29 CFR 1910.151, the OSHA standard governing workplace first aid in general industry, is fewer than 100 words long. It covers three distinct obligations in three short sentences. Despite its brevity, more than 60 OSHA Letters of Interpretation have been issued clarifying what it requires — which tells you something about how often employers get it wrong and what the gaps between the text and the compliance reality actually look like.
This article covers the full legal framework for workplace first aid in the US: the text and meaning of 1910.151 and 1926.50, the role of ANSI Z308.1, what “near proximity” actually means in enforcement, the penalties for non-compliance, and the documentation obligations that OSHA inspectors expect to see.
The Two Primary Standards
Workplace first aid in the US is governed by two standards depending on the industry sector. Both share the same basic framework but differ in specificity.
The Full Text of 29 CFR 1910.151
The standard is short enough to quote in its entirety. Understanding exactly what each sentence requires is the starting point for compliance analysis.
What "Near Proximity" Actually Means
The phrase “near proximity” in 1910.151(b) has generated more OSHA interpretation letters than any other element of the standard. The operative interpretation is specific and more demanding than most employers assume.
ANSI/ISEA Z308.1-2021: The Kit Contents Standard
ANSI Z308.1 provides detailed information regarding the requirements for first aid kits; OSHA has often referred employers to ANSI Z308.1 as a source of guidance for the minimum requirements for first aid kits. The 2021 edition defines two kit classes that apply to different workplace risk profiles.
A chemical plant must stock burn treatment supplies; a sawmill must stock wound closure materials appropriate for laceration depth; a warehouse must address struck-by injuries. The ANSI kit classes set a floor, not a ceiling. Employers in high-hazard environments must supplement standard kit contents based on their specific hazard profile.
In first aid program audits conducted before OSHA inspections, stocking a Class A kit in a high-hazard environment is the most common single compliance gap. The employer purchased a standard commercial first aid kit, placed it in a cabinet, and has not revisited whether its contents match the hazard profile of the site. A fabrication shop with metal shears operating daily needs at minimum a Class B kit supplemented with a tourniquet and hemostatic dressing. Class A is not adequate and will not satisfy an OSHA compliance officer who reviews the kit following a laceration incident.
Training Requirements: What Satisfies the Standard
A training program must include instructor observation of hands-on skills, along with written performance assessments, and nationally accepted and medically sound first aid programs meet the requirements of 1910.151. It cannot be all computer-based.
The standard does not specify how many employees must be trained or mandate a renewal interval for general industry. However, instructor-led retraining for life-threatening emergencies should occur at least annually. The American Red Cross recommends CPR renewal annually and first aid renewal every two years.
Eyewash and Drench Facilities: The Section (c) Obligation
Section 1910.151(c) is triggered whenever employees may be exposed to corrosive materials. The compliance standard is ANSI Z358.1, which requires:
Required for continuous corrosive chemical exposure. Must deliver tepid water at the eye for at least 15 minutes. Must be within 10 seconds of travel from the exposure point. Requires weekly activation test and annual plumbing inspection.
Acceptable where plumbing is not available (construction sites, remote locations). Must still provide 15-minute flow. Solution expires and must be replaced on schedule. Still must be within 10 seconds of travel.
A 4-oz eyewash bottle in a first aid kit does not satisfy 1910.151(c) for corrosive exposures. It satisfies the kit contents requirement but not the immediate drench access requirement. An OSHA inspector will cite both deficiencies separately.
Penalties for Non-Compliance
Penalty amounts are adjusted annually for inflation. Current OSHA penalty maximums as of 2024:
Actual penalties depend on employer size, good faith, violation history, and gravity of the hazard. Small employers and those who demonstrate good faith during inspection typically receive reductions. Willful violations following an employee fatality can trigger criminal referral under Section 17(e) of the OSH Act.
Documentation: What OSHA Inspectors Look For
While 1910.151 does not explicitly require a written first aid program, an OSHA inspector following up after an incident will look for documentation that demonstrates the employer had an adequate program in place before the injury occurred.
State Plan Variations
Twenty-nine states and territories operate their own OSHA-approved State Plans, which must be at least as effective as federal OSHA but may be more stringent. Notable examples:
Employers in state-plan states should verify their state’s specific requirements directly, as state plans frequently add requirements that go beyond the federal standard without advance notice to out-of-state employers.
Common Compliance Mistakes
Sources and Regulatory References
- OSHA, “29 CFR 1910.151: Medical Services and First Aid”
- OSHA, “29 CFR 1926.50: Medical Services and First Aid (Construction)”
- OSHA, “1910.151 Appendix A: First Aid Kits (Non-Mandatory)”
- OSHA, “Best Practices Guide: Fundamentals of a Workplace First-Aid Program” (Publication 3317)
- OSHA, “Standard Interpretation: Near Proximity and First Aid Response Times” (2007)
- ANSI/ISEA Z308.1-2021: Minimum Requirements for Workplace First Aid Kits
- ANSI Z358.1-2014: Emergency Eyewash and Shower Equipment
- WC Safety, “OSHA First Aid Kit Requirements: 29 CFR 1910.151 and ANSI Z308.1” (May 2026)