Page 12 - Occupational Health & Safety, April 2018

FIRST AID
Meeting OSHA’s First Aid Requirements
Employers must evaluate their first aid response and preparedness programs based not only on OSHA compliance, but the needs of their workplace and employees.
BY JESSICA DAVIS
10 Occupational Health & Safety | APRIL 2018
www.ohsonline.com
An OSHA enforcement case announced in September 2011 is a good example of the importance of complying with the agency’s first aid standards. The agency proposed a total of $221,200 in penalties in citing a Texas boat and barge repair company for one willful and 39 seri- ous violations after the deaths of two workers from a fire. Among the violations cited was a serious viola- tion of OSHA 29 CFR 1915.98(a), the medical servic- es and first aid standard for shipyard employment; at the barge OSHA personnel investigated, the only first aid kits were located in the office approximately 300 yards away, far from “readily accessible” as OSHA’s standard mandates.
OSHA lays out general industry employer respon- sibilities for medical services and first aid for injured or sick workers in 29 CFR 1910.151. The standard is familiar: Employers must ensure that medical person- nel are readily available for advice and consultation, a person or persons on site are trained in first aid, and first aid supplies are readily available. In addi- tion, facilities for emergency drenching or flushing of the eyes and body must be present within work ar- eas where a worker’s eyes or body may be exposed to harmful corrosive materials.
First Aid Kit Contents
According to OSHA’s 1904.7(b)(5)(ii), first aid can en- compass a variety of actions, including using wound coverings such as bandages, removing foreign bodies from the eye using irrigation or a cotton swab, and even administering tetanus immunizations.
With such a wide variety of treatments falling un- der the umbrella of first aid, OSHA does not have strict requirements for the materials a first aid kit should contain. Instead, the agency advises in its Best Prac- tices Guide: Fundamentals of a Workplace First-Aid Program, that each employer designate one person the responsibility of choosing the types and amounts of first aid supplies, as well as maintaining them and the kit. As a starting point, OSHA directs employers to American National Standard ANSI/ISEA Z308.1- 2015, “Minimum Requirements for Workplace First- aid Kits,” which recommends the following contents:
■ Adhesive bandage
■ Adhesive tape
■ Antibiotic application ■ Antiseptic
■ Breathing barrier
■ Burn dressing (gel soaked) ■ Burn treatment
■ Cold pack
Eye covering (with means of attachment)
■
■ Eye/skin wash
■ First aid guide
■ Hand sanitizer
■ Medical exam gloves
■ Roller bandage (2 inch) ■ Roller bandage (4 inch) ■ Scissors
■ Splint
■ Sterile pad
■ Tourniquet
■ Trauma pad
■ Triangular bandage
First Aid Training
OSHA’s language around first aid training is also broad. The 1910.151 standard does not name any particular training program or level of expertise for first aid compliance; instead, more specific training requirements are named in several standards that ad- dress permit-required confined spaces, commercial diving operations, logging operations, electric power, shipyard employment, and construction. These in- dustries require more specific standards because of their specialized nature.
The standard for permit-required confined spaces, 1910.146: Permit-required Confined Spaces, requires employers to train affected employees in basic first aid and cardiopulmonary resuscitation (CPR), as well as ensure that at least one member of the rescue team or service holding a current certification in both is avail- able. As for commercial diving operations, 1910.410, Qualifications of Dive Team, requires all dive team members to be trained in CPR and first aid, specifying the American Red Cross standard course or its equiv- alent. The standards for logging operations, electric power, and construction are more detailed.
Logging Operations
Appendix B of 1910.266, Logging Operations, states that, at minimum, employees must be trained in first aid and CPR by conventional methods such as lecture, demonstration, practical exercise, and writ- ten and practical exam, for long enough that trainees can demonstrate their ability to perform the following outlined procedures: