PUB 11 2022-2023 Issue 2

FIRST-AID KITS: Regulations & Good Practice By CELLY SERVICES, INC. (CSI) Background: On Oct. 15, 2022, the American National Safety Institute (ANSI) specifications for First-Aid kits changed. (This article discusses the changes to the ANSI specifications for first-aid kits.) Both California and Federal regulations mandate employers ensure ready and adequate availability of first-aid supplies. The regulations differ, and we discuss the differences here. CAL/OSHA: California regulations mandate that a first-aid kit approved by a consulting physician be available on the premises for every working person on the job. A consulting physician is a medical doctor who is well versed with dealership operations and has knowledge of typical hazards and accidents on the job (Ref: T8CCR3400 (a) and (b) and (c)). Fed-OSHA: Regulations state that an employer must have “adequate first-aid supplies … readily available,” although specific first-aid supplies are not listed. Fed OSHA has referred employers to ANSI as the source of guidance for the minimum requirements for first aid kits and supplies; it does so in Appendix A to 1910.151. On April 15, 2022, ANSI approved ANSI/ISEA Z308. 1-2021, effective Oct. 15, 2022, the sixth revision to the voluntary industry consensus standard since its inception in 1978 (Ref: 29CFR1910.151(b)). New requirements for both Class A and Class B First Aid kits include more hand sanitizer (thanks to COVID-19) and a foil blanket since it serves multiple purposes, such as emergency waterproofer, windbreaking wrap, and treating hypothermia. Additionally, Class B kits now require specific types of tourniquets to prevent blood loss, distinct from those used for drawing blood. Splints are also a requirement for Class B kits. Employers may adopt the ANSI standard or request their local occupational injury clinic to provide a list of items for the first-aid kit. They should, however, be selected only upon completion of a hazard assessment of the work environment by a person competent in first-aid and knowledgeable of the hazards specific to that workplace. Hazard assessment involves reviewing workplace hazards, typical injuries that have occurred (see Log 300) or could occur at the workplace, and the availability of the supplies necessary to respond to those injuries. Risk assessment includes looking at Bureau of Labor Statistics (BLS) or OSHA injury data. The physician at the local clinic responding to occupational injuries can also be a source of guidance. 18 SAN DIEGO DEALER

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