California OSHA First Aid Kit Requirements Explained
What Is OSHA and What Are First Aid Kits?
The Occupational Safety and Health Administration, commonly referred to as OSHA, is a wide-reaching organization of the federal government that polices all manner of workplace safety and risk. While OSHA covers worker safety across all industries and hazardous situations, some areas of concern are given more specific regulations than others. Heavy industry, construction and transportation mediums, such as rail and trucking, among others, all have their own specific agencies, that although under the umbrella of OSHA, separately oversee their compliance.
In the state of California, one of the most commonly overlooked areas of OSHA oversight are those of stocked first aid kits. Most employers will provide their workers with stocked first aid kits, but in addition to providing these crucial supplies, they also must ensure that they are compliant with OSHA’s requirements. Under the General Industry Standards, 29 CFR 1910, Subpart K, "Medical and First Aid," there are some basic requirements of employers regarding the provision and maintenance of first aid kits .
Cal-OSHA, the California State Safety and Health Program, wihtin the California Department of Industrial Relations, enforces certain objectives in its "Section 3400 – Medical Services and First Aid" of Title 8, General Industry Safety Orders, which mirror the federal regulation of 29 CFR 1910.
In California, all employers in general industry are required to meet the OSHA regulation overtly requiring that each workplace be adequately stocked with first aid kits. A simple, one off, standalone incident, could result in fines upwards of $17,000 per cited item. Many employers ignore this responsibility because they maintain healthcare providers for their employees. This is an incorrect assumption. Although Section 3400 offers exceptions for the basic first aid kit compliance requirements to employers using injured workers’ compensation insurance, the primary, fundamental obligation of first aid kit maintenance remains the same, regardless of the injury event.
California-Specific OSHA Requirements for First Aid Kits
California has always been more strict than federal OSHA when it comes to safety equipment. California OSHA has its own set of standards to supplement the federal requirements, and regulations for first aid kits is no exception. The California regulations state that workplaces must be equipped with a first aid kit or first aid bandage and burn kit, where the following are present:
- (1) One 28-gauged, 2-inch by 2-inch sterile gauze pad.
- (2) Two medications for oral administration, such as antiseptic towelettes, eye wash, and burn spray or gel suitable for small second degree burns.
- (3) Three triangular bandages (wool or cotton material recommended, but not required).
- (4) One first aid manual or equivalent instruction book.
- (5) 16 antiseptic, steam packed wipes.
- (6) One unit of sterile saline, 1-ounce minimum.
- (7) One 2-inch or larger splint made of materials such as wood, cardboard, metal, plaster, or other rigid material padded on one side and wrapped securely and taped together.
- (8) One barrier type resuscitation device (one way valve-type mask preferred) for the protection of the rescuer against the transfer of saliva, blood, vomit, and disease.
(b) Universal precautions shall be taken in treating all injuries. Each assigned first aid individual shall be required to have completed a Red Cross San Francisco Course in the administration of first aid, and/or have available at the work site a current, equivalent certification from a recognized first aid training program.
Compliant First Aid Kit Contents
In California, OSHA regulations require employers to maintain first-aid kits stocked to provide treatment for injuries that are likely to be sustained in the course of employment. In addition, if a workplace has a high-risk of exposure to blood borne pathogens in California, then OSHA also requires work shops to have first aid kits that are stocked to treat wounds that pose a risk for infection with blood borne pathogens. While there are different requirements based on the type of industry in which you work, below is a list of the essential contents of a compliant first aid kit:
• Sterile compress, not less than 4 inches x 4 inches with a minimum 10- pounds of pressure
• Triangular bandage
• Gauze pads, with assorted sizes from 2 inch x 2 inch to 7 inch x 8 inch
• Adhesive tape, 2 inches x 2 yards, disinfectant or antiseptic wipes
• Pair of scissors
• Forceps
• Tweezers
• Lens, not less than 1 inch in diameter with protector
• Roller bandage, 4 yards in length 2 inches in width
• Small package of assorted adhesive bandages
• 4 inch x 4 inch sterile dressing with minimum absorption capacity of 6 ounces
• 2 rolls of first aid adhesive or Hypo allergenic tape
• 2 pair of surgical gloves
• Burn-free or water based burn dressings, at least 4 inches x 4 inches
• An emergency blanket
• A CPR shield
• Antiseptic ointment
• An assortment of assorted sterile pads and sponges
• Antibiotic ointment
• A first-aid booklet
• Instant ice packs
• An assortment of sterile gauze pads
• An assortment of assorted-sized adhesive bandages
• Sterile gauze rolls
• A topical antiseptic
• A first-aid numbers kit
In addition to the items listed above, the Federal Department of Labor has a recommended list of first aid kit supplies for compliance with both Federal OSHA rules (which apply in all states except California, Oregon, and Washington) as well as California OSHA rules:
• Sterile adhesive bandages in assorted sizes
• Sterile compress dressing, 4 x 4 inches, with 4 in x 4-inch attached ties
• Roller bandages of each of the following sizes:
• 2-inch wide – 6 yards long
• 3-inch cut – 5 yards long
• 4-inch cut – 4 yards long
• Gauze pads, sterile, in assorted sizes, 3 x 3 inches to 8 x 10 inches in
• Eye dressing, either removable lens or one-piece lens
• Two triangular bandages
• 1 package of gauze roller bandage, 4 inches wide, approximately 10 yards long
• 1 first aid tape, 1 inch wide (If tape containing salicylic acid is used to treat warts, tape containing oil of wintergreen or methyl salicylate should not be used.)
