- Standard Number:
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.
October 5, 1992
Mr. Keith Jepsen
Environmental and Safety Technician
Environmental & Safety Services Inc.
P.O. Box 7305, Dept. 141
Kansas City, Missouri 64116-0005
Dear Mr. Jepsen:
Thank you for your inquiry of October 29, requesting an interpretation of application of employee training in first aid and Bloodborne Pathogen Standard with respect to 29 CFR 1910.151. Please accept our apology for the delay in responding.
You specifically requested answers to the following questions:
Question 1. Do employees need to be trained in first aid regardless of the meaning of "near proximity" in 1910.151, if welding is done at the facility?
In areas where accidents resulting in suffocation, severe bleeding, or other life threatening injury or illness can be expected, a 3 to 4 minute response time, from time of injury to time of administering first aid, is required. In other circumstances, i.e., where a life-threatening injury is an unlikely outcome of an accident, a 15 minute response time is acceptable.
[This letter was edited on 6/12/2002 to strike information that no longer reflects current OSHA policy. Please see the 4/18/02 letter to Mr. Mateus for the current policy.]
If an employer can take employees to an infirmary, clinic, or hospital, or if outside emergency assistance can arrive within the allotted times, the employer is not required to train employees in first aid.
Question 2. If employees have been trained in first aid, do they need to be designated or assigned first aid duties?
Response: 1910.151(b) does not require the employer to assign employees first aid duties. However, in the absence of professional medical care in near proximity, it would be wise to assign employees with adequate training to such duties.
Question 3. Does the Bloodborne Pathogens Standard apply to these individuals with first aid training.
Response: Employees who have occupational exposure to blood of other potentially infectious materials (OPIM) are covered by the Bloodborne Pathogens Standard. Occupational exposure is defined as reasonably anticipated skin, eye, mucous membrane, or parenteral contact with blood or OPIM that may result from the performance of an employee's duties. The vaccination requirements, as well as all other provisions of the standard, apply to all employees who have occupational exposure.
Employees who are designated to provide first aid as a primary or collateral duty are covered by the Bloodborne Pathogens Standard; however, employees who perform unanticipated "Good Samaritan acts" are excluded from coverage by the standard, since such an action does not constitute "occupational exposure."
We appreciate your interest in employee safety and health. If we can be of further assistance, please do not hesitate to contact us.
Roger A. Clark, Director
[Directorate of Enforcement Programs]