In this article we will answer all your questions about OSHA Standard 29 CFR 1910.151

At face value, OSHA standard 29 CFR 1910.151 seems like an unintelligible string of letters and numbers. However, it actually does have meaning! (And, no, it isn’t the name of a background character in Star Wars.)

OSHA, or the Occupation Safety and Health Administration, is an agency under the United States’ Department of Labor. Alternatively, CFR stands for the Code of Federal Regulations,  a compilation of 50 titles outlining major laws from federal agencies.

OSHA Standard 29 CFR 1910.151(b)

Each title of the CFR is broken down into multiple types of subcategories: titles → chapters → parts → subparts → sections. Let’s look at what this means for OSHA standard 29 CFR 1910.151 itself:

  • Title: 29 (Labor Laws)
  • Chapter: XVII
  • Part: 1910 (General Industry Standards)
  • Subpart: K (Medical and First Aid)
  • Section: 151

This knowledge is all well and good and can be handy when it comes to trying to navigate through the CFR online, but you’re likely still wondering what exactly OSHA standard 29 CFR 1910.151 specifically is about.

OSHA standard 29 CFR 1910.151 is divided into 3 parts (that’s right, the subdivisions aren’t done yet!):

  • Part A: “The employer shall ensure the ready availability of medical personnel for advice and consultation on matters of plant health.”
  • Part 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.”
  • Part 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.”

In this article, we’ll answer some clarifying questions you might have about the specifics of each subsection of OSHA standard 29 CFR 1910.151.

Part A: Medical Personnel

Medical services can be internal or external, meaning employers may rely on either a nearby healthcare facility for emergency services or on on-site employees trained in first aid. However, since the goal of OSHA standard 29 CFR 1910.151 is to ensure that care can be administered as soon as disaster strikes, it is best to have internal personnel present.

Part B: First Aid

The unfortunate truth is that OSHA has never actually provided an explicit definition of “near proximity.” Likely, this is because the industry that a workplace is operating in influences how much said workplace needs emergency services. For example, a workplace where the most common injury is a paper cut can stand to be further from a healthcare facility than one where chemical burns are a serious threat.

While it is technically true that not every workplace needs first aid supplies, so long as they are close by to a healthcare facility, the reality is that OSHA compliance officers expect to see first aid supplies present on-site when they conduct inspections.

According to OSHA, the following organizations provide acceptable first aid training courses:

  • American Red Cross
  • American Heart Association
  • National Safety Council

First aid responders fall under OSHA’s Bloodborne Pathogens standard, meaning they need bloodborne pathogen training as well.

Again, what constitutes “adequate” is not laid out in OSHA standard 29 CFR 1910.151 itself, but there have been multiple instances of OSHA pointing to ANSI/ISEA Z308.1 as a guide.

There are 2 classes of first aid kits:

  • Class A kits, which are intended to serve low-hazard environments, such as offices
  • Class B kits, which are meant for higher-risk environments, like laboratories

Both types of kits include the following supplies:

  • Adhesive bandages and tape
  • Antibiotics
  • Antiseptics
  • Breathing barriers
  • Burn dressings and treatments
  • Cold packs
  • Eye coverings
  • Eye/skin washes
  • Foil blankets
  • First aid guides
  • Hand sanitizers
  • Roller bandages
  • Scissors
  • Sterile pads
  • Trauma pads
  • Triangular bandage

Class B kits contain higher quantities of supplies than Class A kits and also include two supplies that Class A kits do not (padded splints and tourniquets).

If exposure to blood or other potentially infectious fluids is likely when administering first aid, employers also need to provide first aid responders with personal protective equipment (PPE). As outlined in OSHA’s Bloodborne Pathogens standard, PPE includes:

  • Face shields (or masks + eye protection)
  • Gloves
  • Gowns
  • Lab coats
  • Mouthpieces
  • Pocket masks
  • Resuscitation bags

Supplies should not be kept in a locked or otherwise inaccessible area. Additionally, travel through numerous doorways, hallways, and/or stairways should not be necessary to reach supplies, meaning larger facilities and/or those with multiple stories should house multiple kits.

Another aspect of having supplies “readily available” is keeping kits updated and in good condition. Employers of workplaces with particularly unique first aid needs should meet with their local fire department and/or emergency room to determine if there are any extra supplies they would benefit from keeping on-site.

Part C: Emergency Eyewash and Shower

OSHA standard 29 CFR 1910.151 states that facilities are needed wherever workers are at risk of exposure to “corrosive materials,” such as:

  • Acids
  • Bases
  • Dust particles
  • Solvents
  • Other chemicals

Below is a list of a few settings where workers are likely to run into the aforementioned materials:

  • Laboratories
  • Manufacturing plants
  • Battery charging stations
  • Construction sites

Flushing facilities are necessary and expected even at temporary worksites!

Similarly to with first aid kits, OSHA has clarified that complying with ANSI/ISEA Z358.1 also ensures compliance with OSHA standard 29 CFR 1910.151.

According to ANSI/ISEA Z358.1, eyewash stations and safety showers should:

  • Be located no more than 10 seconds way from hazard sites
  • Dispense tepid (60–100°F) water
  • Be able to flush for 15 minutes straight, minimum

Compliance with OSHA Standard 29 CFR 1910.151

To ensure that employers make active efforts to comply with OSHA standard 29 CFR 1910.151, OSHA conducts periodic workplace inspections. If a workplace is found to be in violation of the standard, employers may be hit with citations, fines, or other legal repercussions.

Some of our best tips for staying compliant with OSHA standard 29 CFR 1910.151 include:

  • Make sure employees trained in first aid have current certifications
  • Inspect first aid kits monthly and replace supplies as needed
  • Conduct periodic workplace risk assessments and adjust first aid supplies accordingly
  • Inspect safety showers and eyewash stations weekly
  • Test the functionality of safety showers and eyewash stations annually
  • Use signs to clearly indicate the location of safety showers and eyewash stations
  • Treat obstructions of first aid kits and flushing facilities as serious threats to safety and address them as such

To stay on top of inspections, we recommend using InspectNTrack. Not only does using InspectNTrack simplify the process of conducting inspections, it ensures inspections are never missed by sending out automated reminders whenever they are due.

Our software is already being used by tons of customers to track safety shower and eyewash station inspections—and, thanks to its inherent customizability, it can be configured to work for essentially any safety asset, first aid kits included!