OSHA 29 CFR 1910.151
Medical Services and First Aid - Workplace Emergency Response Requirements
Last updated: September 21, 2025
Overview
OSHA 29 CFR 1910.151(b) is the primary federal regulation mandating first aid preparedness in U.S. workplaces. This performance-based standard requires that "adequate first aid supplies shall be readily available" for workplaces not in "near proximity" to a medical facility. The regulation is intentionally non-prescriptive, allowing employers flexibility to determine what constitutes "adequate" based on their specific hazard assessment.
Performance-Based Standard: OSHA 1910.151 is intentionally flexible, requiring "adequate" supplies without prescriptive lists, making ANSI/ISEA Z308.1 compliance the best practice for legal defensibility.
Key Requirements
- First Aid Supplies: Must be readily available and adequate for the hazards present in the workplace
- Near Proximity Rule: 3-4 minutes emergency response time for high-hazard environments, up to 15 minutes for low-hazard offices
- Trained Personnel: If not near medical facilities, trained first aid providers must be available on-site
- Hazard Assessment: Employers must conduct formal assessments to determine appropriate supplies and response capabilities
- Consultation Option: Employers may consult with physicians to determine specific first aid requirements
Compliance Guidance
OSHA explicitly refers employers to ANSI/ISEA Z308.1 in its non-mandatory Appendix A guidance. Compliance with the latest version of ANSI/ISEA Z308.1-2021 is the most reliable and legally defensible method for satisfying OSHA's "adequate supplies" requirement. The standard provides detailed specifications for:
- Class A kits for basic/low-risk environments
- Class B kits for higher-risk or complex environments
- Minimum required contents and quantities
- Container specifications and markings
Response Time Requirements
OSHA's interpretation of "near proximity" varies by workplace hazard level:
- High-Hazard Workplaces: 3-4 minute response time required (construction, manufacturing, chemical processing)
- Low-Hazard Workplaces: Up to 15 minute response time acceptable (offices, retail, professional services)
- Remote Locations: On-site trained personnel and supplies mandatory when response times exceed these thresholds
Enforcement and Citations
OSHA compliance officers evaluate first aid preparedness during workplace inspections. Common citation issues include inadequate supplies for the number of workers, expired or missing items, lack of trained personnel, and failure to conduct hazard assessments. Penalties can range from warnings to significant fines, with willful violations potentially exceeding $150,000 per violation.
Resources
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