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First Aid and CPR on Construction Sites

December 5, 2019

First Aid and CPR Requirements for Construction Sites by Jim Poesl, December 2019

Few topics raise more controversy in the “back office” of companies than First Aid and CPR requirements at construction jobs. After all of the training required by the state and OSHA this normally “falls through the cracks.” Some companies feel that First Aid CPR training is all that is necessary and neglect everything else. As a result, safety takes a back seat to emergency response.

So in response to some of the feedback we have received I will answer what OSHA requirements are for First Aid and CPR, through their Letters of Interpretation and Regulations.

Question 1: Are you actually a construction site?

The first thing you need to do is determine whether you are on a Construction, General Industry, Maritime, or Agricultural workplace. OSHA defines construction as: 1926.32(g)

"Construction work." For purposes of this section, "Construction work" means work for construction, alteration, and/or repair, including painting and decorating.

Question 2: What are the relevant regulations for First Aid on a construction site?

29CFR1926.23. First aid services and provisions for medical care shall be made available by the employer for every employee covered by these regulations. Regulations prescribing specific requirements for first aid, medical attention, and emergency facilities are contained in Subpart D of this part.

29 CFR1926.50(b). Provisions shall be made prior to commencement of the project for prompt medical attention in case of serious injury.

29CFR1926.50(c). In the absence of an infirmary, clinic, hospital, or physician, that is reasonably accessible in terms of time and distance to the worksite, which is available for the treatment of injured employees, a person who has a valid certificate in first-aid training from the U.S. Bureau of Mines, the American Red Cross, or equivalent training that can be verified by documentary evidence, shall be available at the worksite to render first aid.

Question 3: How do we define “reasonably accessible”?

In a letter of interpretation to Charles F. Brogan on January 16, 2007 OSHA states: “However, the requirements that emergency medical services must be "reasonably accessible" or "in near proximity to the workplace" are stated only in general terms… While the standards do not prescribe a number of minutes, OSHA has long interpreted the term "near proximity" to mean that emergency care must be available within no more than 3-4 minutes from the workplace, an interpretation that has been upheld by the Occupational Safety and Health Review Commission and by federal courts.”

Question 4: How do I determine the response time for emergency services?

It depends on the state that you live in. The State of New Jersey issues monthly response times for Basic Life Support and Advanced Life Support (BLS/ALS). In October 2019 the response times for each County is as follows:

State of NJ Response Times for BLS/ALS

County

Response Time

County

Response Time

Camden