Medical Services and First Aid

Medical Services and First Aid is OSHA's general industry standard, 29 CFR 1910.151, that requires employers to make sure injured workers can get prompt care. It requires access to medical advice, trained first aid providers and supplies when professional care is not close by, and emergency eyewash and drench facilities where corrosive materials are used.

The standard is short, only three paragraphs, but it applies to nearly every general industry workplace. Because its key terms are not defined in numbers, employers rely on OSHA's interpretations and consensus standards to decide what adequate first aid coverage looks like at each site.

What Is OSHA 1910.151?

29 CFR 1910.151 sits in Subpart K, Medical and First Aid, of OSHA's general industry standards. It has three requirements and one non-mandatory appendix:

• 1910.151(a), medical personnel. The employer must ensure medical personnel are readily available for advice and consultation on matters of plant health.
• 1910.151(b), first aid. If there is no infirmary, clinic or hospital in near proximity to the workplace that can treat all injured employees, a person or persons must be adequately trained to render first aid, and adequate first aid supplies must be readily available.
• 1910.151(c), corrosive materials. 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 must be provided within the work area for immediate emergency use.
• Appendix A (non-mandatory). Guidance on first aid kit contents, referring to ANSI Z308.1 as an example of minimal contents for small worksites.

What "near proximity" means

The standard does not define near proximity in minutes. In a 2007 letter of interpretation, OSHA restated its long-standing view that where serious accidents such as falls, suffocation, electrocution or amputation are possible, emergency care must be available within no more than 3 to 4 minutes if no employee on site is trained in first aid. OSHA said a response time of up to 15 minutes may be reasonable in lower-risk workplaces such as offices.

In practice, most employers cannot guarantee that an outside ambulance or clinic will reach an injured employee within 3 to 4 minutes, so they train on-site first aid providers.

Who Must Comply?

1910.151 applies to employers covered by OSHA's general industry standards in Part 1910. There is no employee-count threshold, so a small shop and a large plant are both covered. Construction employers follow a parallel rule at 29 CFR 1926.50.

Several other OSHA standards contain their own first aid or CPR requirements that go beyond 1910.151. OSHA has identified examples including permit-required confined spaces (1910.146), logging (1910.266), electric power generation, transmission and distribution (1910.269) and electric power work in construction. Employers in those operations must meet both the general rule and the specific one.

In states with OSHA-approved state plans, the state's first aid rules apply and may be more specific than the federal standard.

Key Requirements

Access to medical advice

Paragraph (a) does not require an on-site physician. Most employers meet it by arranging access to an occupational health clinic, a contracted physician or nurse, or a nearby hospital that can advise on workplace health questions.

Trained first aid providers

Where professional care is not in near proximity, the employer must have one or more people adequately trained to render first aid. The standard does not name a specific course or certifying body, and OSHA does not certify first aid programs. Training should match the hazards at the site, which is why a fabrication shop with amputation hazards needs a different level of preparedness than an office.

Plan for coverage on every shift and in every work area. A single trained person on day shift does not cover the night crew or a remote warehouse.

First aid supplies

First aid supplies must be adequate and readily available. Appendix A points to ANSI Z308.1, Minimum Requirements for Workplace First-aid Kits, as an example of minimal contents for a small worksite. Larger or multiple operations may need more kits and additional supplies. OSHA suggests employers assess their specific needs periodically, using sources such as the OSHA 300 log and 301 forms or advice from local emergency services and medical providers.

Where employees may be exposed to blood or other potentially infectious materials while giving first aid, the Bloodborne Pathogens Standard applies, and the employer must provide personal protective equipment such as gloves, face shields and masks.

Eyewash and drench facilities

Paragraph (c) applies wherever employees may be exposed to injurious corrosive materials, such as strong acids and bases. The facilities must be suitable, allow quick drenching or flushing and be located within the work area. OSHA has not adopted ANSI Z358.1, the consensus standard for emergency eyewash and shower equipment, but OSHA has said it refers employers to it as guidance and considers it when judging whether protection is adequate. Use the chemical's safety data sheet to confirm whether a substance is corrosive.

