The California Occupational Safety and Health Standards Board has approved revisions to its first-aid kit requirements for general industry and construction employers that are expected to take effect Jan. 1, 2027, pending approval by the Office of Administrative Law.

The changes are designed to modernize the rules while requiring employers to consider the size, layout and specific hazards of their workplaces when determining what first-aid supplies they need and where to place them.

For general industry employers, changes to first-aid kit contents are among the most significant. But there are other important changes to be aware of.

 

No doctor’s approval

Under the existing regulation, first-aid materials generally must be approved by a consulting physician. Under the revised rules, employers may instead provide kits that comply with the ANSI/ISEA Z308.1-2021 Class A standard.

Employers without a compliant kit may have their kit contents determined by an employer-authorized licensed physician or other licensed health care professional.

 

Additional kits

Employers would have to evaluate employee work locations and workplace hazards to determine how many kits they need.

These requirements may be particularly important for large facilities, workplaces with employees spread across multiple locations and construction sites where crews frequently move between areas.

Unlike current requirements, kits would have to be readily available, and employers must tell workers where they are located. Where practicable, kit locations must also be clearly identified.

 

Some workplaces may need additional supplies

An ANSI Class A kit provides a baseline, but it may not be enough for every workplace.

Employers must assess their operations for unique, reasonably anticipated and potentially serious hazards that could require specialized first-aid supplies. Depending on the workplace, these could include exposure to chemicals or electricity and risks of burns, heat-related illnesses or serious trauma.

 

What employers can do now

Employers should review their first-aid programs and consider the following steps:

• Compare existing kits with ANSI/ISEA Z308.1-2021 Class A requirements and update them as needed.
• Evaluate whether you have enough kits and whether employees can reach them quickly.
• Identify kit locations and communicate them to employees.
• Conduct a workplace hazard assessment to identify any need for specialized supplies.
• Establish procedures for routinely inspecting and replenishing kits.
• Update your Injury and Illness Prevention Program and other applicable emergency plans as necessary.

 

The changes may simplify first-aid compliance for many employers by eliminating the physician-approval requirement when an ANSI-compliant kit is used. But they also put greater emphasis on ensuring supplies meet actual workforce needs and address identified workplace hazards.

 

New items

The required contents of kits are changing, with four new items and four items being removed. The Board-approved regulations would require most first-aid kits to contain the following:

• Adhesive dressings
• Adhesive tape rolls, 1 inch wide
• Eye dressing packet
• 1-inch gauze bandage roll or compress
• 2-inch gauze bandage roll or compress
• 4-inch gauze bandage roll or compress
• Sterile gauze pads, 2 inches square
• Sterile gauze pads, 4 inches square
• Sterile surgical pads suitable for pressure dressings
• Triangular bandages
• Medical exam gloves (NEW)
• Tweezers
• Cotton-tipped applicators
• Antibiotic treatment, single-use application (NEW)
• Antiseptic, single-use application (NEW)
• Flashlight
• Magnifying glass
• Single-use disposable barrier device for CPR where CPR may be required (NEW)
• Appropriate record forms
• An up-to-date “standard” or “advanced” first-aid textbook, manual or equivalent

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