OHS Code Explanation Guide

Published Date: July 01, 2009
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Part 11 First Aid

Section 184 First aid records access

A person with custody of first aid records must ensure that access to the first aid records is limited to the worker unless the person is allowed to release the information under privacy and access to information laws passed by the province of Alberta or the Government of Canada. Such privacy and access to information laws may authorize or require the disclosure of information such as first aid records.

Section 8 of Alberta’s Occupational Health and Safety Act allows access to first aid records by occupational health and safety officers and the Director of Medical Services, Alberta Human Services.

Other legislation such as the Workers’ Compensation Act, the Health Information Act (HIA), the Personal Information Act (PIPA) and Canada’s Personal Information and Electronic Documents Act may also have provisions authorizing access, use and disclosure of personal information.

A worker can allow his or her first aid record to be made available to other persons but permission must be in writing indicating the information that can be released, the name of the person to whom the information is to be released, the date and the worker’s signature.

Employers that conduct incident investigations need to know the name of the worker, the date of the accident or incident, the date the accident or incident was reported and when first aid was given. Details of the injuries and first aid should be limited.

Persons with access to first aid records must keep the information confidential except when disclosing the information listed in section 8 of the OHS Act.

Posting first aid records with the information contained in subsection 183(2) on notice boards or distributing them throughout the company is not allowed. General information that does not contain any specifics can be distributed to workers and other work sites to increase safety awareness.

An employer must provide the worker with a copy of their first aid record upon request.

At work sites where owners have entered into an agreement with the prime contractor to provide first aid services and the prime contractor’s first aiders are used, the worker can request a copy of his or her first aid record from the first aider. The prime contractor or employer is responsible for ensuring that the worker receives a copy of the first aid record when one is requested.

If the worker requests the first aid record some time after the injury, the worker should request the record from the employer. If the employer is no longer in business, the worker should direct his or her request to the prime contractor. It is recommended that prime contractors and employers develop a procedure for handling worker’s requests.

Tables 1 and 2 of Schedule 2 Low hazard work, high hazard work

Degree of Hazard
One of the criteria used when determining the type of first aid services, equipment and supplies that an employer must provide is the degree to which the work is hazardous. Hazard is a method of estimating the potential for a worker to be injured or become ill while performing his or her work.

Tables 1 and 2 of Schedule 2 are used to determine if the work performed is low, medium or high hazard work. According to the Tables, work that is neither low or high hazard is classified as medium hazard work. As the hazard increases, so do the requirements for first aid services in terms of the number and qualifications of first aid providers and the types and quantities of first aid equipment and supplies.

Low hazard work
Low hazard work is typically clerical or administrative type work. Dispersal sites are classified as low hazard because few workers are normally present there during working hours. Workers usually report to a dispersal site and then move on to the location where work is actually performed.

Low, medium, and high hazard at the same time
Situations commonly arise in which a work site consists of work areas having different hazard classifications. Where work being performed with different hazard classification cannot be separated, employers should classify the entire work site at the highest hazard classification level. Where work can be separated physically or administratively, the employer may choose to have different hazard classifications at a work site. For example, where there is a work site with  low and high hazard work areas separated from one another, the employer must meet the first aid requirements for low hazard and high hazard work respectively, based on the number of workers at the work site.

In classifying areas, the presence of equipment common to high hazard work that appears in a medium hazard work site is insufficient for classifying the area to the higher level. How often the equipment is used, by how many workers, the type of operations it is used for, the environment in which the equipment is located, etc. influence the classification.

Industrial process facilities not elsewhere specified
Subsection (b)(xi) of Table 2 refers to “industrial process facilities not elsewhere specified”. For the purposes of the OHS Code, an industrial process facility is taken to mean a structure within which, or a location at which, an industrial process is carried out. An industrial process is a procedure involving chemical or mechanical operations that normally process raw materials into a finished product that is usually offered for sale. Industrial processes are often carried out on a very large scale.

Industrial process facilities are of concern because large scale processes can be complex, involving complicated and extensive interactions between workers and materials, machines and processes. These interactions can lead to unexpected consequences that might result in a worker requiring first aid.

