What OSHA Requires for First Aid at a Small Shop
Why this matters
Most small shops assume first aid is covered because there is a kit in the van. The federal rule asks for more than a kit: it asks whether a trained person is available to an injured worker within minutes, whether the supplies fit the work, and whether there is a way to flush the eyes and body of anyone working with corrosives. A crew of two in a county where the ambulance takes fifteen minutes is in a different position from the same crew a mile from a hospital, and the rule is written around exactly that difference.
This card owns the legal floor. It covers what the federal standards say, how OSHA has read them, and what they mean for crews that move to a new address every few hours. The kit's contents, eyewash setup and training choices each have their own card. This is not legal advice; the point at which you need an attorney or a consultant is named below.
Two standards, split by the work, not the company
A field-service shop can fall under either of two federal first-aid standards, and often both in the same week:
- 29 CFR 1910.151, general industry, reaches service, maintenance and repair work that is not construction: a furnace tune-up, a drain clearing, an appliance repair, a pool service visit.
- 29 CFR 1926.50, construction, reaches construction work, which Part 1926 defines to include alteration and repair, painting and decorating: a reroof, a bathroom remodel, a service change, a new duct system.
The split follows the activity on that job, not the shop's trade or whether the building is a house. A shop that does both works to the stricter of the two, which is usually 1926.50 because it is more specific.
What the general-industry rule says
1910.151 is three short paragraphs:
- (a) The employer ensures medical personnel are readily available for advice and consultation on plant health. For a small shop this is usually an occupational clinic or the provider your workers' compensation carrier names.
- (b) In the absence of an infirmary, clinic or hospital in near proximity to the workplace, a person or persons must be adequately trained to render first aid, and adequate first aid supplies must be readily available.
- (c) 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 must be provided within the work area for immediate emergency use.
The text does not define "near proximity" or "adequately trained". OSHA has filled both in through interpretation letters, and those letters, not the rule text, are where the numbers come from.
What the construction rule adds
1926.50 says the same things in more detail, and four of its paragraphs change what a crew carries:
- (c) Where no infirmary, clinic, hospital or physician is reasonably accessible in terms of time and distance, a person with a valid first-aid certificate from the American Red Cross or equivalent training that can be verified by documentary evidence must be available at the worksite. That is a certificate, not "someone who knows first aid".
- (d) First aid supplies must be easily accessible, and kits must be in a weatherproof container with individually sealed packages, checked before being sent out on each job and at least weekly to replace what was used.
- (e) There must be proper equipment to transport an injured person to care, or a communication system to contact an ambulance service. For most crews that is a working phone with signal at the site.
- (f) In areas where 911 is not available, the telephone numbers of the physicians, hospitals or ambulances must be conspicuously posted.
Paragraph (g) repeats the corrosive-materials flushing requirement.
How OSHA reads "near proximity"
OSHA's interpretation letters have read near proximity, and the construction rule's "reasonably accessible", in minutes, not miles. Where injuries that threaten life can occur, such as severe bleeding, stopped breathing or electrocution, the letters point to a response of three to four minutes. Where serious accidents are unlikely, as in an office, they have accepted up to about fifteen minutes.
Two consequences follow, and they are the part of this card most shops get wrong:
- An ambulance is not "near proximity" by default. Emergency medical response in many suburbs and nearly all rural areas runs well past four minutes. A crew doing work that can produce a life-threatening injury, which covers most electrical, roofing, ladder and power-tool work, should assume it needs its own trained person on site.
- The test is time to the injured worker, crew by crew. A trained office manager at the shop does nothing for a crew forty minutes away. Each crew that does hazardous work needs its own.
The gap no regulation fills is the solo technician. A trained tech who is the one injured cannot treat himself if unconscious. The answer to that is a check-in and lone-worker plan, not a second certificate. See related: Working Alone: Staying Safe When No One Is Watching.
The corrosives requirement, for crews in the field
"Corrosive materials" here means substances that destroy tissue on contact: acid and caustic drain openers, many coil and descaling cleaners, battery electrolyte, pool acid and some pool chlorine products, wet concrete and mortar. The SDS (safety data sheet) for each product says whether it is corrosive in sections 2 and 8.
