First aid is one of the most common workplace safety issues, yet employers’ obligations are often not as well known as they are for other safety regulations. So we decided it was time to present some typical questions received and answered by the experts at Safety.BLR.com®.
Q. How do you know if you need to have an eyewash station?
A. 29 CFR 1910.151(c) says: 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.
A good way to tell is to check the MSDS for the product.
Q. How often should a facility conduct an emergency shower/eyewash written inspection?
A. OSHA does not have specific requirements for emergency shower/eyewash written inspections. The following is from an OSHA letter of interpretation:
29 CFR 1910.151(c) does not provide specific instruction regarding the installation and operation of emergency eyewash and shower equipment. Therefore, it is the employer’s responsibility to assess the particular conditions related to the eyewash/shower unit, such as water temperature, to ensure that the eyewash/shower unit provides suitable protection against caustic chemicals/materials to which employees may be exposed.
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Q. Are there any specific OSHA requirements for on-site first-aid rooms, equipment, and/or personnel?
A. The OSHA regulation is as follows:
1910.151(b): In the absence of an infirmary, clinic, or hospital in near proximity to the workplace which is used for the treatment of all injured employees, a person or persons shall be adequately trained to render first aid. Adequate first aid supplies shall be readily available.
Near proximity usually means that medical personnel must be available in about 3 or 4 minutes. OSHA does not have any specific requirements for first-aid rooms or supplies. However, first responders should be trained in the bloodborne pathogens standard requirements.
Q. We maintain a first-aid locker with things such as pain relievers, antacids, band-aids, etc. What are the requirements for replenishing first-aid supplies?
A. The OSHA first-aid rule says "adequate first aid supplies shall be readily available" (29 CFR 1910.151). No way around that, and there’s no clear guidance from OSHA for handling excess depletion rates. Many companies deal with excessive depletion of popular items like aspirin by putting those supplies in high visibility areas where people know they’ll be seen taking something. This sometimes deters people from taking more than they need.
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Q. Does OSHA require us to offer and pay for the hepatitis B vaccination or get a declination? What are the medical recording responsibilities if we train all employees even if we do not require them to provide aid?
A. Only those designated by the employer to provide first aid (not all those who are trained) would be covered by the bloodborne pathogens standard and would require the protections of the standard including the hepatitis B vaccine. There are no medical recording responsibilities for training in first aid. There would be recording responsibilities for exposure to bloodborne pathogens.
This is an excerpt from an OSHA letter of interpretation:
The key to this issue is not whether employees have been trained in first aid, but whether they are also designated as responsible for rendering medical assistance. The standard does not necessarily apply to employees who are trained in first aid, but only to those employees who are required by the employer to actually administer first aid. Such employees are covered under the bloodborne pathogens standard, and [you are] required to write an exposure control plan as well as provide all other protections of the standard to them.
Tomorrow, we’ll continue with some more first-aid Q&As.
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Regarding the first-aid locker/depletion rate. What we did about a year ago was attach a First Aid Log book next to the locker. Only supervisors can take or use items from locker but the important part is that everything MUST be entered in log book for usage. This is not an inventory purpose. What this does is give me opportunity to see who has nix,s, scrape’s bruises and headaches and how frequent. I use this info during supervisor training as my book of ‘near misses’. Someone gets repeated use of pain pills, I open the door to check on them to see if they are needing other medical attention. Someone uses a lot of band aids, are they accident prone? It has worked for us.
The Bureau of Labor Statistics says that back injuries account for 1 in 5 workplace injuries/illnesses. Back problems also account for many lost workdays. Simple steps to care for the back can prevent injury.