The OSHA general industry rule on first aid kits is one sentence. Under 29 CFR 1910.151(b), "adequate first aid supplies shall be readily available." There is no mandatory contents list, no number of kits per employee and no inspection interval. A non-mandatory appendix, a few OSHA letters of interpretation and some industry rules fill those gaps. This article covers what the standard requires, what "adequate" and "near proximity" mean, what goes in the kit, and how often to check it.
A note on scope: this is the federal OSHA general industry standard, with the construction, logging and electric power rules noted where they differ. States with OSHA-approved plans can set different requirements, and nothing here is legal advice.
The section has three paragraphs.
Note that the trained person depends on whether care is in near proximity; the supplies do not.
The standard gives no distance or time. OSHA's letters do. In a March 23, 2007 letter, quoting one from January of that year, OSHA wrote that "while the first standards do not prescribe a number of minutes, OSHA has long interpreted the term 'near proximity' to mean that emergency care must be available within no more than 3-4 minutes from the workplace."
The same letter ties the figure to the hazards: "in workplaces where serious accidents such as those involving falls, suffocation, electrocution, or amputation are possible, emergency medical services must be available within 3-4 minutes, if there is no employee on the site who is trained to render first aid." Where serious injuries are less likely, such as offices, "a longer response time of up to 15 minutes may be reasonable."
A June 19, 2019 letter adds that "these time limits are maximums," and that "a response time of less than three minutes would likely require on-site trained first aid employees at every work site." OSHA "recommends, but does not require, that every workplace include one or more employees who are trained and certified in first aid, including CPR."
A site that cannot be sure outside care arrives within 3 to 4 minutes needs trained people on every shift, with kits close to the work.
Appendix A to 1910.151 is titled "First aid kits (Non-Mandatory)." It opens by repeating that supplies "are required to be readily available under paragraph § 1910.151(b)," then says "an example of the minimal contents of a generic first aid kit is described in American National Standard (ANSI) Z308.1-1998 'Minimum Requirements for Workplace First-aid Kits.'" Those contents "should be adequate for small worksites."
For anything bigger, the appendix puts the decision on the employer:
The 2019 letter addresses the newer edition of the ANSI standard. It describes ANSI Z308.1-2015 as recommending "Class A kits, which are minimum kits for workplaces, and Class B kits, which are for workplaces with a high risk for severe injuries," with tourniquets in Class B. OSHA's reading of "adequate first aid supplies" for bleeding control is that general industry workplaces "must have the items for bleeding control listed for Class A kits, unless the workplace has a high risk of serious injuries, in which case the items listed for Class B kits, including tourniquets, are required."
The same letter says OSHA "strongly recommends that industries where amputations are likely use Class B kits," and that Class B kits "are strongly recommended for the construction industry."
The appendix also carries a requirement from another standard. If employees may reasonably be exposed to blood or other potentially infectious materials while using first aid supplies, "employers are required to provide appropriate personal protective equipment (PPE)" under the bloodborne pathogens standard, 1910.1030(d)(3), such as "gloves, gowns, face shields, masks, and eye protection." OSHA's advisory first aid best practices guide (publication 3317) adds that "an automated external defibrillator (AED) should be considered when selecting first-aid supplies and equipment."
1910.151 sets no interval. Other OSHA rules do, and they show what OSHA expects where it has written it down:
The common thread is that used items get replaced before the kit is needed again. OSHA's guide advises giving "a specific person the responsibility for choosing the types and amounts of first-aid supplies and for maintaining these supplies." A scheduled check, plus a check after every use, does that. The first aid kit inspection checklist is set up for a monthly check and after each use: the kit's location and condition, the contents, the earliest expiry date, what was used since the last check, and a restock result.
The 2019 letter says "OSHA does not certify first aid training programs, instructors, or trainees." It points to a 1978 agreement with the American Red Cross, still in effect, under which "the American Red Cross Standard Course is the recommended MINIMUM level of first-aid training," and says that to be adequately trained a first aider "shall be trained in accordance with the 2015 AHA/ARC Guidelines," which cover direct pressure, hemostatic dressings and tourniquets for bleeding control. OSHA's first aid programs page suggests basic adult CPR retesting every year and a review of first aid skills every three years.
The kit's contents also line up with recordkeeping. Under 1904.7(b)(5)(ii), "first aid" includes cleaning or flushing surface wounds, "using wound coverings such as bandages," hot or cold therapy, non-rigid supports such as elastic wraps, eye patches, finger guards, and removing splinters by simple means, and paragraph (b)(5)(iii) says the list is complete. First aid alone does not make a case recordable on the OSHA 300 log, so a note of what was used from each kit is often the only record of those minor injuries, and Appendix A asks you to use your injury reports to decide what the kits need.
A paper tag inside the lid works until someone takes the last burn dressing and nobody notices for a month.
The same approach covers the rest of a site's safety checks: safety inspections that get done.
If your sites keep kits alongside eyewash stations, extinguishers and spill kits, see how Vardian handles safety inspections and corrective action: a scan at each kit, the contents check as a form, items used logged by location, and a missing item that becomes a restock request.
Bring a round, an inspection or a maintenance process to a demo, and we'll show how it runs in Vardian.
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