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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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 28, 1993

Ms. Carol A. Bacon
C-A-B Consultants, Inc.
4921 Butterfield Road
Hillside, Illinois 60162-1445

Dear Ms. Bacon:

This is in further response to your November 23 letter, requesting that the Occupational Safety and Health Administration (OSHA) answer several questions concerning first aid in the workplace. Your questions and our responses follow:

Question 1: Several individual sections of OSHA regulations require eyewash and shower facilities for emergency care without specifics as to the definition of continuous flow. Many companies have small bottles of solutions available. Some have wall units that require filling, and others have the plumbing connected to water. Is there specific wording relating to acceptable standards for eyewash and shower facilities?

Reply: In answer to this question, we have enclosed our letter of July 20, 1992, to Mr. Paul R. Naim, which addresses the same issue and reflects current OSHA policy. We have also enclosed our letter of November 22, 1993, to Mr. Mark Hageness, which gives additional specific information about plumbed emergency eyewash units. Other OSHA letters of interpretation are available on CD-ROM which may be purchased from the Government Printing Office (GPO), telephone number (202) 783-3238. The CD-ROM is titled "OSHA Regulations, Documents and Other Technical Information". The GPO order number is 729-013-00000-5. The cost is $28 for the current disc or $88 for one year including 4 quarterly updates.

Question 2: Many companies are marketing a "First Aid Kit" for use in a company. Are there specific regulations concerning kits, that is, who needs one and what education should there be if you have a kit?

Reply: The general requirements for first aid supplies and training are contained in the General Industry standard, 29 CFR 1910.151(b). Similar requirements are contained in the OSHA Construction and Maritime standards. First aid supplies, including kits, must be approved by the consulting physician to comply with 1910.151(b). These supplies must include first aid items needed for the particular workplace. For example, the pulpwood logging standard 1910.266(c)(1)(vii) (copy enclosed) requires a snake bite kit in all areas where poisonous snakes may exist. A copy of OSHA Instruction CPL 2-2.53 which includes Guidelines for First Aid Training Programs (Also available on the aforementioned CD-ROM) is enclosed for your use.

Question 3: Do you feel it is and should be within the regulations of OSHA to address the "First Aid" given at a company?

Reply: OSHA standards are promulgated pursuant to the Occupational Safety and Health Act. A copy of this Act is enclosed for your use. "A company" in the context of your question is an employer as defined in the Act. The "general duty clause" that is, Section 5(a)(1) of the Act requires that each employer must furnish to each of his or her employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause physical harm to his or her employees. Consistent with the intent of this general duty clause, the OSHA standards on first aid are deemed appropriate to mitigate harmful employee exposure to workplace hazards.

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