June 02, 2011 at 5:15 PM

Update on Medical Services and First Aid Requirements for Industrial Facilities

The regulatory standard on First Aid is subject to interpretation.  We’ve consolidated many of the key official agency Letters of Interpretation in this update. 

First Aid Requirements

Industrial facilities of any size are required to have personnel on-site trained in first aid and provide adequate First Aid supplies unless they are located within 3-4 minutes of a hospital or emergency medical facility.  “The employer shall ensure the ready availability of medical personnel for advice and consultation on matters of plant health”, where “plant health” means the overall safety and health condition of employees in the plant.    

Serious injuries such as those involving stopped breathing, cardiac arrest, or uncontrolled bleeding, may result in permanent damage or even death if first aid is not provided within the first few minutes.   Therefore, in workplaces where serious accidents such as those involving falls, suffocation, electrocution, or amputation are possible, medical service must be available within 3-4 minutes.  In workplaces where serious work-related injuries are less likely, OSHA may allow a response time of up to 15 minutes. 

NOTE: Facilities which use local emergency medical services to meet the First Aid requirement, must consider travel (even during peak hours) when calculating the time of arrive for medical personnel.

CPR Training

OSHA recommends that CPR be included in a first aid program.  However, some OSHA standards have specific requirements that employees be trained in first aid and CPR.  These include:

• Permit Required Confined Spaces
• Electric power generation, transmission, and distribution (includes work on exposed lines or equipment of 50 volts or more)

NOTE: OSHA does not require automated external defibrillation (AED)’s be available at the worksite at this time, but in light of the increased availability of AEDs for use in public and private facilities, workplaces, and homes, OSHA plans to add AED training in the near future in the form of a "best-practices guidelines”.

First Aid Kits

First aid supplies are required to be readily available / accessible and supplies should be selected by a person competent in first aid and knowledgeable of the hazards found in the specific workplace. First Aid kits should be regularly inspected to ensure that they full, in good condition, and contents have not expired.

Minimum requirements per ANSI Z308.1-1998 include:

• Absorbent Compress, 32 sq. in. (No side smaller than 4")- 1
• Adhesive Bandages, 1" x 3"- 16
• Adhesive Tape, 5 yd. - 1
• Antiseptic, .5g application- 10
• Burn Treatment, .5g application- 6
• Medical Exam Gloves- 2 pair
• Sterile Pads, 3" x 3"- 4
• Triangular bandage, 40" x 40" x 56"- 1

Additional items may be needed to address specific workplace hazards.  Employers should assess the specific needs of their worksite periodically and augment the first aid kit appropriately.

Enhancements:

• Splints, backboard, burn gel, materials suggested by the MSDS
• Special materials on-site for an outside medical agency to use
• Multiple first aid kits throughout a large facility

NOTE: Over-the-counter medicine can be put in first aid kits if packaged in single dose, tamper-evident packaging and labeled as required by FDA regulations.

Eyewash and Shower Requirements

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.  There is no threshold quantity of corrosive material that triggers the eyewash or shower requirement!  Injurious corrosive chemicals / materials are identified on the Material Safety Data Sheet (MSDS) for each product. 

Quick Drenching / Flushing

OSHA has adopted no specific requirements regarding flow rates for drenching/flushing facilities. OSHA references Section 4.1 of ANSI Z358.1 as a guideline that specifies:

• Emergency shower heads shall deliver a minimum of 75.7 liters per minute (20 gpm) of flushing fluid for 15 minutes.  The velocity should be low enough to be non-injurious to the user.
• Plumbed & self-contained eyewash equipment shall deliver flushing fluid to both eyes of at least 1.5 L per min. (0.4 gpm) for 15 minutes.  For strong acid or caustic materials, the eye/face wash should be immediately adjacent to the hazard. 
• Eye/Face wash units shall deliver flushing fluid to both eyes of no less than 11.4 liters per minute (3.0 gpm) for 15 minutes. For strong acid or caustic, the eye/face wash should be immediately adjacent to the hazard.

Facilities shall also inspect at least annually and properly maintain per the manufacturer’s instructions flushing and eye/face wash stations and fluids, including:

• Plumbed and self-contained eye/face & shower equipment shall be constructed of materials that will not corrode in the presence of flushing fluid.

• Equipment shall be in accessible locations that require no more than 10 seconds to reach and shall be located on the same level as the hazard.
• Stored flushing fluid shall be protected against airborne contaminants.
• All eye/face and shower equipment shall deliver tepid flushing fluid (60 – 100° F) and be activated weekly for a period long enough to verify operation and ensure that flushing fluid is available.

For answers to these and other OSHA questions, additional information or to discuss training for your facility, please reply to this email, or contact Pete Schmidt of the Fairfax Compliance Group at pschmidt@fairfaxgrp.com or by calling (717) 880-5946.  

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