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.

February 23, 2023

Mr. John A. Contino, MD
1101 Clover Hill Road
Wynnewood, PA 19096

Dear Dr. Contino:

Thank you for your letter to the Occupational Safety and Health Administration (OSHA) expressing support for annual CPR retraining and OSHA's previous guidance stated in CPL 2-2.53.

OSHA cancelled CPL 2-2.53 in 2007 (https://www.osha.gov/enforcement/directives/cpl-02-07-04). Your letter cites OSHA's current guidelines for CPR training contained in OSHA 3317-06N 2006, Best Practices Guide: Fundamentals of a Workplace First-Aid Program. Although retraining intervals are not mandated by OSHA, this guidance, at p. 13, recommends that "Instructor-led retraining for life-threatening emergencies[,]" specifically CPR and AED, "should occur at least annually."

OSHA has also published Letters of Interpretation (LOIs) that refer to CPR training. These LOIs were published in response to requests for clarification on OSHA Standard 1910.151, Medical Services and First Aid and can be found here: https://www.osha.gov/laws-regs/standardinterpretations/standardnumber/1910/1910.151%20-%20Index/result.

Some OSHA standards, for example: Permit-required confined spaces (29 CFR 1910.146), Logging operations (29 CFR 1910.266), Electric power generation, transmission, and distribution (29 CFR 1910.269), Qualification of Dive Team (29 CFR1910.410), and Construction Subpart V, Power Transmission and Distribution [1926.951 and 1926.968] have specific requirements that employees be trained in first aid and CPR. If an employer is covered by one of these specific standards, CPR training would be required. However, while OSHA supports the annual CPR retraining intervals, as noted in the Best Practices Guide, the Agency does not mandate the frequency of refresher training.

We hope you find this information helpful. Thank you for your dedication to worker safety.

Sincerely,

Andrew Levinson, MPH, Director
Directorate of Standards and Guidance

[Corrected 11/27/2023]