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.

November 1, 2005

Mr. David Nakama
Manager - Sales Administration
Vantec World Transportation (USA), Inc.
Los Angeles Headquaters
991 Francisco Street
Terrance, California 90502

Dear Mr. Nakama:

Thank you for your September 20, 2005, letter to the Occupational Safety and Health Administration's (OSHA's) Directorate of Enforcement Programs. This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any question or scenario not delineated within your original correspondence. You inquired about first aid training in the workplace.

Question 1: Does 29 CFR 1910.151(b) only cover basic first aid?

Reply: Paragraph 1910.151(b) of OSHA's general industry standard, Medical services and first aid (29 CFR 1910.151), states, "In the absence of an infirmary, clinic, or hospital in near proximity to the workplace which is used for the treatment of all injured employees, a person or persons shall be adequately trained to render first aid. Adequate first aid supplies shall be readily available." Employers should provide medical services and first aid that are most appropriate to respond to incidents at their workplaces. OSHA allows employers to tailor the specific details of their first aid and medical services program, depending on the circumstances of each workplace and employer.

Question 2: Is having personnel trained in adult cardiopulmonary resuscitation (CPR) an OSHA requirement?

Reply: OSHA recommends that CPR training be a general program element of a first aid program. However, some OSHA standards, for example, Logging operations (29 CFR 1910.266), Permit-required confined spaces (29 CFR 1910.146), and Electric power generation, transmission, and distribution (29 CFR 1910.269), have specific requirements that employees be trained in first aid and CPR. If an employer is covered by one of these specific standards, CPR training would be required.

Thank you for your interest in occupational safety and health. We hope you find this information helpful. Please be aware that OSHA's enforcement guidance is subject to periodic review and clarification, amplification, or correction. Such guidance could also be affected by subsequent rulemaking. In the future, should you wish to verify that the guidance provided herein remains current, you may consult OSHA's website at
www.osha.gov. If you have any further questions, please feel free to contact the Office of General Industry Enforcement at (202) 693-1850.


Richard E. Fairfax, Director
Directorate of Enforcement Programs