December 17, 1984
||JAMES W. Lake|
||JOHN B. MILES, JR. Director|
Directorate of Field Operations
||American Red Cross Standard First Aid Modular System|
This is in response to your memorandum dated August 28, 1984, subject as above.
In order for employers to be in compliance with the various OSHA first aid training requirements, the recommended minimum level of training has been the ARC Standard course, taught in multi-media form or otherwise, or the equivalent. With the advent of the ARC Modular System, another method of training was provided, consisting of subject matter and skill and knowledge levels no less than that required in the more traditionally taught courses. Therefore, the ARC Standard First Aid Modular System course meets the intent of the 29 CFR 1910.151(b) and the other standards requiring first aid training. As noted in the flyer, all ten modules must be taken for a Standard First Aid certificate, and the ten modules must be completed within a four-month period.
The Fundamental First Aid certificate, consisting of the two "core" modules and any four of the remaining eight, is not sufficient to provide the minimum uniformity and scope for first aid training in order for employers to be in compliance with the OSHA standards.