OSHA 29 CFR 1910.151

Q: Does every workplace need a first aid kit?

OSHA 1910.151(b) requires first aid supplies when the workplace is not in "near proximity" to a medical facility. In practice, virtually every workplace needs one because relying on a nearby hospital does not satisfy the need for immediate wound care.

Q: Do remote or mobile jobsites need first aid supplies?

Yes. Remote sites are by definition not in "near proximity" to medical facilities, which triggers both the trained personnel and adequate supplies requirements. Roofing crews, utility workers, and construction teams should carry portable kits and eyewash.

Q: Are AEDs (automated external defibrillators) required by OSHA?

OSHA 1910.151 does not require AEDs. However, OSHA recommends them as a best practice, and some state OSHA plans and local codes do require them in certain occupancies.

Medical Services and First Aid: Workplace Emergency Response Requirements

Last updated: March 19, 2026

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Overview

OSHA 29 CFR 1910.151 is the federal regulation governing medical services and first aid in general industry workplaces. It contains three subsections covering physician availability (a), first aid supplies and trained personnel (b), and eye/body flushing equipment for corrosive hazards (c). The standard applies to every general industry employer covered by the OSH Act.

This is a performance-based standard. OSHA does not prescribe exactly which supplies to stock or how many trained responders to have. Instead, it requires employers to ensure "adequate" first aid provisions based on their specific workplace hazards. In practice, OSHA points employers to ANSI/ISEA Z308.1 as the benchmark for what "adequate" means.

Key distinction: 1910.151 covers general industry. Construction sites fall under 29 CFR 1926.50, which has its own first aid requirements (see Industry-Specific Standards below).

Regulatory Text

The regulation is short. The full text of 29 CFR 1910.151 contains three subsections:

(a) The employer shall ensure the ready availability of medical personnel for advice and consultation on matters of plant health.

(b) 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.

(c) Where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use.

Each of these three sentences creates a distinct compliance obligation. The sections below break down what each one requires in practice.

First Aid Supplies: Section (b)

Section (b) has two requirements that work together: trained personnel and adequate supplies. Both apply when the workplace is not in "near proximity" to a hospital, clinic, or infirmary.

What "adequate" means

OSHA does not define "adequate" in the regulation text. However, the agency's non-mandatory Appendix A to 1910.151 and multiple Letters of Interpretation point to ANSI/ISEA Z308.1 as the consensus standard that satisfies this requirement. In enforcement, OSHA compliance officers evaluate adequacy against the Z308.1 Class A and Class B kit specifications.

Kit Class	Environment	Key Contents
Class A	Basic/low-risk workplaces (offices, retail, light assembly)	Adhesive bandages, gauze, antiseptic, gloves, cold pack, scissors, tape
Class B	Higher-risk or multi-hazard environments (manufacturing, warehouses, construction)	Everything in Class A plus: larger/more bandages, tourniquets, splints, burn treatment, eye coverings

See the full ANSI/ISEA Z308.1 minimum contents table for detailed item counts and specifications.

What "near proximity" means

OSHA has never defined "near proximity" with a specific distance or time in the regulation. Interpretation letters and enforcement history establish that it depends on the severity of potential injuries. A workplace where the most likely injuries are paper cuts has a different proximity threshold than a chemical plant. In practice, most employers treat any location more than 3-4 minutes from emergency medical services as requiring on-site first aid capability.

What "readily available" means

Supplies must be accessible during all work shifts, not locked away or stored in a location that requires special access. For multi-floor buildings or large facilities, this typically means multiple kit locations. Supplies must not be expired, depleted, or contaminated. OSHA expects employers to inspect kits regularly and restock after any use.

Eye Wash and Drench Showers: Section (c)

Section (c) requires flushing equipment wherever workers may be exposed to "injurious corrosive materials." This applies to any workplace that uses acids, bases, solvents, or other chemicals that can damage eyes or skin on contact. Common examples include battery charging stations, chemical mixing areas, plating operations, laboratories, and roof coating application.

ANSI Z358.1 reference: While OSHA 1910.151(c) only says "suitable facilities," the agency's compliance directives reference ANSI Z358.1 (Emergency Eyewash and Shower Equipment) as the design standard. ANSI Z358.1 specifies 15-minute flushing capacity, 10-second travel time from the hazard, and tepid water temperature (60-100°F).