• 2 large and 4 medium, individually wrapped antiseptic towels
• 1 package each of assorted sizes of safety pins
• 4 antiseptic towelettes – 10 x 12 inches, at least 70% isopropyl alcohol
• 1 eye/face shield
• 1 box, assorted sizes of adhesive bandages
• 1 sterile flotation eye patch
• 2 azet catlin-brown immobilizers or 5 triangular bandages add 5 safety pins for each
• 2 4 x 4-inch sterile abdominal pads
• 2 6 x 8-inch sterile abdominal pads
• 1 card contains the following:
• Acetylsalicylic acid (aspirin) – 2 each tablet 325 mg
• Oral anti-diarrhea drug – 12 each tablet 3.5 g
• Diphenhydramine hydrochloride (Benadryl, Unisom) – 1 each tablet 25 mg
• Diphenhydramine HCL liquid – 1 bottle 4 ounce
• Loperamide hydrochloride capsules (Imodium) – 5 each dosage 2 mg
• Loperamide hydrochloride caplets (Imodium) – 5 each dosage 2 mg
• Lactase enzyme (Lactaid) – 2 each tablet 3,000 FCC units
• Bisacodyl (Dulcolax) – 2 each tablets 5 mg
• Diphenoxylate hydrochloride/Atropine sulfate (Lomotil) – 10 each tablet 2.5mg/0.025 mg
• Ibuprofen (Advil, Motrin) – 5 each tablet 200 mg
• Acetaminophen caplets (Tylenol) – 10 each tablets 500 mg
• Diphenhydramine hydrochloride (Benadryl, Unisom) – 15 each tablet 25 mg
• Calcium carbonate (TUMS) – 30 each tablet 1,250 mg
• Simethicone (Gas-X, Mylanta) – 6 each tablet 80 mg
• Docusate sodium (Colace) – 6 each capsule/softgel 100 mg
• Docusate sodium/cenafate (Ducolax) – 6 each capsule/softgel 100 mg
• Pseudoephedrine (Sudafed) – 15 each tablet 60 mg
• Phenylephrine HCL (Sudafed PE) – 15 each tablet 30 mg
• Alertness red pills
• Pain relief red pills
• Oral rehydration salts
• Alcohol-based hand cleaner
• Water-based burn dressing (aqua gel)
• Antibiotic ointment
• 50 bandages per box with antiseptic
• 4 x 4 sterile gauze pads (10 pads)
• Injury/illness treatment kit
• Bandage scissors
• Eye patch
• Sunscreen
• Gauze rolls
• Miscellaneous bandages and dressings
• Triangular bandages
• 50 antiseptic wipes per box
• 14" x 5′ "plastic strip" adhesive tape
• Burnshield or similar
• Sterile saline in pouch.
• First aid manual
Employer Responsibilities Under OSHA Requirements
Employers in California are responsible for ensuring their workplaces are safe and healthful for their employees. This encompasses a wide range of obligations, including those related to first aid kit requirements. Under California OSHA regulations, employers are required to keep first aid kits properly stocked and readily available to their employees. This requirement is part of the larger obligation to provide medical and first aid services and supplies.
Keeping a well-stocked first aid kit is essential for treating minor injuries and stabilizing more serious injuries until help can arrive. While the details of first aid kit requirements vary by industry and risk level, employers must evaluate the specific needs of their workplace and ensure that their first aid kits are equipped to meet those needs. Compliance with California OSHA first aid kit regulations not only helps protect employees from injuries, but it also makes sure employers meet the standards to qualify for first aid exemption under Cal/OSHA regulations.
Training and Accessibility
Training Requirements
California employers are required to provide employee training in the first aid practices employed at their workplace. The law states:
Most employers already meet the requirement to train employees in basic first aid because they have employees that are trained and certified in first aid and CPR. California does not have a regulatory requirement that at least one employee at a worksite maintain certification.
Accessibility of First Aid Kits
California requires employers to ensure accessibility to all first aid kits. However, "accessible" depends on the hazards associated with the industry within which the employer operates. According to the California Division of Occupational Safety & Health (Cal-OSHA):
"Safety or health personnel (qualified in first-aid and CPR) shall be immediately available to render first aid. The person(s) need not be on the site , but must be so nearby as to be able to reach the injured employee for immediate aid."
