Pub. 2 Issue 3
14 www.glancda.org CAL/OSHA: THE REGULATIONREQUIRES THAT IN THE ABSENCEOF ANOCCUPATIONAL INJURYCLINICORHOSPITALCLOSE TOTHEWORKPLACE, APERSONOR PERSONS SHALL BE ADEQUATELY TRAINED TO RENDER FIRST-AID. THE TRAINING PROVIDED TO STAFF MUST BE EQUAL TO OR BETTER THAN THAT PROVIDED BY THE AMERICAN RED CROSS. First-Aid — continued from page 12 is not compromised, i.e., it must remain completely accessible when employees are present. Another advantage of the kit being in the managers’ view is that if one employee is observed using multiple bandages more often than others, the employee can be counseled on safety and proper work procedure to avoid slicing his/her hand multiple times a day! Employers who choose not to have first-aid kits not only violate the law, but also risk loss of productive time when employees have to rush to the local drug store for a bandage every time they incur an injury. FIRST-AID & CPR TRAINING Cal/OSHA: The regulation requires that in the absence of an occupational injury clinic or hospital close to the workplace, a person or persons shall be adequately trained to render first-aid. The training provided to staff must be equal to or better than that provided by the American Red Cross. Federal-OSHA: The standard for first-aid training in general industry, 29 CFR 1910.151(b), states: 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. Commentary: The primary requirement addressed by these standards is that an employer must ensure prompt first-aid treatment for injured employees, either by providing a trained first-aid provider at the workplace or by ensuring that emergency treatment services are within reasonable proximity of the workplace. The basic purpose of these standards is to assure that adequate first-aid is available in the critical minutes between the occurrence of an injury and the availability of a physician or hospital care for the injured employee. One option these standards provide employers with is to ensure that an employee is trained in first-aid. This option is, for most employers, a feasible and low-cost way to protect employees, as well as ensuring that the employer is clearly in compliance with the standards. OSHA recommends, but does not require, that every workplace include one or more employees are trained and certified in first aid, including CPR. The other option for employers is to rely upon the reasonable proximity of an infirmary, clinic, or hospital. OSHA has consistently taken the view that the reasonable availability of a trained emergency service provider, such as fire department paramedics or EMS responders, would be equivalent to the "infirmary, clinic, or hospital" specified by the literal wording of the standards. Emergency medical services can be provided either on-site or by evacuating the employee to an off-site facility in cases where that can be done safely. However, the requirements that emergency medical services must be "reasonably accessible" or "in near proximity to the workplace" are stated only in general terms. An employer who contemplates relying on assistance from outside emergency responders as an alternative to providing a first-aid-trained employee must take a number of factors into account. The employer must take appropriate steps prior to any accident (such as making arrangements with the service provider) to ascertain that
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