Types of flushing equipment

Equipment	Use case	Flush time	Notes
Plumbed eyewash station	Fixed chemical handling areas	15 min continuous	Preferred for permanent installations
Portable eyewash unit	Remote or temporary worksites	15 min (self-contained)	Must be refilled/recharged regularly
Personal eyewash pods	Supplemental / immediate response	Seconds only	Not a substitute for a full station per ANSI Z358.1
Combination shower/eyewash	Full-body and eye exposure risk	15 min continuous	Required where full-body drenching is possible
Drench hose	Supplemental flushing for specific body areas	15 min continuous	Can supplement but not replace eyewash or shower

For mobile jobsites like roof coating crews, portable eyewash pods provide immediate response capability. However, if the SDS for the coating material specifies "flush for 15 minutes," you also need access to a full eyewash station or plumbed water supply within the 10-second travel distance. See our Roof Coating PPE & First Aid Kit guide for portable eye wash options.

Response Time

OSHA does not specify exact response times in the regulation, but enforcement history and Letters of Interpretation provide clear guidance. The threshold depends on the hazard level at the workplace.

Hazard Level	Examples	Expected Response	On-site First Aid Required?
High hazard	Construction, chemical processing, logging, roofing	3-4 minutes	Yes, trained personnel + supplies
Moderate hazard	Warehouses, light manufacturing, food processing	5-10 minutes	Yes, unless hospital is very close
Low hazard	Offices, retail, professional services	Up to 15 minutes	Only if no medical facility nearby

These thresholds come from OSHA's 1989 rulemaking preamble and subsequent enforcement guidance. If EMS cannot reach the worksite within the applicable window, the employer must have trained first aid providers and supplies on-site.

Hazard Assessment

Because 1910.151 is performance-based, the hazard assessment is the foundation of compliance. Employers must evaluate their workplace to determine what first aid provisions are needed. OSHA expects this assessment to consider:

Types of injuries and illnesses likely to occur (cuts, burns, chemical exposure, falls, heat stress)
Number of employees on each shift and their distribution across the facility
Distance and travel time to the nearest hospital or clinic
Chemicals used or stored on-site (check SDS Section 4: First-Aid Measures)
History of workplace injuries and near-misses
Remote or multi-level work locations where standard EMS access is limited

Best practice: Document the hazard assessment in writing and review it annually or whenever processes change. While OSHA does not explicitly require written documentation for 1910.151, a written assessment is your primary defense during an inspection.

Section (a) of the regulation allows employers to consult with a physician to determine appropriate first aid measures. For workplaces with complex chemical hazards, a physician review of the SDS library and injury history can help justify the specific kit contents and training program.

Training Requirements

Section (b) requires "a person or persons shall be adequately trained to render first aid" when the workplace is not near a medical facility. OSHA considers the following to meet the training requirement:

American Red Cross first aid and CPR/AED certification
American Heart Association first aid training
National Safety Council first aid programs
Equivalent training programs with hands-on skills assessment

Training must be current. Most certifications are valid for two years. Employers should ensure at least one trained person is present during all work shifts. For larger facilities, OSHA expects proportional coverage so that a trained responder can reach any injured worker within minutes.

Bloodborne pathogens overlap

Employees designated as first aid responders are covered by OSHA's Bloodborne Pathogens standard (29 CFR 1910.1030). This means designated responders need BBP training, hepatitis B vaccination offers, exposure control plans, and access to PPE (gloves, face shields). First aid kits should include at least two pairs of exam gloves per ANSI Z308.1.

Industry-Specific Standards

OSHA 1910.151 applies to general industry. Several other OSHA standards impose first aid requirements for specific industries, often with stricter provisions.

