What this is
When are trained first aiders required?
When are trained first aiders required?
Under 29 CFR 1910.151(b), where there is no infirmary, clinic or hospital in near proximity used for treatment of all injured employees, a person or persons must be adequately trained to render first aid, with adequate supplies readily available. The construction equivalent is 1926.50(c).
What does near proximity mean?
OSHA interprets it as a response time rather than a distance. Where accidents resulting in suffocation, severe bleeding or other life-threatening or permanently disabling injury are possible, three to four minutes from injury to first aid is required. Where such outcomes are remote, as in an office, up to fifteen minutes may be reasonable.
Scope
When is a first aid training required?
This records first aid training and currency. The needs assessment behind it is separate.
Use this template when
- Training and certifying first aiders for each shift and operation
- Recording site-specific additions: the substances, machinery and hazards present
- Tracking certification currency and scheduling refresher training
- Recording assessment of practical competence rather than attendance alone
- Reviewing after a change in shift patterns, staffing, site location or hazards
Do not use it for
- The first aid needs assessment, which determines how many first aiders and what provision is required
- First aid kit and equipment inspection, which checks supplies and their accessibility
- The first aid report, which records treatment given to an individual
- Bloodborne pathogens training, which is a separate requirement where exposure is anticipated
- Emergency response planning, which addresses site-wide scenarios
Compliance mapping
Which OSHA 1910.151 requirements does this satisfy?
First aid obligations are performance-based, with the interpretation supplying the numbers.
| Clause | Requirement | Where it lands |
|---|---|---|
| 29 CFR 1910.151(a) | Ready availability of medical personnel for advice and consultation on plant health matters | Header |
| 29 CFR 1910.151(b) | Persons adequately trained to render first aid where no facility is in near proximity, with adequate supplies readily available | Header |
| OSHA interpretation, near proximity | Three to four minutes response where serious injury possible; up to fifteen minutes where remote | Site specific additions |
| OSHA interpretation, bleeding control | Adequate training includes direct pressure, hemostatic dressings and tourniquets in certain situations | Assessment |
| 29 CFR 1926.50(c) | Construction equivalent, with a person trained to render first aid where no facility is near | Header |
| ANSI/ISEA Z308.1 | Class A kits for common injuries and Class B kits for workplaces with high risk of severe injury | Site specific additions |
| 29 CFR 1910.1030 | Bloodborne pathogens programme where employees may be exposed rendering aid | Currency |
| 29 CFR 1910.151(c) | Suitable facilities for quick drenching or flushing where corrosive materials are used | Site specific additions |
What it does not cover
- The first aid needs assessment, determining how many first aiders and what provision the site requires.
- Kit and equipment inspection, checking supplies, accessibility and expiry.
- The first aid report, recording treatment given to an individual.
- Bloodborne pathogens training, a separate requirement with vaccination and post-exposure elements.
- Emergency response planning, addressing site-wide scenarios rather than individual injury.
How to complete it
How to complete a first aid training, step by step
Measure the response time, cover the site's actual hazards, and check cover across every shift.
Time an emergency vehicle to the point of work at the hours you operate, including site access, gatehouse and finding the building. Record it, because that number determines whether trained first aiders are a requirement or a choice, and it is the evidence if the question is ever asked.
Generic first aid covers bleeding, burns, fractures and unresponsiveness. What it does not cover is the chemical on your site with a specific first aid measure, the machinery producing crush or amputation injuries, the confined space rescue interface, or the cold store. Section 4 of each safety data sheet is the source for the chemical additions.
OSHA's interpretation states adequate training includes direct pressure, hemostatic dressings and tourniquets in certain situations. Where the site has cutting, machinery or vehicle hazards capable of catastrophic bleeding, Class B kit contents and the training to use them are the proportionate provision rather than an enhancement.
The requirement extends to each shift and each operation. A site with fifteen trained first aiders can still have a night shift with none, or one who is on annual leave. Cover should be reported as the number of shifts with adequate cover rather than as a total, which conceals precisely the gap that matters.
What auditors find
Most common first aid training findings
First aid findings concentrate on cover, currency and content.
