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.

January 27, 1976

Ms. Kay Urtz
General Assignment Reporter
333 N. Dominick Street
Rome, New York 13440

Dear Ms. Urtz:

This is in response to your letter dated November 22, 1975, which was referred to the National Office for response. Your questions concerning First Aid Training are discussed as follows.

[For OSHA's current policy on "near proximity," please see the
1/16/2007 letter to Mr. Brogan.]

As for your second question, yes, the American Red Cross continues to be a source for obtaining the needed training. The new American Red Cross Standard and Advanced First Aid and Emergency Care Courses provide information relating to a total working environment.

A statement concerning the degree of compliance attained, and our satisfaction with it, could best be described as follows. Many industries have done an excellent job through their associations; many employers have met the requirement through voluntary compliance; and others may be lacking. OSHA continues to encourage all employers to review their current occupational safety and health programs and implement voluntary compliance programs which in some cases may exceed OSHA requirements.

In regard to your fourth question on problems with enforcement, OSHA at this time has not experienced any major problems in the enforcement area relating to 29 CFR 1910.151.

Thank you for your interest in occupational safety and health.


John K. Barto, Chief
Division of Occupational Safety Programming

[Corrected 06/13/07]