California Occupational Safety & Health Administration (Cal/OSHA) regulation 8 CCR § 1512 specifies that first-aid supplies must be made available to all employees. The standard requires: Where more than one employer is involved in a single construction project on a given construction site, each employer is responsible to ensure the availability of emergency medical services for its employees. The employers on the project may agree to ensure employee access to emergency medical services for the combined work force present at the job site. Such an emergency medical service program shall be adequate to service the combined work force present, but only one emergency medical program need be established at such site.
Paragraph (c) of the standard states that a physician must approve the contents of a workplace first-aid kit however it does not specify kit content requirements and is often overlooked by an employer. Also, medicine including those purchased over the counter (e.g. Advil) should not be in the first aid kit unless you have a physician’s approval for dispensing. First aid-kit non-compliance has the potential of becoming a citation during inspections of the workplace in response to an accidents or worker complaints. In addition to avoid penalties for this standard, the following are useful guidelines and tips for workplace first-aid kit compliance:
- First-aid supplies must be adequate and made available to all employees on every job.
- First-aid materials are to be kept in sanitary and usable conditions such as on a wall mounted cabinet, a mobile case or duffle bag.
- Frequent inspections are to be conducted to all first-aid materials with attention to items with expiration dates.
- First-aid materials are to be replenished as necessary.
The American National Standard Institute (ANSI Z308.1-2015), “Minimum Requirements for Workplace First Aid Kits” offers recommendations for an adequate first-aid kit. The majority of employers purchase a well-stocked first-aid kit from a store or vendor, but it is still required to have a physician’s approval.
Cal/OSHA regulation, 8 CCR § 1512(e) states, effective provisions are to be made in advance for prompt medical treatment in the event of serious injury or illness. According to the standard Provision for
Obtaining Emergency Medical Services: Proper equipment for the prompt transportation of the injured or ill person to a physician or hospital where emergency care is provided, or an effective communication system for contacting hospitals or other emergency medical facilities, physicians, ambulance and fire services, shall be provided. The telephone numbers of the following emergency services in the area shall be posted near the job telephone, telephone switchboard, or otherwise made available to the employees where no job site telephone exists:
- A physician and at least one alternate if available.
- Ambulance services.
- Fire-protection services.
Also be aware that when pertaining to emergency call systems the standard requires: A two-way voice emergency communication system must be installed for buildings and structures five or more floors or 48 feet or more above or below ground level, to notify persons designated in the emergency medical services plan. The location and condition of the employee must be able to be communicated over the system. The use of the construction passenger elevators for medical emergencies shall take precedence over all other use.
Bottom Line: An employer must have a written plan to provide emergency medical services. The plan should specify the means of implementing all applicable requirements. When employers form a combined emergency medical services program with appropriately trained persons, one written plan will be considered acceptable to comply with necessary regulations. Check with the general contractor at jobsites for implementation of emergency medical services.
Note: This information was provided by Tim Bormann, CIH, FAIHA, The Cohen Group