About OSHA and ANSI First Aid Compliance

Q: Do I need to comply with OSHA First Aid Standards, or ANSI First Aid Standards?
A: Typically, both. (and often even more…)

ANSI is a private organization that creates voluntary standards, while OSHA is a regulatory government body that enforces safety compliance rulings in the United States, and often incorporates ANSI standards into their standards. Another way of putting this is that OSHA is the regulation, or law. ANSI is an industry standard agreed upon by manufacturers, engineers and other professionals who work in the area subject to the standard (basically the USA equivalent of ISO / International Organization for Standardization). When OSHA incorporates or references the ANSI Standards, then organizations must meet or exceed the ANSI Standard requirements or be subject to OSHA penalties.

A relevant example of this is OSHA 1910.151(b) & ANSI Z308.1: OSHA CFR 1910.151 references ANSI Z308.1 Minimum Requirements for Workplace First Aid Kits, but did not adopt it as the OSHA standard. This is interpreted by OSHA as “A source of guidance for the minimum requirements for first aid kits”. OSHA states that “the contents of the first aid kit listed in ANSI Z308.1 should be adequate for a small worksite. However, larger or multiple operations should consider the need for additional first aid kits, additional types of first aid equipment, and first aid supplies in larger quantities.”

There are similar references throughout OSHA’s CFRs, including 1915.87 App A, 1926.50 (Construction & Electrical orders), and even more requirements specific to logging operations, tree trimming, and other industries. Whew! Beyond this, the OSHA regulations call out ANSI Standards from 1978, 1998, 2002, 2009, 2015 and others – but should always be interpreted as requiring the latest/current ANSI guidelines (at present ANSI Z308.1-2021).

Furthermore, the following 22 states and territories have OSHA-approved State Plans that cover both private and state and local government workers. These States include: Alaska, Arizona, California, Hawaii, Indiana, Iowa, Kentucky, Maryland, Michigan, Minnesota, Nevada, New Mexico, North Carolina, Oregon, Puerto Rico, South Carolina, Tennessee, Utah, Vermont, Virginia, Washington, Wyoming. Beyond that, Connecticut, Illinois, Maine, Massachusetts, New Jersey, New York, and the U.S. Virgin Islands have specific plans that cover state and local government workers only. State-run safety and health programs must be at least as effective (ALAE) as the federal OSHA program (which generally means State plans are even more strict than Federal OSHA and may have higher fines and penalties*).

Q: OKAY, Thanks for the background information, but I still don’t get it… Do I need to comply with OSHA First Aid Standards, or ANSI First Aid Standards?
A: Check your specific Industry and State requirements above to be certain, but as a basic rule of thumb, start with the right ANSI Class First Aid Kit or Cabinet sized appropriately for your organization, and follow OSHA First Aid Guidelines if you have no specific State requirements.

The newest ANSI/ISEA standard introduces two classes of first aid kits: Class A and Class B.

• Class A kits are designed to deal with the most common types of workplace injuries.
• Class B kits are designed with a broader range and quantity of supplies to deal with injures in more complex or high-risk environments.

It is up to you to decide which describes your workplace, but as a general rule, Class A would suffice for a general office environment with nothing more hazardous than a stapler or copy machine. If you have moving parts (forklifts, presses, falling object potential, food preparation, cutting devices, etc.) go Class B (Go Big or go home) to be on the safe side, and assure you have the first aid supplies and equipment needed for potential injuries. Be sure the first aid kit or cabinet is right-sized for the number of people… employees and guests/visitors. Another consideration is placement… you’ll want to have a 3 minute or less roundtrip response time from any location (e.g. in emergency circumstances, elevators may be down and stairways may be blocked, so you should certainly consider minimum one first aid cabinet or kit per floor if you have a multi-story facility.)

Q: Great. Now what do I need in my ANSI First Aid Kit to meet the Standard?
A: Here’s a quick reference table for you. Note that all Urgent First Aid^® kits are designated for ANSI Type, or Industry, and typically describe the number of people they are designed to care for.