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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

March 30, 1993

Mr. Charles G. Marvin
Executive Vice President
The Refractories Institute
500 Wood Street
Suite 326
Pittsburgh, Pennsylvania 15222

Dear Mr. Marvin:

Thank you for your letter of December 3, 1992, requesting an interpretation of the Occupational Safety and Health Administration (OSHA) standards, 29 CFR 1910.151(a) and (b). Please accept our apologies for the delay in responding.

We note that you will share our interpretation with members of the Refractories Institute. They should be aware that we cannot provide a list of "exact requirements" which will apply in every workplace. Rather, conditions in each workplace must be evaluated when a first aid program is developed to ensure that it is adequate to meet anticipated needs. For example, the first aid program requirements for a workplace or industry with a history of burns or electrical shock injuries will differ from those for an office environment.

Where a medical facility is near the workplace, 29 CFR 1910.151(a) requires the employer to ensure the following:

a. 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 is required. In other circumstances, i.e., where a life-threatening injury is an unlikely outcome of an accident, a longer response time, for example up to 15 minutes, may be acceptable.

b. If employees work in areas where emergency transportation is not available, the employer must make provisions for acceptable emergency transportation.

Where an employer complies with 29 CFR 1910.151(a), as stated above, but has areas where the eyes or body of a person may be exposed to injurious corrosive materials (as specified in 29 CFR 1910.151(c)), the employer must comply with 29 CFR 1910.151(b) to train a person or persons to render first aid.

Where an employer complies with 29 CFR 1910.151(a), and .151(c) as stated above, and requires employees to report to the medical facility for all injuries and illnesses requiring first aid, the employer is not obligated to have first aid supplies approved by the consulting physician readily available.

OSHA's interpretation for the phrase "in near proximity" as used in 29 CFR 1910.151(b) emphasizes the need for prompt assistance when an injury or illness occurs. The response time is the same as the response time required in 29 CFR 1910.151(a).

Trained first aiders are required to be available for each shift and operation when other arrangements are not made for the provision of emergency medical service, e.g., the use of a local hospital or clinic.

When the worksite is located in a rural area, or is some distance from the nearest hospital or clinic, the employer is required to provide an acceptable type of emergency transportation.

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 Compliance Programs