Does my facility need a first aid team? Seems to be an easy question to answer, but there are a lot of “condition” that will affect the answer. First thing we have to discuss is the multiple OSHA standards that may come into play, as there is more to this assessment than 1910.151. Here is how I break it down….
First standard to look at is of course 1910.151, perhaps the shortest of all 1910 standards, but one that has many LOI’s associated with it. 1910.151(a)-(b) states the following:
(a) The employer shall ensure the ready availability of medical personnel for advice and consultation on matters of plant health.
(b) 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. Adequate first aid supplies shall be readily available.
As you can see these requirements are very open to interpretation and this is where we turn to LOIs for guidance. But bottom line, OSHA has stated that if a worker has a risk of a serious injury (e.g. stopped breathing, cardiac arrest, or uncontrolled bleeding) then they MUST have care provided to them within 3-4 minutes.
From OSHA LOI dated 3/23/07:
OSHA has long interpreted the term ‘near proximity’ to mean that emergency care must be available within no more than 3-4 minutes from the workplace. Medical literature establishes that, for serious injuries such as those involving stopped breathing, cardiac arrest, or uncontrolled bleeding, first aid treatment must be provided within the first few minutes to avoid permanent medical impairment or death. Accordingly, in workplaces where serious accidents such as those involving falls, suffocation, electrocution, or amputation are possible, emergency medical services must be available within 3-4 minutes, if there is no employee on the site who is trained to render first aid.”
So we have our framework set up… 3-4 minutes for most workplaces. Now we have to look at how do we meet this timeframe? If we are in a populated area there is a good chance that we may be able to rely on our local EMS/FD to be our first aid responders as most major cities will have response times under 5 minutes. However, most high-risk operations are in rural locations and thus outside response may NOT meet our needs in both ability and timing. When our facility is in a rural setting, it will be most likely that we will need our own in-house first aid team. Even when your facility has a full-time EMS group that can respond, the response distance will usually be too far in order to be on scene and providing care within 3-4 minutes. NOTICE I stated “providing care” in 3-4 minutes! This is critical, as just arriving at the main gate in 3-4 minutes is NOT going to cut it! If it will take another 3-4 minutes to get on site and get to the patient the facility will NOT be in compliance, nor providing ample care for their employee/contractor.
Next we look at three other standards that may apply to your workplace and how they could impact your first aid team assessment:
1. 1910.146(k)(2)(iii) Permit Required Confined Spaces
2. 1910.266(i)(7) Logging operations
3. 1910.269(b) Electric Power Generation, Transmission, and Distribution
4. Bloodborne Pathogens
1) If the facility does entries into a PRCS and they have their own rescue team, at least one (1) member of the specific group of rescuers must hold a current certificate in FA/CPR. By the way, this is asinine – EVERY RESCUER should be FULLY trained in basic first aid/CPR, as well as getting FA training on an ANNUAL basis regardless of what the Red Cross or American Heart Association state the refresher frequency is. It is one thing for a person who works in the industry and uses their skills daily/weekly; it is an entirely different need when the provider may never use their skills. FA/CPR may be a critical path for some entrants who are rescued and the confidence level of the rescuer MUST BE that he/she can perform the necessary medical procedures needed to give the entrant(s) a shot at survival.
2) In the same spirit of the “3-4 minute response time” as in 1910.151 LOIs, OSHA mandates that loggers be trained in FA/CPR, as well as requiring FA kits be equipped and sized properly for the type of work and number of workers. This is clearly required as almost all logging jobs are in remote locations and ALMOST NONE will have a 911 address, making it very difficult for responders to find and eventually reach the injured worker. So basically OSHA is assuming that help will not be within 3-4 minutes and thus requiring the employer to provide first aid services.
3) Generating stations have some very specific FA requirements… For fixed work locations such as generating stations, the number of trained persons available shall be sufficient to ensure that each employee exposed to electric shock can be reached within 4 minutes by a trained person. However, where the existing number of employees is insufficient to meet this requirement (at a remote substation, for example), all employees at the work location shall be trained. We once again see a “timing” requirement and it is again set at 4 minutes. Having done my fair share of work in these types of facilities I can attest to the fact that even a small station will need its own FA team in order to reach a worker on the top of the unit (my personal opinion).
4) The bloodborne pathogens angle is not one that would require a FA team, but it does come into play regarding injuries. The audit question we always ask when we come across a serious injury that involved blood/body parts contaminating a piece of equipment is… “Who cleaned the equipment?”. A facility that does NOT have a trained FA team (assuming that all FA responders are trained in BBP) will have two (2) options to handle this situation: 1) beg for the local responders to clean up and decon the machine, 2) hire a 3rd party to do the work. The point is, even if you have local responders 3-4 minutes away, it may still be advantageous to have your own trained team. Just this week OSHA issued a citation because the employees who cleaned a machine after an amputation were not trained in BBP. (Click Here for the citation).