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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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 19, 1990

Mr. Donald J. Nichols
Safety Consultant
Trevino Safety
P.O. Box 9029
The Woodlands, Texas 77387

Dear Mr. Nichols:

This is in response to your letter of October 11, requesting a clarification explaining why the Medic First Aid program meets 29 CFR 1910.151(b) and why it does not meet the cardiopulmonary resuscitation (CPR) training requirements in 29 CFR 1910.410. You also asked for a list of examples of companies that are required to have this type of training.

The Occupational Safety and Health Administration (OSHA) has changed its method of reviewing and/or evaluating first aid programs for meeting the intent of the OSHA first aid training standards, such as 29 CFR 1910.151(b) or 29 CFR 1910.410. OSHA has developed guidelines for first aid training programs by which the adequacy of first aid training can be evaluated by our compliance officers in the context of workplace inspections. Through these same guidelines, a competent professional will be able to develop adequate first aid training and tailor it to the specific needs of a workplace. The agency will no longer evaluate individual first aid courses, other than at the work place during an inspection. The general requirements for complying with the attached guidelines for first aid programs are follows:

1. General program elements, III, A.1. through I. will be required by all. (D.1. covers cardiopulmonary resuscitation.)

2. Specific program elements, IV, A.1 through A.9 will be required when those types of injuries are anticipated.

3. Specific injury sites, IV, B.1. through B.7. will be required when injuries to those sites are anticipated.

The amount and nature of training can vary widely, depending on the type of employment and workplace conditions, such as the following:

a. Maximum time required to transport injured or ill employee to an infirmary, clinic, or hospital;

b. Provisions for acceptable emergency transportation;

c. Job function and known hazards, types of injuries and/or illnesses anticipated; and

d. Number of shifts and job locations.

Thank you for your interest in occupational safety and health. If we may be of further assistance, please contact us.


Patricia K. Clark, Director
Directorate of Compliance Programs