OSHA-1st Aid, CPR, AED Required

OSHA & CPR: Who’s Required to Know It and Who’s Not?

Under OSHA’s General Duty Clause, every employer is responsible for keeping workers safe. “Each employer shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees.”

The health and safety of your workers should be a number one priority. But what is your responsibility to keep workers safe from incidents that are out of your control, like a heart attack?

Every year, according to the American Heart Association, there are more than 135 million cardiovascular deaths in the world. Of the ones that happen out of the hospital, the survival rate is only two to 11 percent. In the United States, more than 500,000 people experience cardiac arrests, and less than 15 percent survive.

In workplaces in the U.S., there are 10,000 cardiac arrests every year. If these workers receive immediate defibrillation, the survival rate can be as high as 60 percent. If they don’t, the survival rate is as low as five to seven percent.

The minutes after a cardiac arrest are critical. Cardiopulmonary resuscitation, or CPR, or an automated external defibrillator, or AED, can greatly increase the chance of survival. However, the American Heart Association notes that only half of workers know where an AED is located.

The value of knowing CPR and how to use an AED is immeasurable. As an employer, are you required to train your workers in CPR and AED use? What does OSHA say about certification? OSHA’s guidelines on CPR training are not very detailed and are therefore open to interpretation. There are a few industries where OSHA requires employees to be CPR certified. OSHA outlines these in various standards and in its publication, “Training Requirements in OSHA Standards.”

Required Industries

The industries where OSHA requires CPR certification for some workers include logging, electrical, dive team and confined spaces.

Logging. Some workers in the logging industry are required to be CPR trained under OSHA Standard 1910.266. This training must “remain current” and meet specific requirements, outlined in Appendix B.

Electrical. In the electrical industry, specific people must be certified in CPR if they work on exposed lines or “equipment energized at 50 volts or more.” If there are two or more employees at one location, at least two must be CPR trained. But, if new hires are certified within the first three months, only one person needs to be certified. In addition, when working at stationary locations, OSHA does not outline a specific number of people that need to be certified. Rather, OSHA says that enough people must be certified to guarantee that if an incident occurs, there is someone who can reach the person in four minutes.

Confined Spaces. Specific workers in permit-required confined spaces must be trained in CPR. At least one worker on the rescue and emergency services teams is to be trained and remain current in CPR training, according to OSHA Standard 1910.146.

Dive. For commercial dive team members, workers must be trained in CPR as outlined in OSHA Standard 1910.410, with an “American Red Cross standard course or equivalent.”

There are a few other industries where CPR is recommended, if not required. These can be found in OSHA Standards 1915 – Occupational Safety and Health Standards for Shipyard Employment and 1926 – Safety and Health Standards for Federal Service Contracts.

Recommended, but not required

For industries that do not fall under those categories, worker CPR certification is not required, but it is recommended. When it comes to CPR training and first aid requirements, OSHA said in a letter dated April 15, 1999, “Although it is not an OSHA requirement that employers provide Cardiopulmonary Resuscitation (CPR) training, OSHA’s ‘Guidelines for First Aid Training Programs’ recommends that CPR training be a general program element of a first aid program.”

In an interpretation letter dated January 16, 2007, OSHA explained that employers need to make sure that adequate first aid is available to workers in sufficient time. It can be performed by someone in the workplace or an external responder.

If an employer or worksite is not in “near proximity” to an infirmary, clinic, hospital or emergency service provider, “a person or persons shall be adequately trained to render first aid.” Although OSHA does not specifically define “near proximity,” the agency has explained it to mean three to four minutes in a letter of interpretation.

But a set time one company uses might not be necessary for another. In an interpretation letter, OSHA said, “OSHA recognizes that a somewhat longer response time of up to 15 minutes may be reasonable in workplaces, such as offices, where the possibility of such serious work-related injuries is more remote.”

No matter what time table you are working with, understanding the basic requirements of CPR and AED certification can be the difference between life and death.

In an interpretation letter from 2012, OSHA briefly outlines what is and isn’t required for certification. It notes that online training isn’t enough. Workers must practice the skills in person. The letter points to OSHA’s “Best Practices Guide: Fundamentals of a Workplace First-Aid Program” for guidance.

When determining how often to retrain/recertify workers, this guide offers a suggestion: “Numerous studies have shown a retention rate of six to 12 months of these critical skills. The American Heart Association’s Emergency Cardiovascular Care Committee encourages skills review and practice sessions at least every six months for CPR and AED skills. Instructor-led retraining for life-threatening emergencies should occur at least annually. Retraining for non-life-threatening response should occur periodically.”

(It should be noted the guide is just that, a guide. It doesn’t replace any standards. “The guide is advisory in nature, informational in content, and is intended to assist employers in providing a safe and healthful workplace.”)

Worker Interest

Is CPR training something workers are interested in? According to a survey by Edelman Intelligence for the American Heart Association, the answer is simple: yes. A total of 2,000 workers were surveyed in 2017. More than 90 percent said if their employer had first aid or CPR/AED training, they would likely sign up.

There’s no denying the importance of CPR training. The chance of saving a life greatly improves when CPR is used. Though it’s not required by OSHA for many organizations, it’s still a valuable tool you can use to improve your worker’s health and safety.

This article originally appeared in the June 2022 issue of Occupational Health & Safety.

ABOUT THE AUTHOR

Alex Saurman is a former Content Editor for Occupational Health & Safety, who has since joined OH&S’s client services team. She continues to work closely with OH&S’s editorial team and contributes to the magazine.

1910.151 – Medical services and first aid.

1910.151(a)

The employer shall ensure the ready availability of medical personnel for advice and consultation on matters of plant health.

1910.151(b)

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.

1910.151(c)

Where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use.

[63 FR 33450, June 18, 1998]

OSHA Letters  interpretation