Forget What Your Safety Manual Says About Injury Management – What Does OSHA Say?

A lot of companies have a safety manual that they bought from a service or maybe it was written by some previous safety manager and tends to be updated only when things change.   Over time, we tend to accept our written policies and procedures without looking at what they are supposed to accomplish.   Managing workplace injuries is one of those areas.  So just to take a fresh look at the issue, let’s go back to what the OSHA regulations actually say about managing injuries.  It is found in the  Medical Services and First Aid Standard (29 CFR 1910.151).  It is very simple and very clear:

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.

Companies tend to focus on the second part – CPR/first aid training and a cabinet of first aid supplies.  The first part tends to get glossed over.   It shouldn’t be, especially in the real workplace with OSHA’s current threat to cite companies that in any way discourage employees from reporting injuries.

If an employee is injured, at the least 1910.151(a) indicates that the company is responsible for the availability of “advice and consultation” from a qualified medical provider.  A co-worker with first aid training can’t just say “you are OK. Get back to work.”  Doing so puts the company at risk of violating the ban on discouraging reporting.

Now what about the first aid training referenced in 1910.151(b)?   OSHA interpretations have said that

In areas where accidents resulting in suffocation, severe bleeding, or other life threatening injury or illness can reasonably be expected, a 3 to 4 minute response time, from time of injury to time of administering first aid, is required. In other circumstances, i.e., where a life-threatening injury is an unlikely outcome of an accident, a 15 minute response time is acceptable.

Based on that interpretation, the decision by many companies to provide first aid training to some or all employees is prudent.  The challenge is in that part of the regulation that says they must be “adequately trained” to render first aid.   The regulation and the interpretation above imply that a first aid responder can deliver aid for a major injury, at least until the ambulance can arrive.  It is also unclear how injuries that are less than life threatening and more than first aid can be handled.  Do you send every case to the emergency room?  That would be unnecessary and prohibitively expensive.  Do you rely on an employee with a one-day first aid class to determine if an injured worker needs nothing more than first aid?  Probably not.

Those are the kinds of questions companies need to resolve and they may take consultation with a medical professional.   For companies that work in the field, the questions are complicated by the possibility of a remote location.  The bottom line is that it may be worth taking another look at the wording in your safety manual and thinking about how you can meet the regulatory intent in the real world.


Lifeline Strategies works with CORE Occupational Medicine to provide workplace health solutions for companies.  One of CORE’s services, TimeZero injury management is specifically designed to help clients fill the gap between serious injuries that require immediate care and simple first aid cases that can be handled by company personnel with adequate training.   CORE’s nurses are available by phone to consult with injured workers 24 hours-a-day.  If treatment is recommended, CORE has relationships with more than 3400 clinics around the country to offer quality care anywhere crews may be working.   For more information contact us at info@lifelinestrategies.com.

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