What Does OSHA Require for First Aid?
What Does OSHA Require for First Aid?
An employer's responsibility in the workplace to its employees is that the employees be given a safe and healthy workplace that is reasonably free of occupational hazards. Information on the OSHA Web site, however, states that it is unrealistic to expect accidents wonít happen. Therefore, an employer must provide medical and first aid personnel and supplies commensurate with the hazards of the workplace. Here are some tips on how to meet this requirement.
First aid generally refers to the medical treatment administered immediately after an injury at the location where the injury occurred. It's usually a one-time, short-term treatment and requires little technology or little training to administer. In dental laboratories, we have heard that the most frequent types of injuries are cuts, abrasions and burns so first aid could include the cleaning of those minor cuts, scrapes or scratches, treatment of a minor burn and applying bandages and dressings. OSHA does not require that first aid cases be documented on the OSHA 300 log. We recommend that you track even these minor injuries as it may show a trend in a certain type of injury that requires further safety training. Near misses, as some of these inuuries may be called, can be just as important in the evaluation of safety training as an injury that results in medical treatment outside the location.
OSHA's requirements for first aid by an employer can be found at www.osha.gov by searching for first aid on the home page. The standards that apply to first aid for general industry are outlined at 29 CFR 1910 Subpart K, Medical and first aid and 1910.151, Medical services and first aid. There are also interpretation letters that address this subject so if you have a specific question that's not answered in this article, then search the interpretations for the topic first aid to see if that question has been addressed by OSHA for another employer.
The following is an example of one of the issues dealt with by an interpretation letter on the topic of what does in near proximity mean. Paragraph 1910.151(b) of OSHA's general industry standard on medical services and first aid states:
"In the absence of an infirmary, clinic, or hospital in near proximity to the workplace which is used for the treatment of all injured employees, a person or persons shall be adequately trained to render first aid. Adequate first aid supplies shall be readily available."
OSHA stated in a letter of in interpretation dated January 16, 2007:
"The primary requirement addressed by these first aid standards is that an employer must ensure prompt first aid treatment for injured employees, either by providing for the availability of a trained first aid provider at the worksite, or by ensuring that emergency treatment services are within reasonable proximity of the worksite."
The employer must ensure that:
". . . adequate first aid is available in the critical minutes between the occurrence of an injury and the availability of physician or hospital care for the injured employee."
The letter further explains:
"While the first standards do not prescribe a number of minutes, OSHA has long interpreted the term 'near proximity' to mean that emergency care must be available within no more than 3-4 minutes from the workplace. Medical literature establishes that, for serious injuries such as those involving stopped breathing, cardiac arrest, or uncontrolled bleeding, first aid treatment must be provided within the first few minutes to avoid permanent medical impairment or death. Accordingly, in workplaces where serious accidents such as those involving falls, suffocation, electrocution, or amputation are possible, emergency medical services must be available within 3-4 minutes, if there is no employee on the site who is trained to render first aid."
The letter goes on to state that:
"OSHA does exercise discretion in enforcing the first aid requirements in particular cases. For example, OSHA recognizes that in workplaces, such as offices, where the possibility of such serious work-related injuries is less likely, a longer response time of up to 15 minutes may be reasonable."
A question that has been asked of us is if you need a blood spill kit in a dental laboratory. Typically a laboratory has all the equipment required to clean up a blood spill (i.e. gloves, eyewear, absorbent material, bag for disposal, etc.). If you feel it necessary to have a person trained on first aid due to exposure to blood, then you must offer them the Hepatitis B vaccine. In laboratories, we recommend that you designate a first responder in your emergency action plan, but that is to respond internally to chemical spills. If that person is also required to clean up blood spills, then you need to provide the appropriate training for that individual plus the Hepatitis B vaccine.
Because an exposure to blood from a cut in a dental laboratory normally involves an employee cutting themselves, Safelink recommends that all employees be informed to clean up their own blood and to sanitize the counter and/or equipment with disinfectant. Small cleanup kits in the immediate work area minimize the risk of contaminating other workers. These kits can be very small and basic, containing a pair of latex gloves, adhesive bandages and disinfectant towelettes.
The requirements for blood exposure under the Bloodborne Pathogen Standard would not fall within this general first aid standard. If you have further questions and can't find the answers on the OSHA Website, then please call Safelink.
