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.

 

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 http://www.osha.gov.

 


October [5], 1992

Mr. David R. Carnow, MD, FACPM
Vice President and Director
Carnow, Conibear, & Associates, Ltd., Eastern Division
One Central Plaza
11300 Rockville Pike, Suite 1205
Rockville, Maryland 20852

Dear Mr. Carnow:

Thank you for your inquiry of July 24, addressed to the Office of Information and Consumer Affairs, Occupational Safety and Health Administration, requesting all available public information about 29 CFR 1910.151, First Aid Programs, and answers to some specific questions.

Copies of pertinent interpretations are enclosed for your information.

Your specific questions and our responses are as follows:

Question 1. Does 29 CFR 1910.151 apply to all employers? If not, to whom does it apply?

Response: Yes, it applies to all employers in general industry, regardless of size, except for state and local government entities and employers that fall under the jurisdiction of other Federal Agencies.

Question 2. What is meant by "plant health" in 29 CFR 1910.151[(a)]?

Response: "Plant health" in 29 CFR 1910.151[(a)] means the overall safety and health condition of the employees in the plant.

Question 3. What does an employer do if he has no "health room" or other provisions for first aid?

Response: [For the response to this question, please see the 1/16/2007 letter to Mr. Brogan for OSHA's current policy on "near proximity."]

Question 4. What if an employer has 27 locations or offices and only one (the headquarters) has a health unit?

Response: The employer may seek assistance from outside first aid professionals that can meet the required response times, or the employer may provide his own adequately staffed and trained first aid staff that can meet the required response times for all locations.

Question 5. Does 29 CFR 1910.151 apply to small employers?

Response: The response to this question is the same as the response to question #1.

Question 6. Does it apply to offices?

Response: Yes, 29 CFR 1910.151 does apply to offices.

Question 7. Please explain the reference to sources of standards in [1910.151], specifically 41 CFR 50-204.6.

Response: 41 CFR 50-204.6 is a source standard from Title 41, Subtitle B, and it requires the availability of first aid to employees of employers granted public contracts from the Department of Labor. The language, for 29 CFR 1910.151 was derived from 40 CFR 50-204.6.

We appreciate your interest in employee safety and health. If we can be of further assistance, please do not hesitate to contact us.

Sincerely,



Roger A. Clark, Acting Director
[Directorate of Enforcement Programs]

[Corrected 06/13/07]