| Finding | Clause | What fixes it |
|---|---|---|
| Near proximity assessed from distance rather than measured response time. | 1910.151(b) | Time an actual response at operating hours; the test is minutes to treatment. |
| First aid cover reported as a headcount rather than by shift. | 1910.151(b) | Report shifts with adequate cover; totals conceal night and weekend gaps. |
| Training generic, with no site-specific chemical or machinery content. | 1910.151(b) | Add from safety data sheet section 4 and from the site's injury mechanisms. |
| Bleeding control not covered where catastrophic bleeding is credible. | OSHA interpretation 2019 | Direct pressure, hemostatic dressings and tourniquets, with Class B kit contents. |
| Certification lapsed with no tracking of expiry. | ISO 45001 cl.7.2 | Track currency per person and per shift; certifications expire quietly. |
| No bloodborne pathogens provision for designated first aiders. | 1910.1030 | Where aid may involve blood exposure, the programme including vaccination offer applies. |
| Remote site without arrangements for emergency transportation. | 1910.151(b) | Where distant from a hospital, acceptable emergency transportation must be provided. |
| Kit class not matched to the severity of credible injuries. | ANSI Z308.1 | Class B where high risk of severe injury; Class A is the general minimum. |
| Training assessed by attendance rather than practical demonstration. | ISO 45001 cl.7.2 | Assess practically; first aid is a skill that decays and is used under stress. |
| Contractors and lone workers outside the cover arrangement. | ISO 45001 cl.8.1.4 | They are on site and frequently in the least covered locations and hours. |
Case in point
Case in point: the hospital four minutes away
A manufacturing site assessed its first aid needs and concluded that trained first aiders were not strictly required, because a hospital with an emergency department was about two miles away and the site was in a town.
The response time was never measured. When it finally was measured, after a serious injury, the sequence took considerably longer than the map suggested: the call handling, the dispatch, the drive, the arrival at a gatehouse with a barrier, locating the correct building on a site with three entrances, and reaching a machine in the middle of a production hall.
None of those steps are unusual and none appear on a map. OSHA's threshold is three to four minutes from injury to first aid where a life-threatening outcome is possible, and the assessment had compared a distance against a requirement expressed in minutes.
The template
The template, field by field
The form exactly as it installs. Every field, option, score and conditional rule is editable, and the links to other templates come with it.
5 sections
- Reference
- TRN-040
- Archetype
- Training
- Record ID
- TRN-2026-000
- Scoring
- Certification achieved
- Direction
- High is good
- Singleton
- No
- Basis
- OSHA 1910.151, WorkSafeBC 33
- Links
- Links Worker, Vendor
- Tags
- Training, Emergency
- Sections
- 5
- Fields
- 48
- Follow up fields
- 4
- Repeating sections
- 0
- Links out
- 6
Header
16 fieldsTraining ID*
Auto sequence. Format TRN-2026-00000.
The record's own ID. Other templates point at this value.
Status*
Drives who this goes to next.
- Planned2 pts
- In progress2 pts
- Complete3 pts
- Deferred0 pts
- Open0 pts
- Closed3 pts
- Overdue0 pts
Date and Time*
Delivered By*
Site*
Site ID*
Format SITE-000.
Links to FDN-001 Site ID
Course
Course ID
Format CRS-000.
Links to FDN-007 Course ID
Delivery Method*
Duration Minutes*
Trainer Qualified*
- Yes3 pts
- Subject expert, not trainer trained1 pt
- No0 pts
Worker*
Person ID*
Format PER-0000.
Links to FDN-003 Person ID
Qualification Level*
Emergency first aid, full first aid at work, or specialist such as defibrillator or oxygen.
- Emergency first aid1 pt
- Full first aid at work3 pts
- Specialist, defibrillator or oxygen4 pts
Provider
Accredited Provider*
- Yes3 pts
- No1 pt
Site specific additions
10 fieldsGeneral Courses Miss Our Hazards
Standard first aid courses do not cover ammonia exposure, severe cuts from boning knives, or cold injury from freezers. Add these.
Ammonia Exposure Response Covered*
- Yes3 pts
- Partly1 pt
- No0 pts
Severe Bleeding And Deep Laceration Covered*
- Yes3 pts
- Partly1 pt
- No0 pts
Cold Injury And Hypothermia Covered*
- Yes3 pts
- Partly1 pt
- No0 pts
Chemical Burns Covered*
- Yes3 pts
- Partly1 pt
- No0 pts
Crush And Entanglement Injury Covered*
- Yes3 pts
- Partly1 pt
- No0 pts
Suspension Trauma Covered
- Yes3 pts
- Partly1 pt
- No0 pts
Defibrillator Training Included*
- Yes3 pts
- Partly1 pt
- No0 pts
Site Kit Locations Walked*
- Yes3 pts
- Partly1 pt
- No0 pts
Ambulance Access Route Explained*
- Yes3 pts
- Partly1 pt
- No0 pts
Assessment
3 fieldsPractical Assessment Passed*
- Yes3 pts
- No0 pts
Written Assessment Passed
- Yes3 pts
- Partly1 pt
- No0 pts
Certificate Number
Currency
5 fieldsCertificate Expiry*
Register ID
Links to TRN-028 Register ID
Annual Refresher Booked*
Skills fade fast. Most schemes recommend an annual half day between three yearly renewals.
