First aid requirements

Yes. Under 1926.23 employers must make first‑aid services and provisions for medical care available to every employee covered by Part 1926.

• The text of 1926.23 is the baseline requirement; more specific rules about supplies, facilities, and response are found in Subpart D of Part 1926.

All employees covered by Part 1926 (the construction standards) are covered — the employer must make first‑aid services and medical care available for every employee who falls under those construction regulations.

• See the plain requirement in 1926.23.

No. 1926.23 requires that first‑aid services and provisions for medical care be made available, but it does not list exact supplies or staff counts; those specific requirements are set out in Subpart D and in other related standards or guidance.

• To determine what is required on a particular job, consult Subpart D of Part 1926 for detailed rules and carry out a workplace hazard assessment to tailor first‑aid provisions to your site.

Yes. 1926.23 requires employers to make first‑aid and medical care available, which can be satisfied by providing onsite services or by arranging prompt access to offsite medical providers (for example, local EMS or hospitals), so long as the arrangement provides timely care appropriate to the hazards and conditions on the job.

• Employers should confirm response times and capabilities and document the arrangement as part of emergency planning.
• Use a workplace hazard assessment to determine whether offsite providers are sufficient for the site's risks and remoteness.

OSHA requires that first‑aid services and medical care be available, but it does not impose a universal mandatory retraining interval for CPR; OSHA guidance recommends instructor‑led CPR retraining at least annually, while specific OSHA standards may require CPR or first‑aid training for certain operations.

• OSHA's Best Practices Guide recommends annual instructor‑led retraining for life‑saving skills such as CPR and AED use. OSHA does not set a mandatory CPR retraining interval for all employers, but some standards (for example, permit‑required confined spaces or logging operations) include explicit first‑aid/CPR training requirements.

Section 1926.23 itself does not require a written first‑aid plan; however, employers should use a written plan when appropriate based on the site hazards and any specific standards that apply.

• Perform a hazard assessment to decide what written procedures, training, and resources you need; OSHA's interpretation on PPE hazard assessment explains the employer's duty to assess the workplace and prepare appropriate controls and procedures.
• Specific standards within Part 1926 or other OSHA rules may require written plans for particular hazards (for example, permit‑required confined spaces or other specialized operations).

Each employer is responsible for making first‑aid services and medical care available for its own employees under 1926.23; general coordination between contractors is important to ensure timely care for all workers on site.

• Host contractors and subcontractors should communicate and coordinate emergency arrangements—such as shared trained responders, first‑aid kits, or EMS access—to avoid gaps in coverage.
• Use the site hazard assessment to agree on roles, communication, and resources for emergencies.

Decide the number of trained responders based on a site‑specific hazard assessment that considers the type of work, number of workers, site layout, distance to emergency medical services, and likely injuries. 1926.23 requires availability of first‑aid services, and OSHA's interpretations stress the employer's duty to assess workplace hazards to determine appropriate protections.

• Conduct a written or documented hazard assessment to evaluate risks and emergency response times.
• Consider higher coverage when work is remote, when hazardous tasks are performed, or where access by EMS will be delayed.

No single OSHA provision in 1926.23 mandates AEDs on every construction site; the standard requires employers to make first‑aid services available, and whether an AED is necessary should be determined by a hazard assessment and emergency planning for the site.

• If the hazard assessment indicates a realistic need for AEDs (for example, remote site, large workforce, or delayed EMS response), employers should include AEDs in their emergency response resources and training.

Yes — hazardous‑materials work can change the scope of first‑aid and medical attention required because specific OSHA standards that cover those hazards may impose additional medical, training, or emergency requirements beyond 1926.23's general duty to make first‑aid available.

• For example, asbestos work is governed by 29 CFR 1926.1101 (see OSHA's asbestos interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-11-14), and that standard includes detailed medical and protective requirements.
• Perform a hazard assessment and then follow the applicable specific standard(s) in addition to ensuring general first‑aid availability under 1926.23.

1926.23 requires employers to make first‑aid services and medical care available, but it does not spell out payment terms in that single sentence; when a specific OSHA standard requires employer‑provided training, equipment, or protective measures those items are typically provided by the employer.

• If a particular standard in Part 1926 or another OSHA rule explicitly requires training or protective equipment, the employer must supply it as required by that standard (see examples of standards that mandate training in the CPR interpretation).
• To be compliant, plan for and budget the first‑aid supplies and training needed to meet the site's hazards and any specific regulatory requirements.

Employers must ensure that appropriate first‑aid services and medical care are available promptly; whether that means immediate onsite care or rapid transfer to EMS depends on the injury, site hazards, and arrangements made in advance.

• For life‑threatening emergencies, employers should have procedures to obtain immediate emergency medical care (e.g., activate EMS), and where feasible trained responders should provide immediate lifesaving care until EMS arrives.
• Use a hazard assessment and emergency plan to define response actions and timelines for onsite care versus EMS transport.