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First Aid Regulation, 29 CFR 1910.151 and Z308.1-2003 Summary

Quick Tips #208

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The medical services and first aid regulation, 29 CFR 1910.151, was revised in 1998. The revision 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." ANSI Z308.1-2009 establishes minimum performance requirements for first aid kits and their contents.  As each work environment is unique, it is expected that the contents of each kit will be supplemented as needed based upon the recommendations of a person competent in first aid.

*Note: The non-mandatory Appendix A refers to ANSI Z308.1-1978, Minimum Requirements for Industrial Unit-Type First Aid Kits. Since Appendix A was added, ANSI has updated Z308.1-1978 to the 2003 standard. OSHA has yet to revise Appendix A to reference the updated ANSI Z308.1-2003 standard.

Classification of First Aid Kits

Under the ANSI standard, Z308.1-2009, first aid kits are divided into four different categories or classifications. Kits must also meet the performance and testing requirements set by the standard.

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 in a light manufacturing facility. First aid cabinets would fall in this classification.

Type II: Intended for use in portable indoor applications. Kit contents should have minimal potential for damage. These kits should be equipped with a carrying handle. Some applications for Type II first aid kits are general indoor use, 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. Kits should have the means to be mounted and have a water resistant seal. Transportation industry or construction jobs present typical applications for Type III first aid kits.

Type IV:Intended for portable use in the mobile and/or outdoor applications where the potential for damage to the kit contents due to environmental factors and rough handling is significant.

Basic Fill Contents for Type I, II and III First Aid Kits

All first aid kits meeting the first aid regulation of ANSI Z308.1-2009 should contain the first aid items listed in Section 6.1, Table 2 of the standard. The quantity and size specifications of these components are the minimum necessary to comply with the standard. The components list includes such items as compresses, bandages, tape, gloves, antiseptic and burn treatments. Additional quantities or components can be added to meet the requirements of a specific workplace or hazard.

In addition to the minimum contents listed in the standard, a kit should have optional items added, based upon specific workplace hazards. The selection of additional supplies should be made by consulting with a healthcare professional or a person competent in first aid who is knowledgeable of the hazards found in that specific workplace. The optional items shall meet specifications stated in Section 6.2 of ANSI Z308.1-2003. Items not addressed by the standard should be in compliance with U.S. Food & Drug Administration (FDA) or any other governing body or regulation. Additional supplies include oral analgesics, antibiotic treatments, compress bandages, CPR barriers, burn dressings, cold packs, eye covers, eyewash and a roller bandage.

Marking and Labeling

All first aid contents meeting the first aid regulation of minimum requirements of basic fill contents should at least be marked with ANSI Z308.1-2009 designation. Each complete first aid kit meeting these requirements must have a permanent label on the back or outside of the kit with the information listed in the box below. All labeling should be legible and permanent. Recommended first aid contents meeting the criteria of Section of 6.2.1, Minimum Performance Criteria for Recommended Contents,may be marked as "ANSI A308.1-2009." Minimum requirements for unit first aid kits section 6.1.1 of the ANSI Z308.1-2009 standard discusse minimum requirements of unit first aid kits. The contents of unitized first aid kits are packaged in uniform-size boxes that contain one or more applications of first-aid supplies. The packaging must meet the specific requirements for dimensions, physical stability, marking and labeling. Please see ANSI Z308.1-2009 for packaging requirements. Packages must also be color coded, using the follow guidelines:

Q.   Is a consulting physician required to approve first aid supplies on site?
A.   No. According to 29 CFR 1910.151, first aid supplies do not need to be approved by a consulting physician. They should, however, be selected by a person competent in first aid and knowledgeable of the hazards found in the specific workplace.
 
Q.   Is it required that first aid kits be regularly inspected to ensure that contents are complete and up to date?
A.   Yes, first aid kits should be regularly inspected to ensure that they are full, in good condition and have not expired. The contents list for the first aid kits should be periodically reviewed to ensure that it meets the needs of the workplace hazards at all times.
 
Q.   Can over-the-counter medicine be put in first aid kits?
A.   Over-the-counter medicine can be put in first aid kits if packaged in single dose, tamper-evident packaging and labeled as required by FDA regulations. Over-the-counter drug products should not contain ingredients known to cause drowsiness.

Blue: Antiseptic
Yellow: Bandages
Red: Burn Treatment
Orange: Personal Protective Equipment



Sources for More Information

OSHA Medical Services and First Aid regulation, 29 CFR 1910.151

For a copy of the Standard ANSI Z308.1-2009, contact International Safety Equipment Association (ISEA) at:

1901 North Moore Street, Ste. 808,
Arlington, VA 22209-1762
Phone: 703.525.1695
Online: www.safetyequipment.org

http://www.ansi.org/

(Rev. 8/2014)


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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Please Note:
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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