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 http://www.osha.gov.

September 2, 1992

Mr. Michael J. Norris
Bennett & Durham
Attorneys at Law
Suite 1600
851 S.W. 6th Avenue
Portland, Oregon 97204-1376

Dear Mr. Norris:

Thank you for your letter of July 14, addressed to Dr. Ralph E. Yodaiken, Senior Medical Advisor for the Occupational Safety and Health Administration (OSHA). Your letter was forwarded to me for response. In your letter you asked for a written clarification whether successful completion of a first aid course may be demonstrated by means other than a written knowledge test.

According to 29 CFR 1910.151(b), a person or persons shall be adequately trained to render first aid. To be in compliance with this standard, employers must ensure that the trained person or persons have the ability to read medical documentation, including Material Safety Data Sheets, labels on medication and antidotes, and Med-Alert bands which could be referenced to render proper first aid to injured employees in the workplace. We believe that these abilities can best be demonstrated by means of a written test. It is, however, the ability to read the necessary information that is critical to compliance, not the means by which that ability is tested. Thus, lack of a written test does not, by itself, establish a violation of the standard if that ability can be demonstrated in some other fashion.

We appreciate you interest in employee safety and health. If we can be of further assistance, please do not hesitate to contact us.

Sincerely,



Patricia K. Clark, Director
Directorate of Compliance Programs