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.

March 25, 1994

Mr. Bernard J. Fisher, Director
American Lifeguard Association, Inc.
Philomont, Virginia 22131

Dear Mr. Fisher:

Thank you for your inquiry of September 28, 1993, requesting the Occupational Safety and Health Administration (OSHA) to accept the American Lifeguard Association, Inc. issuance of a new photo identification to Association members who have been trained in first aid. We apologize for the delay in response.

The Occupational Safety and Health Administration (OSHA) does not certify first aid training programs, instructors, or trainees. It is the responsibility of the employer to make an assessment of the work area and all first aid needs for expected injuries and illnesses. Each employer using any first aid course must satisfy him/herself that the course adequately covers the type of injuries/illnesses likely to be encountered in the workplace. We have enclosed a copy of OSHA instruction CPL 2-2.53, guidance for first aid training.

OSHA standard requirements do not apply to the public. First aid training for lifeguards would be covered by OSHA's first aid standards only when training is required for the protection of employees.

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


Raymond E. Donnelly, Director
Office of General Industry Compliance Assistance