Training and Inspection Practices

1910.151 does not set a refresher training interval or require written records. OSHA's 2023 interpretation confirmed that OSHA does not mandate a refresher frequency, while noting that its Best Practices Guide recommends instructor-led CPR and AED retraining at least annually. Many employers follow the certification period of their training provider.

Good practice includes:

• Keeping a list of trained first aid providers by shift and location, with certification expiry dates.
• Inspecting first aid kits on a set schedule and restocking after each use.
• Activating and inspecting eyewash stations regularly, following manufacturer instructions and ANSI Z358.1 guidance.
• Posting emergency numbers and the site address so anyone can direct responders.

First aid records can count as employee medical records under OSHA's rule on access to employee exposure and medical records, although records of minor, one-time first aid kept separately have no fixed retention period.

Common Compliance Mistakes

• Assuming 911 is enough. Relying on outside responders without checking whether they can arrive in time for the hazards at the site.
• Gaps in coverage. Trained providers on one shift only, or certifications that have lapsed.
• Empty or outdated kits. Supplies used and never replaced, or kits locked where employees cannot reach them.
• Missing or blocked eyewash stations. No eyewash near a battery charging area or chemical transfer point, or stations obstructed by stored materials.
• Relying on squeeze bottles alone. Small personal eyewash bottles hold a limited amount of fluid, so check whether they can provide the quick, thorough flushing the hazard calls for.
• No BBP protection. First aid providers without gloves, training or exposure procedures.

OSHA adjusts maximum penalty amounts each year; see OSHA's penalties page for current figures.

How to Comply: Step by Step

1. Map response times. Determine how long it takes outside emergency care to reach each work area on each shift.
2. Assess hazards. Identify where serious injuries such as amputations, falls or electrocution could occur, and where corrosive materials are handled.
3. Decide on coverage. If care is not in near proximity, designate enough trained first aid providers to cover every shift and area.
4. Train and certify. Use a recognized first aid and CPR course matched to your hazards, plus bloodborne pathogens training for designated responders.
5. Stock supplies. Provide kits based on ANSI Z308.1 and your site's needs, and place them where they can be reached quickly.
6. Install eyewash and drench equipment. Place units within the work area wherever corrosives are used, and keep the path clear.
7. Inspect and restock. Check kits and eyewash stations on a schedule and record the results.
8. Review after incidents. Use each injury or near miss to confirm that first aid response worked as planned.

How SMS360 Helps

SMS360's Compliance Management module helps teams turn first aid obligations into scheduled, tracked tasks. Safety managers can set recurring checks for first aid kits and eyewash stations, assign them to owners at each site, collect results on digital checklists and follow up on missing supplies with corrective actions.

Dashboards show which locations are overdue, and training records with expiry reminders make it easier to keep enough certified first aid providers on every shift.

Frequently Asked Questions

Does OSHA require first aid kits in the workplace?

Yes, where first aid supplies are needed under 1910.151(b), they must be readily available. OSHA does not prescribe exact contents, but its non-mandatory appendix points to ANSI Z308.1 as an example of minimal contents for small worksites. Employers should add supplies based on the specific hazards at their site.

How close does medical care need to be to avoid training first aid providers?

OSHA interprets near proximity to mean emergency care within 3 to 4 minutes where serious injuries are possible. Up to 15 minutes may be reasonable in low-risk workplaces such as offices. If outside care cannot reliably arrive within that time, the employer needs trained first aid providers on site.

How often must first aid and CPR training be renewed?

OSHA does not set a mandatory refresher interval in 1910.151. OSHA guidance recommends instructor-led CPR and AED retraining at least annually, and most training providers issue certificates valid for a fixed period. Keeping certifications current is the simplest way to show providers remain adequately trained.

When is an eyewash station required?

An eyewash or drench facility is required wherever the eyes or body of any person may be exposed to injurious corrosive materials. It must provide quick flushing and be located within the work area for immediate use. OSHA uses ANSI Z358.1 as guidance on equipment performance and placement.