WorkSafeBC has amended its regulations to enhance requirements that employers in British Columbia provide first aid in their workplaces. These changes to BC’s Occupational Health and Safety (OSH) Regulation were effective November 1, 2024. The remainder of this note summarizes first aid requirements, highlighting the latest enhancements to direct requirements and to procedural requirements.
How have the direct requirements expanded?
BC’s Occupational First Aid revisions apply to most requirements (OHS Rule 3.14 – 3.21, and Schedule 3-A). Changes include the following:
- Expand requirement to provide “equipment, supplies, facilities, first aid attendants and services” necessary for injured employees to be provided first aid, and transported to receive medical treatment, which is now “at least” the employer’s requirement, which now includes “any additional” measures necessary
- Formalize requirement to “conduct an assessment” of first aid needs to now require a written assessment that sets out at least the following:
- number of workers present who may require first aid at any time
- locations of workers
- nature and extent of the risks and hazards in the workplace, including whether the workplace as a whole creates a low, moderate or high risk of injury
- types of injuries likely to occur
- any barriers to first aid being provided to an injured worker
- time that may be required to obtain transportation and to transport an injured worker to medical treatment, and the methods of transportation available
- new requirement that the assessment be reviewed and updated in consultation with the joint committee or the worker health and safety representative
- expand requirement for employer-provided “equipment, supplies and facilities” to require them to be:
- suitable for their intended use [new]
- clean, dry and ready for use
- readily accessible [new]
- add to training requirements (changing as identified below) a formal requirement for drills or training annually and when procedures change
- add more explanation and flexibility regarding modes of emergency transport, including specific requirements when aircraft are used for transport
What formal risk factors have been provided?
The revisions also provide additional direction to employers for use when evaluating OSH hazards and associated first aid needs. These include four workplace characteristics:
- Number of workers at the workplace
- Hazard rating assigned to the industry
- Whether the workplace is “remote” (more than 30 minutes surface travel time from the nearest BC Emergency Health Services (BCEHS) ambulance station)
- Whether the workplace is “less accessible” (cannot be safely accessed by BCEHS ambulance, or includes any hazardous work area(s) that cannot be safely accessed by ambulance personnel)
How have requirements been aligned with Canadian Standards Association (CSA) standards?
An Explanatory Note to the revised rules notes:
The requirements in Schedule 3-A have been in place for almost 20 years with minimal updates. Since these requirements were introduced, there have been improvements in both first aid training and equipment, as well as the issuance of two Canadian Standards Association (CSA) standards: CSA Z1210-17, First aid training for the workplace – Curriculum and quality management for training agencies, and CSA Z1220-17, First aid kits for the workplace. These standards provide national guidance on workplace first aid training programs and first aid kits. The purpose of the proposed amendments is to update the first aid requirements, with a focus on remote high-risk industries, and to align the OHSR with the first aid training and first aid kits framework in CSA Z1210-17 and CSA Z1220-17.”
Now what?
Employers’ responsibility for first aid have been in place in Canadian OHS and US occupational safety and health jurisdictions for decades (I wrote about US OSHA’s requirements HERE). BC’s new requirements formalize provisions that have been best practices in BC and many other jurisdictions (and already required in some). Employers in British Columbia should be complying with these requirements, and all employers should take the opportunity to review their planning for and delivery of first aid to injured workers.
Self-Assessment Checklist
Does each of the organization’s worksites provide for first aid to respond to workplace injuries and illnesses?
- Are first aid supplies kept onsite?
- Are any employees trained to provide first aid, and if so are specific employees designated to do so?
- Has the employer identified offsite response and medical resources available if needed to respond to injuries and illnesses?
If so, has the employer reviewed these onsite activities and offsite resources to determine if they meet the requirements of BC’s revised requirements?
Where Can I Go For More Information?
- WorkSafeBC
- First Aid Requirements webpage
- Canadian Standards Association website
- Canadian Centre for Occupational Health and Safety (CCOHS) First Aid webpage
- US Occupational Safety and Health Administration (OSHA) Medical and First Aid webpage
About the Author
Jon Elliott is President of Touchstone Environmental and has been a major contributor to STP’s product range for over 30 years.
Mr. Elliott has a diverse educational background. In addition to his Juris Doctor (University of California, Boalt Hall School of Law, 1981), he holds a Master of Public Policy (Goldman School of Public Policy [GSPP], UC Berkeley, 1980), and a Bachelor of Science in Mechanical Engineering (Princeton University, 1977).
Mr. Elliott is active in professional and community organizations. In addition, he is a past chairman of the Board of Directors of the GSPP Alumni Association, and past member of the Executive Committee of the State Bar of California's Environmental Law Section (including past chair of its Legislative Committee).
You may contact Mr. Elliott directly at: tei@ix.netcom.com