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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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 31, 1994

Ms. Gretchen M. Mendez-Vilella, Esq.
P.O. Box 70364
San Juan, Puerto Rico 00936-0364

Dear Ms. Mendez-Vilella:

Thank you for your inquiry of February 27, requesting an interpretation of standard 29 CFR 1910.151, Medical Services and First Aid.

You specifically requested the following items:

1. Definition and/or standards for the term "available medical personnel" included in the standard 29 CFR 1910.151(a).

Response: Advice and consultation on matters of plant health must be readily available from qualified medical professionals. Because of the wide range of medical requirements, the Occupational Safety and Health (OSHA) does not set criteria as to what is a qualified medical professional.

2. Definition and/or standards for the term "quick drenching or flushing supplies" included in the standard 29 CFR 1910.151(c).

Response: Enclosed is a copy of ANSI 358.1-1990, American National Standard for Emergency Eyewash and Shower Equipment and a letter of interpretation stating that ANSI 358.1-1990 is acceptable to OSHA.

3. Copies of CPLs or Compliance "guidelines" pertaining to the referenced 29 CFR 1910.151 terms or standards.

Response: Enclosed are several letters of interpretation and CPL 2-2.53, Guidelines for First Aid Training Programs, addressing various questions pertaining to standard 29 CFR 1910.151.

4. Copy of (American National Standard Institute Inc.) ANSI Z358.1-1990.

Response: Already enclosed for item # 2.

5. Copies of OSHA letters issued by the Office of Compliance Programs which set additional standards in documents #1 and #2 and pertaining to the aforementioned inquiry.

Response: The Office of Compliance Programs does not set standards. We only interpret existing standards. Copies of letters of interpretation are already enclosed for item # 2.

We appreciate your interest in employee safety and health. If we can be of further assistance, please contact David Garcia on 202-219-8031 x 121.


John B. Miles, Jr., Director
Directorate of Compliance Programs