- Yes3 pts
- Partly1 pt
- No0 pts
Shift Coverage Adequate After This*
- Yes3 pts
- Partly1 pt
- No0 pts
Displayed On Notice Boards*
- Yes3 pts
- Partly1 pt
- No0 pts
Outcome
14 fieldsOverall Result*
- Pass3 pts
- Pass with note2 pts
- Fail0 pts
Retraining Required*
- No3 pts
- Yes1 pt
Retraining Detail
Matrix Updated*
- Yes3 pts
- No0 pts
Certificate Issued
- Yes3 pts
- Not applicable3 pts
- No0 pts
Valid Until*
Action Required*
Raise the action record, then enter its reference here.
- No2 pts
- Yes0 pts
Priority
- High0 pts
- Medium1 pt
- Low3 pts
CAPA ID
Format CAPA-2026-00000.
Links to FDN-014 CAPA ID
Action Owner
Trainer*
Signature*
Worker*
Second Signature*
TRN-040 · record IDs look like TRN-2026-000 · Links Worker, Vendor
Open in KnowellaRun it with agents
From a document you fill in to a programme that runs itself
The record certifies first aiders. What fails is cover measured as a headcount and a response time nobody timed.
Tracks certification currency per person and reports cover by shift rather than as a site total.
Holds the needs assessment including the measured response time, and connects site chemicals to the first aid content required.
Links kit provision and class to the credible injury severity, and schedules inspection of supplies and accessibility.
Brings contractors and lone workers into the cover arrangement, since they occupy the least covered hours and locations.
This template lives in KnowTrain — training and credentials. Induction, competency, toolbox talks, refreshers and expiry tracking.
Meet KnowTrain→Glossary
First Aid Training definitions and key terms
- Near proximity
- OSHA's test for whether trained first aiders are required, expressed as response time rather than distance.
- Adequately trained
- Training appropriate to the hazards present, which OSHA has interpreted to include bleeding control where relevant.
- Class A kit
- The ANSI Z308.1 minimum workplace kit for common injuries.
- Class B kit
- The kit for workplaces with high risk of severe injury, including tourniquets.
- Hemostatic dressing
- A dressing that promotes clotting, named in OSHA's bleeding control interpretation.
- Catastrophic bleeding
- Blood loss capable of causing death within minutes, requiring immediate control rather than professional response.
- Bloodborne pathogens programme
- The 1910.1030 requirements applying where employees may be exposed to blood while rendering aid.
- Shift cover
- Whether adequate trained first aiders are present on each shift, which a site headcount conceals.
FAQ
Frequently asked questions about first aid training
How do we know if we need first aiders?+
Measure the response time. OSHA interprets near proximity as three to four minutes from injury to first aid where suffocation, severe bleeding or other life-threatening or permanently disabling injury is possible, and up to fifteen minutes where such outcomes are remote. Where the measured response exceeds the applicable threshold, trained first aiders are required.
What does the clock actually cover?+
From injury to treatment. That includes someone recognising what happened, making the call, the service dispatching and travelling, entering the site, and reaching the casualty at their actual location. A gatehouse, a barrier, three entrances and a production hall all sit inside that window, and none of them appear on a map.
Does first aid cover extend to every shift?+
Yes. Trained first aiders are required for each shift and each operation where other arrangements have not been made. A site total conceals the shift with none, which is usually nights or weekends, and which is also when response times are typically longer and supervision lower.
What does bleeding control training need to include?+
OSHA's 2019 interpretation states that adequate first aid training includes instruction on applying direct pressure, using hemostatic dressings, and using tourniquets in certain situations. Where the site has machinery, cutting or vehicle hazards capable of catastrophic bleeding, Class B kit contents under ANSI Z308.1 and the training to use them are the proportionate provision.
What should be added to a generic course?+
The site's specific injury mechanisms and chemicals. Section 4 of each safety data sheet gives the first aid measures for the substances present, which generic training will not cover. Add the machinery injury types the site can produce, the confined space or height rescue interface where relevant, and cold or heat exposure where those apply.
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Written and reviewed by
Siddarth Singh
Founder & Chief Executive Officer, Knowella
Certified Safety Professional and industrial and systems engineer with more than a decade inside food supply chain, freight and manufacturing operations. This page was written against the current text of the standards it cites, not against secondary summaries of them.
- Certified Safety Professional (CSP), Board of Certified Safety Professionals
- MBA, University of Chicago Booth School of Business
- MS and BS, The Ohio State University, Industrial and Systems Engineering
- Six Sigma Black Belt
Sources and last review. Reviewed 16 August 2026 against:
- 29 CFR 1910.151, medical services and first aid, OSHA
- OSHA letter of interpretation on near proximity and first aid response time
- OSHA letter of interpretation on first aid for bleeding control, 2019
- ANSI/ISEA Z308.1, minimum requirements for workplace first aid kits
- 29 CFR 1926.50, medical services and first aid in construction, OSHA
This page is general guidance, not legal advice. Confirm requirements with your jurisdiction’s regulator.