Standard	Industry	Key Differences from 1910.151
29 CFR 1926.50	Construction	Requires first aid kit per ANSI Z308.1 (not optional), one per 25 workers at remote sites
29 CFR 1910.266	Logging	Specific first aid kit contents listed in the standard, 20-unit minimum, must be carried on equipment
29 CFR 1910.269	Electric power generation/distribution	CPR/first aid training mandatory for field crews, specific burn treatment requirements
29 CFR 1926.1153	Silica in construction	Medical surveillance for exposed workers, not first aid kits directly, but intersects with PPE and first aid planning

If your workplace falls under multiple standards, the more specific or stringent requirement applies. Construction employers should follow 1926.50 rather than 1910.151.

Documentation and Recordkeeping

While 1910.151 does not explicitly mandate written documentation, several related requirements create a documentation trail that OSHA inspectors review:

Training records: Current first aid/CPR certifications for designated responders (typically required to be maintained for duration of employment)
Kit inspection logs: Monthly check showing supplies are stocked, sealed, and not expired
Hazard assessment: Written evaluation of workplace hazards driving your first aid program design
Injury logs: OSHA 300/300A logs (required separately under recordkeeping rules) help demonstrate whether your first aid provisions match actual incident patterns
Eyewash inspection records: Weekly activation test and annual plumbing inspection per ANSI Z358.1

Inspection tip: When OSHA visits, the compliance officer will ask to see your first aid kits, check expiration dates, and ask who on shift is trained. Having documentation ready avoids a situation where you are compliant in practice but cannot demonstrate it.

Enforcement and Citations

OSHA compliance officers evaluate first aid preparedness during routine inspections, complaint investigations, and fatality/catastrophe follow-ups. Common citation scenarios for 1910.151:

Violation	Typical Classification	Penalty Range (2024)
No first aid supplies on-site	Serious	Up to $16,131 per violation
No trained first aid personnel	Serious	Up to $16,131 per violation
Expired or depleted kit contents	Other-than-serious	Up to $16,131
No eyewash where corrosives are used	Serious	Up to $16,131 per violation
Willful or repeat violation	Willful	Up to $161,323 per violation

Penalty amounts are adjusted annually for inflation. The amounts above reflect 2024 maximums. Actual penalties depend on employer size, good faith, violation history, and gravity of the hazard.

Frequently Asked Questions

Does every workplace need a first aid kit?

Not technically. 1910.151(b) only requires first aid supplies when the workplace is not in "near proximity" to a medical facility. In practice, virtually every workplace needs one because relying on a nearby hospital does not satisfy the need for immediate wound care, and OSHA inspectors expect to see supplies on-site.

What size first aid kit do I need?

ANSI Z308.1 Class A kits are sufficient for most low-risk workplaces with under 25 employees. Class B kits are recommended for higher-risk environments or larger workforces. For construction sites, 29 CFR 1926.50 requires at least one kit per 25 workers.

How often should first aid kits be inspected?

OSHA does not specify a frequency, but ANSI Z308.1 recommends checking kits at least every 3-6 months. Monthly inspections are a common best practice. Replace any used, expired, or damaged items immediately.

Do remote or mobile jobsites need first aid supplies?

Yes, and the need is more acute. Remote sites are by definition not in "near proximity" to medical facilities, which triggers both the trained personnel and adequate supplies requirements. Roofing crews, utility workers, and construction teams in remote areas should carry portable kits and eyewash.

Are AEDs (automated external defibrillators) required?

OSHA 1910.151 does not require AEDs. However, OSHA has stated that providing an AED is a recommended best practice, and some state OSHA plans and local codes do require them in certain occupancies. An AED combined with CPR-trained personnel significantly improves cardiac arrest survival rates.

What OSHA training is required for workplace first aid?

OSHA 29 CFR 1910.151(b) requires employers to have personnel trained in first aid available at the workplace when there is no nearby medical facility. OSHA does not specify a particular certification provider, but accepts training from organizations like the American Red Cross, American Heart Association, and National Safety Council. First aid certification typically requires renewal every two years. For a detailed guide to setting up a workplace training program, see the workplace first aid training requirements guide on FireProtectionPro.com.

Does OSHA require CPR training for employees?

OSHA does not require all employees to hold CPR certification, but 29 CFR 1910.151(b) requires that trained first aid personnel be available. OSHA recommends that first aid training include CPR and AED (automated external defibrillator) instruction. Many OSHA first aid compliance training programs bundle first aid, CPR, and AED into a single certification course.