January 29, 2019

OSHA Requires Physician Approval of Workplace First Aid Kits

The California Occupational Safety & Health Administration (Cal/OSHA) regulation Title 8 CCR Section 3400 specifies that first-aid supplies must be made available to all employees on every job.

In paragraph (c) of this standard, it further states that a physician must approve the contents of a first-aid kit in the workplace, but does not go so far as to specify the exact contents of the kit. This requirement is often overlooked by an employer and has the potential of becoming a citation during inspections of the workplace in response to an accident or worker complaint as part of routine enforcement visits. 

A helpful suggestion to comply with the physician approval requirement included in this standard is to contact the occupational health clinic used for workplace injuries. On most occasions, the occupational health clinic will provide this service. Once a medical professional inspects the first-aid kit, a letter is created acknowledging that the workplace first-aid kit is adequate.

Section 3400 is not the most common citation issued nor does it have a high dollar penalty associated with it; however, it is an easily citable item for a Cal/OSHA inspector to write up. For a statistical reference, all industries during the period of October 2017 through September 2018 experienced five inspections resulting in citations involving Section 3400 totaling $18,145. While these are not staggering numbers, there has been an increase in penalties as a result of changes made by U.S. Occupational Safety and Health Administration in 2016. 

To avoid penalties for this standard, the following are useful guidelines and tips for workplace first-aid kits to be in compliance:

  • First-aid supplies must be adequate and made available to all employees on every job including after hours and weekends.
  • First-aid materials shall be kept in sanitary and usable condition preferably in a wall mounted cabinet or a mobile case or duffle bag.
  • Frequent inspections shall be made of all first-aid materials with particular attention to items with expiration dates.
  • First-aid materials shall be replenished as necessary.

As noted earlier, this Cal/OSHA standard does not specify the exact contents of a first-aid kit. For an example of an adequate first-aid kit, the American National Standards Institute created a guide listing minimum requirements found under code ANSI Z308.1-2015. Another source for minimum requirements for contents of a workplace first-aid kit can be found on the American Red Cross website.  

While most employers will purchase a well-stocked first-aid kit from a store or vendor, it is still required to have a physician’s approval to ensure against an inspector’s citation and associated penalties.

For more information, please contact Hilario Garcia at H[email protected] or (559) 650-7520