Cal/OSHA Mulls Changes to First Aid Kit Requirement

California employers may have to update and expand their workplace first aid kits next year as Cal/OSHA finalizes new regulations governing what they should contain.

The rule-making board for Cal/OSHA has proposed changes that should make it easier to comply as one of the most confusing parts of the regulation is set to be eliminated. A portion of the current rules lays out the requirements for the first aid kit contents, which the employer can deviate from with a note from an employer-authorized licensed physician.

The regulations being formulated now would do away with those requirements and instead require employers to have adequate first aid supplies based on the hazards of their workplace, or face a Cal/OSHA citation.

The new regulations will essentially be performance standards, since the contents of the kit will be determined by the needs of an employer’s workforce.

Cal/OSHA wants employers to assess the likely injuries in their workplaces and prepare appropriately with supplies and training.

The standard is in need of revision as knowledge about first aid has evolved over time.

Most small employers are unaware of the consulting provision, but members of Cal/OSHA’s rule-making board say that the provision is unnecessary. Often if there is a note, it is merely a photocopy that has been provided by the manufacturer of the first aid kit.

Many of Cal/OSHA’s board members recommend using the first aid kit contents as recommended by the American National Standards Institute (ANSI), and that the contents be checked every three months to ensure all of the required suppliers are there.

Minutes from the October board meeting indicated that the members are leaning towards a three-pronged requirement:

  • That there be a minimum list of materials that are suitable for an office environment and perhaps at least partially include items in the ANSI list.
  • That there are other items in the kit based on the hazards that are specific to the workplace.
  • Requirements for specific hazards, like companies that have chemicals or other substances keeping the proper antidotes on hand for workers who are exposed. That would require a doctor’s certification.


What constitutes first aid?

First aid is defined by Cal/OSHA as:

  • Issuing non-prescription medications at non-prescription strengths;
  • Administering tetanus vaccinations;
  • Cleaning and covering wounds;
  • Using hot/cold therapy;
  • Using non-rigid supports and temporary immobilization devices;
  • Drilling fingernails and toenails to relieve pressure;
  • Administering eye patches, irrigating eyes or swabbing them to remove foreign bodies;
  • Removing splinters from areas other than the eye;
  • Using finger guards;
  • Using massage; and
  • Providing fluids for heat stress.


One piece of good news is that the requirements will likely not cost employers a lot of money. If a business already has an ANSI-approved kit, it would most likely suffice unless there are workplace dangers that may require additional materials.

The new rules are expected to take effect in early 2017.