OSHA's construction medical standard is short, but it raises one practical question for every site.
The core rule (1926.50)
- The employer must ensure medical personnel are available for advice and consultation.
- In the absence of an infirmary, clinic, hospital or physician that is reasonably accessible in terms of time and distance to the worksite, a person with a valid first aid certificate must be at the worksite to render first aid.
- First aid supplies must be easily accessible, and checked before being sent to each job and at least weekly.
- Emergency phone numbers must be posted where there is no communication system to call for help.
- Where corrosive materials can splash eyes or body, quick-drenching or flushing facilities are required.
OSHA has interpreted "reasonably accessible" to mean, for life-threatening injuries like stopped breathing or severe bleeding, a response time of about 3–4 minutes. On most sites, that means having a trained person there.
Track the expiry
First aid and CPR certificates expire on the issuer's schedule, commonly every two years. Record the expiry date for each trained person, and make sure each site has at least one current cert per shift.
Pair it with an AED plan
AEDs are not required by 1926.50, but many GCs require them on larger sites. Your CPR training should cover AED use.
How to decide if your site needs a trained first aider
The standard does not give a mileage number. It asks whether medical help is "reasonably accessible" in time and distance, and OSHA's interpretations point to about three to four minutes for life-threatening emergencies such as stopped breathing, cardiac arrest or severe bleeding. Ask three questions for each site:
- How long would an ambulance take to reach the person, not the gate? On a high-rise, add the time to get from the street to the 14th floor.
- Is there a clinic or infirmary on site or next door? A hospital campus job may qualify; a highway job almost never does.
- Will the emergency number actually work? Dead zones, basement levels and remote utility work can all delay a call.
If the honest answer to the first question is more than a few minutes, which it is on most construction sites, you need a person with a valid first aid certificate on site. In practice, most contractors plan for at least one per crew and per shift.
Coverage per shift and work area
One trained person in the trailer does not help a worker injured on the far side of a large site. Plan coverage by work area:
| Site type | Practical coverage |
|---|---|
| Single small crew, one area | At least one trained person in the crew |
| Multiple crews spread across a large site | One trained person per crew or work area |
| Night shift or weekend work | A trained person on that shift, not only on days |
| High-rise | Trained persons on the floors where work is happening |
| Remote utility or road work | One per crew, plus a plan for evacuation |
If your trained person is on vacation, the site still needs coverage. Train at least two people per crew so absences do not leave gaps.
Does OSHA require CPR on construction sites?
Not generally. Section 1926.50 requires a person with a valid first aid certificate, and many first aid courses include CPR, but OSHA's construction standard does not by itself require CPR certification for every site. There are exceptions where CPR is specifically required, such as electric power transmission and distribution work under Subpart V (1926.950 and following), which requires trained first aid and CPR responders on crews. Many general contractors also require CPR and AED training in their own safety programs.
As a safety manager I recommend CPR training for every first aider anyway. Cardiac arrest is the emergency where minutes matter most, and a first aid course without CPR leaves the most serious case uncovered.
Choosing a course
OSHA does not approve first aid courses. It expects training equivalent to what national organizations provide. Look for:
- Hands-on skills practice, not only video.
- Adult CPR and AED, and bleeding control including tourniquet use.
- Content that matches construction risks: falls, crush injuries, burns, eye injuries, heat illness, electrical shock.
- A certificate showing the expiry date.
Courses from the American Red Cross, American Heart Association, National Safety Council and similar organizations are widely accepted. Blended courses, online theory plus an in-person skills session, are fine; online-only courses without a hands-on skills check are a weak choice for construction.
First aid kits and eyewash
The standard requires first aid supplies that are easily accessible and checked before being sent out to each job and at least weekly. OSHA's Appendix A to 1910.151 points to the ANSI Z308.1 standard as a guide to kit contents. Practical points:
- One kit per crew vehicle and one in each work area on large sites.
- Weekly check with a simple tag on the kit: date and initials.
- Bleeding control: add a tourniquet and trauma dressings for crews using saws, grinders and other cutting tools.
- Eyewash: where corrosive materials can splash eyes or skin, quick-drenching or flushing facilities are required. A squeeze bottle is not enough for corrosives.
Posting emergency numbers and making the plan known
Where there is no communication system to call for help, emergency telephone numbers must be posted. I go further: put the site address, nearest cross street and the nearest emergency room on the posting, in English and Spanish. In an emergency, workers forget addresses. Cover it in the first-day orientation and in a toolbox talk at the start of each new project.
Tracking first aid certificates
First aid and CPR certificates expire on the issuer's schedule, commonly two years. Tracking them is simple if you treat them like any other expiring credential:
- Record each trained person's name, course, issuer and expiry date.
- Tag which sites and shifts they cover.
- Set reminders at 60 and 30 days, because classes fill up.
- Check before each new project that every crew still has a current first aider.
In a training matrix, first aid is one column with an expiry date, and it turns red before it lapses. A crew card tracker can send the reminders automatically.
Common first aid mistakes on job sites
- Assuming the OSHA 10 covers it. OSHA 10 is awareness training; it is not a first aid certificate.
- One trained person for the whole company. Coverage is per site and per shift.
- Expired certificates. A certificate that lapsed last month does not meet the standard.
- Empty kits. The weekly check is part of the rule, not a suggestion.
- No AED plan on large sites. Not required by 1926.50, but often required by GCs, and the best chance a cardiac arrest victim has.
A worked example: three sites, one contractor
A 40-person concrete contractor runs three jobs this month:
- Downtown hospital expansion. The emergency department is on the same campus, a two-minute walk. Medical help is reasonably accessible, but the GC still requires one CPR/AED-trained person per crew. Plan: follow the GC rule.
- Suburban school addition. The nearest emergency room is 15 minutes away. Plan: at least one first aider per crew, two on the larger pour crew, kits in each truck and at the pour area.
- Rural bridge deck. Ambulance response is 25 minutes or more, and cell coverage is patchy. Plan: two first aiders per crew, a trauma kit with tourniquets, a radio or satellite messenger, and the evacuation route agreed with the local fire department before work starts.
Same company, same standard, three different answers. That is why first aid coverage belongs in the pre-job planning checklist, not in a company-wide policy alone.
Sources and further reading
Read the first aid standards themselves before setting your site policy.
- 29 CFR 1926.50, medical services and first aid: the construction first aid rule.
- 29 CFR 1910.151: the general industry equivalent.
- OSHA Best Practices Guide: Fundamentals of a Workplace First-Aid Program: program design and training content.
- Your training provider's certificate terms, which set the renewal interval.