The Occupational Safety and Health Administration’s (OSHA’s) medical services and first aid regulation (29 Code of Federal Regulations (CFR) 1910.151(b)) states: “Adequate first aid supplies shall be readily available.” Performance requirements and contents of first aid kits are given in the American National Standards Institute/International Safety Equipment Association (ANSI/ISEA) Z308.1 American National Standard – Minimum Requirements for Workplace First Aid Kits and Supplies standard.
On June 17, 2015, ANSI approved the latest edition of ANSI/ISEA Z308.1-2015. The effective date of this revised standard is June 17, 2016.
The newest edition does not change the scope or purpose of the previous edition. However, it does introduce two classes of first aid kits: Class A and Class B. Class A kits are designed to deal with the most common types of workplace injuries. Class B kits are designed to deal with a broader range and quantity of supplies to deal with injuries in more complex or high-risk environments. The purpose of adding these two classes is to expand the basic items included so employees will have greater access to items needed to treat common workplace injuries.
Below is a list of the minimum required components of the Class A and Class B kits. The quantity and size specifications of these components are the minimum necessary to comply with the 2015 standard.
First aid kit containers are classified by portability, the ability to be mounted, resistance to water, and corrosion and impact resistance.
Type I: Intended for use in stationary, indoor applications where kit contents have minimal potential for damage. These kits are not intended to be portable and should have a means for mounting in a fixed position. Some applications for Type I first aid kits are general indoor use, office use or use in a light manufacturing facility. First aid cabinets would fall in this classification.
Type II: Intended for portable use in indoor applications where the potential for damage to kit supplies due to environmental factors and rough handling is minimal. Some applications for Type II first aid kits are general indoor use, or use in office or manufacturing environments.
Type III: Intended for portable use in mobile indoor and/or outdoor settings where the potential for damage of kit supplies due to environment is not probable. These kits should have the means to be mounted in a fixed position and have a water-resistant seal. Typical applications are general indoor use and sheltered outdoor use.
Type IV: Intended for portable use in mobile industries and/or outdoor settings where the potential for damage to kit supplies due to environmental factors and rough handling is significant. These kits must have a means to be mounted in a fixed position and must be corrosion, moisture and impact resistant (meet the performance requirements of ANSI/ISA Z308.1-2015 Section 5.2.5). Typical applications for Type IV first aid kits include the transportation, utility and construction industries, and the armed forces.
The revised 2015 edition removed requirements for unitized kits. The emphasis is now placed more on content versus kit configuration. Guidance on color coding of first aid supplies for configuration purposes to provide users and suppliers with an easy reference when identifying and stocking first aid items is provided in Appendix B.3 and is noted below:
- Blue – Antiseptics
- Yellow – Bandages
- Red – Burn Treatment
- Orange – Personal Protective Equipment
- Green – Miscellaneous
In deciding which class of kit is more appropriate for a given workplace, employers should consider the risks and task load of the work environment and the potential severity and likelihood of occurrence of an injury. Since each workplace is unique, additional first aid kit components should be selected in addition to the basic components to address these hazards. Employers who have large or multiple operations and unique or changing first aid needs in their workplace may need to supplement with additional supplies, as noted in Appendix B.2 of the 2015 edition. By assessing the needs of their worksite, employers can ensure that reasonable first aid supplies are available. Employers should review this information on an annual basis.
Bloodborne pathogen-related personal protective equipment is not required in a first aid kit, but is recommended. 29 CFR 1910.151 Non-Mandatory Appendix A states: “If it is reasonably anticipated that employees will be exposed to blood or other potentially infectious materials while using first aid supplies, employers are required to provide appropriate personal protective equipment (PPE) in compliance with the provisions of the occupational exposure to bloodborne pathogens standard, 1910.1030(d)(3). This standard lists the appropriate PPE for the type of exposure, such as gloves, gowns, face shields, mask or eye protection.”
Over-the-counter (OTC) medicine can be put in first aid kits if packaged in single-dose, tamper-evident packaging and labeled as required by Food and Drug Administration (FDA) regulations. OTC drugs should not contain ingredients known to cause drowsiness. It is suggested to check your company procedures as well as your insurance company regarding the policy for OTC medications. Many insurance companies do not approve of OTC medications as first aid kit components.
Section 7 of ANSI/ISEA Z308.1-2015 requires all labeling and markings to be legible, permanent and if adhesive labels are used they must not be easily removed. Each kit and/or location must be visibly marked and contain the following information, as applicable, in at least six-point font:
Appendix B.1 of the 2015 edition notes that first aid kits should be frequently inspected to ensure that they are full, in usable condition and that the contents have not expired.
Find even more information you can use to help make informed decisions about the regulatory issues you face in your workplace every day. View all Quick Tips Technical Resources at www.grainger.com/quicktips.
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The content in this newsletter is intended for general information purposes only. This publication is not a substitute for review of the applicable government regulations and standards, and should not be construed as legal advice or opinion. Readers with specific compliance questions should refer to the cited regulation or consult with an attorney.
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