OSHA has looked to ANSI/ISEA Z358.1, the consensus standard for emergency eyewash and shower equipment, to judge what "suitable" means. The standard is not adopted into the federal rule by reference, so it binds you only as the yardstick an inspector uses, but in practice that yardstick is what counts. Its central figure is a flushing flow that can be sustained for 15 minutes, reachable within about 10 seconds of the hazard. A squeeze bottle does not deliver that, and is a supplement, not the facility. See related: How to Set Up and Maintain an Eyewash That Meets the Standard.
Which layer applies: federal and state
More than twenty states run their own OSHA-approved state plan for private employers, and a state plan must be at least as effective as the federal rules and is often more specific. California's General Industry Safety Orders, Title 8, section 3400, carry their own first-aid requirements, and Washington and Oregon write theirs into their own codes. If your state runs a plan, its rule is the one an inspector cites. Check your state agency's site before relying on the federal text alone.
Two neighboring federal rules attach to first aid and belong to their own cards. A worker designated to give first aid as part of their job is covered by the general-industry bloodborne pathogens standard, 29 CFR 1910.1030, which brings training and hepatitis B vaccination duties. See related: Bloodborne Pathogens and Helping a Bleeding Coworker. And whether an injury is "first aid" or recordable "medical treatment" for the OSHA 300 log is decided by 29 CFR 1904.7, which lists what counts as first aid.
A worked case: a twelve-person shop with five crews
A combined HVAC and plumbing shop runs five crews from one office. The owner sorts them against the rule:
| Crew | Work this month | Standard | Trained person on site | Eyewash need |
|---|---|---|---|---|
| A, HVAC service, 2 techs | Tune-ups, repairs | 1910.151 | Needed: electrical and ladder work | Coil cleaner is corrosive |
| B, HVAC service, 2 techs | Repairs, two system changeouts | Both | Needed | Coil cleaner |
| C, install crew, 3 | Duct and equipment replacement in a remodel | 1926.50 | Certificate required | None found in its SDS set |
| D, plumbing service, 2 | Drain and water heater calls | 1910.151 | Needed | Acid drain opener |
| E, drain tech, solo | Drain clearing, rural route | 1910.151 | Cannot be self | Acid drain opener |
The reasoning. The county publishes a median emergency response of about 9 minutes in town and over 20 on the rural routes (illustrative figures for this example; look up your own county's). Neither is three to four minutes, so the owner treats every crew doing hazardous work as needing its own certified person. For crews A through D that means one certified tech per crew, four people, plus the solo tech on crew E for five in all, with the install crew's certificate kept on file because 1926.50(c) asks for documentary evidence. Crew C is the one where the certificate is explicitly required, but the owner applies the same standard to all four rather than tracking which jobs were construction that week.
Supplies. All five vans carry a kit checked before each job and weekly, the construction rule's cadence, because crew B moves between the two standards inside a week.
Corrosives. Crews A, B, D and E handle corrosives. Each of those four vans gets a self-contained eyewash station meeting Z358.1, mounted where it can be reached in seconds from the work, not a squeeze bottle behind the seat.
Crew E. The solo tech is certified, but the rule's purpose is a responder for an injured worker. The owner adds a check-in plan with a defined call-back time and confirms the rural route has cell coverage, which is what 1926.50(e)'s communication requirement points at even on general-industry work.
What changes the answer. A crew working at a commercial site with an on-site clinic or medical team may satisfy near proximity through that. A state-plan state may require more, or name specific training. And a shop that stops using acid drain openers and corrosive coil cleaner removes the eyewash requirement for those vans, which is a legitimate way to comply and often the better one.
Where to stop and get help
Act on this card for planning. Bring in an attorney or a safety consultant when an inspector has opened an inspection or a citation has arrived, when you operate in a state-plan state and cannot tell which of its rules applies, or when a crew does work where your own hazard assessment is unclear. Walk in with the crew list above, the SDS set for each van, your county's response times and the training certificates on file.
References
- 29 CFR 1910.151, Medical services and first aid (general industry), and its nonmandatory Appendix A.
- 29 CFR 1926.50, Medical services and first aid (construction).
- OSHA standard interpretations on "near proximity" and first-aid response times; ANSI/ISEA Z358.1 for emergency eyewash equipment.
- 29 CFR 1910.1030, Bloodborne pathogens; 29 CFR 1904.7, first aid versus medical treatment.
- See related: The First-Aid Kit for a Service Van; How to Choose First Aid and CPR Training for the Crew.