OHS Code Explanation Guide

Published Date: July 01, 2009
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Part 11 First Aid

Section 178 Providing services, supplies, equipment

Subsection 178(1)

The OHS Act requires employers to protect the health and safety of workers performing work for them, as well as the health and safety of other workers present at the work site where the work is being performed. In fulfilling this obligation, the employer is responsible for ensuring that first aid services, supplies and equipment are available at the work site. In a limited number of cases, a first aid room must also be provided.

The type of first aid services an employer must provide is based on three criteria:

(1) how hazardous the work is;
(2) the time taken to travel from the work site to a health care facility (a measure of the remoteness of the work site); and
(3) the number of workers on each shift.

To determine if the work performed is low, medium, or high hazard work, refer to Tables 1 and 2 of Schedule 2. According to the Tables, work that is neither low hazard or high hazard is classified as medium hazard work.

For the purposes of this Part, work sites are classified based on the length of time required to get an ill or injured worker from the work site to a health care facility under normal travel conditions. In most situations, “normal travel” involves the use of a vehicle on some type of roadway under weather and road conditions that are usually and frequently experienced at that work site. In some situations however, “normal travel” may involve the use of a boat, aircraft, or helicopter, as might be the case at a remote work camp.

When determining the classification of a work site, consider the means of transportation usually and frequently available. If a road-accessible work site is serviced by a helicopter once every few days, then the travel time to the health care facility should be based on the time taken by a vehicle to travel the distance as the helicopter is not usually and frequently available for the transport of an ill or injured worker. Classifying a work site as close, distant, or isolated helps establish the first aid services, equipment and supplies at the work site. The required services, equipment and supplies are listed in Tables 5, 6 and 7 of Schedule 2.

The final criterion for establishing the type and level of first aid services to be provided is the number of workers on each shift. Tables 5, 6 and 7 provide this information.

Figure 11.1 presents a flow chart for determining the type of first aid services that must be provided at a work site.

Application for acceptance

The Director of Medical Services only has the authority under the OHS Act to grant acceptances for a requirement listed in the OHS Code.

Section 34 of the OHS Act requires that the suggested alternate first aid services, first aid supplies, or first aid equipment provide a level of worker protection that is equal to or greater than what is already required by this Part.

Employers can apply in writing to the Director of Medical Services for an “acceptance” to one or more of the requirements of this Part of the OHS Code. The employer explains their alternative to the requirement(s) and provides sufficient justification and supporting information to allow the Director to evaluate the alternative.

Figure 11.1 Determining first aid requirements

Subsection 178(2)

According to the OHS Act, every work site must have a prime contractor if there are two or more employers engaged in work at the work site at the same time. The prime contractor for a work site is the contractor, employer or other person who enters into an agreement with the owner of the work site to be the prime contractor. This prime contractor is responsible for making sure that appropriate first aid services, supplies and equipment are available at the work site as required by this Part. The services, supplies and equipment must be available and accessible during all working hours as required by section 179(a)(ii) of this Part.

For more information
The Prime Contractor
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Educational institutions

Educational institutions are responsible for providing first aid services, supplies and equipment for workers as required by Table 6 of Schedule 2 for the number of teachers, support staff and maintenance personnel and other workers at the work site.

For the purposes of this Part, students taking training at grade schools, technical colleges and universities are not considered workers. However, a university student working as a teacher’s assistant is a worker, and must therefore be included in the total number of workers.

Although the OHS Act does not apply to students, the first aid requirements outlined in Table 6 of Schedule 2 should be used as a guideline for providing first aid services, supplies and equipment.

For more information
Are Students Workers?
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Subsection 178(3)

This subsection allows employers and the prime contractor at a project to jointly supply first aid services, supplies and equipment to the work site. Such a sharing of responsibilities and resources must be described in a written agreement and must be based on the total number of workers at the work site.

Example: Construction company ABC has 100 workers working at a work site. According to Table 2 of Schedule 2, construction is high hazard work. Assuming the work is performed at a close work site, then according to Table 7 of Schedule 2, the employer must provide two Emergency First Aiders, two Standard First Aiders and one Advanced First Aider.

If construction company XLR has 100 workers and also begins working at the same work site, then the site requires a prime contractor and the first aid requirements for the site are based on 200 workers. According to Table 7 of Schedule 2, the prime contractor must ensure that two Emergency First Aiders, two Standard First Aiders and either one nurse or one EMT-P, and a first aid room are provided. By cooperating on their responsibilities, the two employers can share resources, avoid duplication of first aid services and maintain the required first aid coverage.

Subsection 178(4)

Table 4 of Schedule 2 lists the requirements for a permanent first aid room. A first aid room that is temporary or mobile must also meet the requirements of Table 4 of Schedule 2 except that if it is not practical to have hot water, a supply of cold potable water is acceptable.