Therefore, most employers will ensure their first aid kit(s) are located at the site, or very near, to any potential hazard faced by the employees. The law also requires employees to have "first aid kits with regular inventory."
Inventory, Inspection and Restocking of First Aid Kits
The first aid kits must be stocked with first aid supplies appropriate to the workplace. California regulations require a "regular inventory" and must be kept "in usable condition and must be inspected periodically, at least monthly." Moreover, inventory of items within the first aid kit must be "made at least quarterly", meaning every three months. Employers must also ensure the first aid kit meets the requirements of any applicable federal agency, such as the U.S. Department of Transportation, if the requirements of such agency apply.
Pitfalls and How to Prevent Them
Employers have many obligations to protect their employees, and many of them are aimed at preventing employee injuries and deaths before they happen. However, accidents do happen and it is important that employers be prepared to do all they can to help their employees who get injured on the job. Despite being a good first step in injury prevention, there is actually a requirement for California businesses to maintain a first aid kit. What constitutes an adequate first aid kit under the California Occupational Safety and Health Administration (Cal/OSHA) regulations? How is a first aid kit to be used? What happens if an employer is found to be out of compliance in the event of an injury? What are some common mistakes employers make in understanding and determining how to become compliant with the Cal/OSHA first aid kit requirements? The common mistakes we have come across are time consuming, costly and are easily preventable by knowing the regulations! Here are some common mistakes and how to avoid them.
After the California Code of Regulations Section 3400 for confined space entry went into effect in 2015, employers became confused about whether their requirements for a first aid kit had changed. Under the confined space entry regulation, every employer is required to provide at least one first aid kit and it must be kept one quarter mile (1 mile / 4 = 0.25 miles) from the confined space location, or be otherwise immediately available. Cal/OSHA does not require employers with confined spaces to provide additional first aid kits, other than what would be required under the general regulations (see below).
Provided the first aid kit meets the requirements in subsection (b) of section 3406, employers will not be cited for non-compliance with the general industry first aid kit requirements in section 3400.
Under the general industry, regulations section 3400 requires employers that have more than five employees to maintain a first aid kit "adequate to render first aid to employees who may be injured at the place of employment." Common mistakes employers make include:
An adequate first aid kit is defined by the regulations to mean one that contains materials that would treat any employee who has been injured on the job. This requires employers to assess all the possible injuries employees could face in a given workplace. What types of injuries does your workplace expose your employees to? What de minimis injuries occur on a fairly regular basis? These should be considered when determining what an adequate first aid kit would contain.
Under the general industry, section 3400 does not define the right size of a first aid kit. Instead, it only requires that employers replace materials that are used so that the kit remains adequate as required by subsection (a). A compliance inspector will likely only check to see if the first aid kit contents match those described in the table under section 3400.
Employers are required to ensure that employees know the location of every first aid kit at an individual workplace. A common mistake employers make is failing to notify employees. Compliance inspectors will quickly look at records kept by the employers to verify compliance with the notification requirements. In addition, inspectors will determine if the kit is visible and easily accessible within 15 minutes of the location of hazards.
Penalties for Not Complying with OSHA Requirements
The implications of failing to comply with California OSHA first aid kit standards could result in fines and penalties for employers.
In California, employers are subject to civil penalties of $15,000 for failing to properly assess hazardous work areas. In addition, carriers that willfully violate the regulations could face criminal sanctions of up to $10,000 and one year in prison for each offense. Sometimes the penalties accrue on a daily basis. Civil penalties are assessed after a notice of citation has been issued. If serious violations persist after an abatement notice has been issued, penalties of up to $100,000 may be assessed. If a workplace injury occurs and the employer did not have a California OSHA-compliant first aid kit, the employer can be held liable for medical bills or temporary disability payments related to injuries to employees if they occurred because the employer failed to comply with regulations. If a business does not have an OSHA-compliant safety program, and an employee takes the employer to court because they were injured by a workplace hazard, the employer could be subject to hefty liability payments, and could lose the case in litigation.
Conclusion and Best Practices
Successful workplace safety programs include effective first aid and injury prevention components. The regulations discussed above provide a baseline for what employers should have in their first aid kits. But as we all know, while the bleeding may have stopped, the damage may have been done by the time the first aid kit is located within the company and brought to the scene . A better plan is to ensure that every employee knows where it is located and that all supervisors, managers, and safety staff periodically inspect the workplace for first aid kit contents and maintain adequate first aid kits throughout the facility. Beyond the required basic first aid kit, employers should consider having first aid kits onsite appropriate to the following processes or locations: The above examples are not a comprehensive list, but serve as a good jumping off point to consider the needs of your facility and employees.