Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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

December 17, 1984



Regional Administrator
Directorate of Field Operations
SUBJECT: American Red Cross Standard First Aid Modular System


This is in response to your memorandum dated August 28, 1984, subject as above.

In order for employers to be in compliance with the various OSHA first aid training requirements, the recommended minimum level of training has been the ARC Standard course, taught in multi-media form or otherwise, or the equivalent. With the advent of the ARC Modular System, another method of training was provided, consisting of subject matter and skill and knowledge levels no less than that required in the more traditionally taught courses. Therefore, the ARC Standard First Aid Modular System course meets the intent of the 29 CFR 1910.151(b) and the other standards requiring first aid training. As noted in the flyer, all ten modules must be taken for a Standard First Aid certificate, and the ten modules must be completed within a four-month period.

The Fundamental First Aid certificate, consisting of the two "core" modules and any four of the remaining eight, is not sufficient to provide the minimum uniformity and scope for first aid training in order for employers to be in compliance with the OSHA standards.