The California Occupational Safety and Health Standards Board has approved revisions to California’s workplace first aid requirements affecting both general industry and construction employers. The amendments revise General Industry Safety Orders § 3400 and Construction Safety Orders § 1512 and modernize California’s approach to workplace first aid compliance.
The rulemaking now proceeds through the final regulatory process. Subject to approval by the Office of Administrative Law, the amendments are expected to become effective on January 1, 2027.
Background
The Standards Board initiated the rulemaking to update and clarify California’s first aid requirements and to improve employee access to workplace first aid supplies. According to the Board’s Initial Statement of Reasons, the amendments are intended to modernize existing rules, facilitate employer compliance, and improve worker safety.
The new standards incorporate modern workplace first aid practices and align California requirements more closely with the American National Standards Institute (ANSI)/International Safety Equipment Association (ISEA) first aid standard.
Change for General Industry Employers
Perhaps the most significant change affects employers subject to Section 3400.
Historically, California’s first aid regulation required first aid materials to be approved by a consulting physician. Employers could face citations because they lacked a physician approval letter even when first aid supplies were otherwise adequate.
Under the approved amendments, employers generally may satisfy the first aid kit requirement by providing a first aid kit that complies with ANSI/ISEA Z308.1-2021 Class A workplace first aid kit requirements. Alternatively, employers may continue to have first aid contents determined by an authorized licensed physician or other licensed healthcare professional (PLHCP).
ANSI-Compliant First Aid Kits Required
The revised regulations require workplace first aid kits to comply with the requirements applicable to ANSI/ISEA Z308.1-2021 Class A first aid kits unless an employer utilizes the alternative professional consultation option.
The Standards Board concluded that utilizing the ANSI standard would provide a more consistent and modern framework for workplace first aid supplies.
Hazard Assessment Requirement
The amendments do not permit employers to simply purchase a standard first aid kit and stop there.
Employers must evaluate workplace-specific hazards and provide additional first aid supplies when reasonably necessary to address those hazards. The rule specifically requires employers to assess unique workplace risks and supplement standard first aid supplies accordingly.
This means employers with higher-risk operations may need supplies beyond those contained in a standard ANSI Class A first aid kit.
Ready Access Requirements
The amendments also include requirements designed to ensure employees can quickly reach first aid supplies. Among other changes, employers must:
- Ensure employees have ready access to first aid kits;
- Clearly communicate the location of first aid kits to employees; and
- Clearly identify first aid kit locations where practicable.
According to the Standards Board, the revisions are intended to ensure employees can access first aid supplies within a matter of minutes following an injury.
Inspection and Replenishment Obligations
The approved amendments continue to require employers to maintain first aid supplies and ensure kits remain properly stocked. Employers must inspect and replenish supplies as necessary to maintain compliance.
Employers Impacted
The amendments are particularly relevant for:
- California general industry employers (i.e., most employers that are not covered by a more specific safety standard or industry-specific safety order);
- Construction employers;
- Multi-site employers;
- Manufacturing employers;
- Warehousing and logistics operations;
- Healthcare employers; and
- Employers responsible for Cal/OSHA compliance programs.
Employer Takeaway
Assuming final approval by the Office of Administrative Law, California employers should begin reviewing first aid procedures before the anticipated January 1, 2027 effective date. Employers should evaluate existing first aid kits, determine whether kits satisfy ANSI/ISEA Z308.1-2021 Class A requirements, assess workplace-specific hazards requiring additional supplies, and verify that employees have ready access to clearly identified first aid resources. General industry employers should also note the elimination of the longstanding physician-approval requirement and consider whether they will utilize the new ANSI-compliance pathway.