OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

December 24, 1975

Mr. Robert J. Bolger, President
National Association of Chain Drug Stores, Inc.
1911 Jefferson Davis Highway
Arlington, Virginia 22202

Dear Mr. Bolger:

This is in response to your letter dated November 4, 1975, which requested clarification of Subpart K, section 29, CFR 1910.151(b) concerning first aid training. A registered pharmacist relying only on his formal education would not meet the requirement of 29 CFR 1910.151(b). A special training course in emergency care of the sick or injured would be required with a review course requirement every few years.

I would recommend that you contact the local chapter of the American Red Cross, which provides continuous standard and advance first aid courses, that are recognized by the Occupational Safety and Health Administration (OSHA).

If I may be of any further assistance, please feel free to contact me.


John K. Barto, Chief
Division of Occupational
Safety Programming