for all shifts.

Yes. 1918.97 sets minimum requirements for kits and trained personnel, but employers may provide additional items like bleeding control kits or tourniquets as part of a more protective program. See the First aid provisions in 1918.97(b) and (c).

• OSHA’s 2019 First aid and bleeding control interpretation recognizes the importance of rapid bleeding control and advises employers may consult medical personnel about appropriate kit contents and training.
• If you add items like tourniquets, document the medical rationale, provide training, and maintain replacement supplies.

Under 1918.97(c), a person certified in first aid and cognizant of the hazards found in marine cargo handling operations should determine the kit contents. See the Kit-content determination requirement in 1918.97(c).

• Employers may additionally consult occupational health professionals or the guidance in OSHA's 2019 First aid and bleeding control interpretation to evaluate whether kits should include trauma/bleeding control supplies based on risk assessments.

1918.97(b) requires a first aid kit to be available at or near each vessel being worked, so employers should ensure kits and trained personnel provide prompt access for each active work location; whether one kit/first aider can cover multiple vessels depends on proximity and the ability to respond quickly. See the First aid location requirement in 1918.97(b).

• Perform a site-specific assessment: if vessels are adjacent and response is immediate, one kit and one trained responder may be sufficient; if travel time would delay care, provide additional kits or responders.
• Document the assessment and rationale for coverage decisions.

Yes. Under 1918.97(d)(7), if lifesaving equipment is concealed from view in an enclosure, the enclosure must be marked to indicate the location of the lifesaving equipment, and the equipment must be mounted to prevent damage and protected from the elements if outdoors. See the Concealed equipment marking and protection requirement in 1918.97(d)(7).

• Use clear signage and regular checks to ensure markings remain visible and equipment is accessible in emergencies.

No. Under 1918.97(d)(6), wire mesh must be secured and have no burrs; damaged stretchers shall not be used until repaired. See the Stretcher damage prohibition in 1918.97(d)(6).

• Remove damaged stretchers from service immediately, tag them out, repair per manufacturer or competent person instructions, and record the repair before returning them to service.

1918.97 does not address vehicle modifications, but OSHA has advised that adding safety devices such as strobe lights is allowed provided any modification that might affect vehicle capacity or safety has the manufacturer's prior written approval or the written approval of a professional engineer experienced with the equipment (see OSHA's strobe lights on industrial trucks interpretation).

• If you add strobe lights, obtain the proper approvals and update operator training as required.
• While this citation is from a maritime-related interpretation, also review the specific powered industrial truck standards that apply to your operations.