Workers at an industrial process facility may be exposed to a variety of hazards. For the purpose of defining the required first aid equipment, supplies and trained staff required at such a facility, the presence of the following hazards should result in the facility being classified as “high hazard work”:

(a) working in the presence of a biohazardous material, toxic substance or chemical, which, if released, would result in workers needing immediate medical treatment as a result of inhalation or eye or skin contact;
(b) working in the presence of equipment or machinery containing substances under high pressure, substances that may explode or catch fire, or substances that may react dangerously when combined with another process material;
(c) using tools, equipment, or machinery for high-speed grinding, cutting, chipping, or drilling;
(d) working near mobile equipment where there is a possibility of a worker being struck;
(e) working at elevations;
(f) entering confined spaces where toxic atmospheres may exist or develop; and
(g) working where there are other hazard factors that may expose workers to risk of serious injury or occupational disease.

Table 3 of Schedule 1 First aid equipment and supplies

Barrier devices, gloves
Table 3 of Schedule 2 lists the contents of the four types of kits required by this Part. Disposable surgical gloves and resuscitation barrier devices are intended to be used to prevent accidental contact with blood or body fluids. Surgical gloves do not need to be sterile.

Recommended practices
First aid kits should not contain any prescription or non-prescription drugs. The inclusion of symptom-relief medication(s) is beyond the scope of first aiders. The routine inclusion of over-the-counter medication(s) in first aid kits is not recommended as there is no established benefit and there is a potential for problems. If an employer determines that it is necessary to provide over-the-counter medication(s) in a first aid kit, a physician should be asked to prepare a policy and procedures to cover their use. Health care professionals would then be designated to give medications.

For more information
Medication in First Aid Kits
Bulletin FA014

Table 4 of Schedule 1 First aid room requirements

First Aid Room
Table 4 of Schedule 2 lists the characteristics of a permanent first aid room and the first aid supplies to be contained in that room. First aiders, first aid supplies and first aid equipment needs to be readily accessible and located near the work area. A first aid room need only be provided in cases where there are 200 or more workers per shift performing medium hazard work (see Table 6 of Schedule 2), or there are 100 or more workers per shift performing high hazard work (see Table 7 of Schedule 2).

Supervision of First Aid Room
When a first aid room is required, the most highly qualified first aid person is in charge of it. In the case of high hazard work involving 100-199 workers per shift at close, distant, or isolated work sites (see Table 7 of Schedule 2), the first aid person in charge should be the advanced first aider.

Oxygen therapy equipment provided in the first aid room must meet the requirements of CSA Standard Z305.12-06, Safe Storage, Handling and Use of Portable Oxygen Systems in Residential Buildings and Health Care Facilities. “Oxygen” and “No Smoking” signs should be placed on oxygen delivery equipment and storage rooms.

Oxygen cylinders must be hydrostatically tested every five years and the test date marked on the cylinder. Oxygen tank labels must include a Drug Identification Number (DIN) and the fabricator’s name and address. Only suppliers licensed to refill oxygen bottles can do so.

Tables 5, 6, and 7 of Schedule 2 First aid requirements for work

First Aid Qualification Levels
The Tables state minimum levels to which first aid personnel must be trained for various work site situations. In all cases, these minimum levels can be exceeded. For example, a nurse or Emergency Medical Technician – Paramedic can replace an Advanced, Standard or Emergency First Aider; an Advanced First Aider can replace a Standard or Emergency First Aider; and a Standard First Aider can replace an Emergency First Aider. Table 11.1 summarizes this relationship:

Table 11.1 Comparison of qualification levels

Most Qualified Nurse
or Emergency Medical Technician-Paramedic
Advanced First Aid
or Emergency Medical Technician-Ambulance
or Emergency Medical Technician
or Emergency Medical Responder
Standard First Aider
Least Qualified Emergency First Aider

Where reference is made to “3 blankets” in these Tables, at least one of these blankets should be of a woven fabric such as wool, polyester or other material. In addition to providing warmth, such blankets can also be used for positioning or immobilizing the limbs or head during care and treatment. Depending on the work site, one or more of the remaining blankets might be a space blanket used for keeping an ill or injured worker warm.

One worker per shift
As part of the first aid services provided, an adequate number of appropriately qualified first aid personnel as listed in Tables 5, 6 and 7 of Schedule 2 must be available at the work site to respond to any acute illness or injury that might reasonably be expected to occur. Although first aid training is recommended, the OHS Code does not require that a worker be trained in first aid if they are the only worker on a shift.

Numbers of first aid personnel required – examples
First aid personnel must be available and accessible during all working hours as required by section 179. When establishing the number of personnel required for work sites involving large numbers of workers, consider the following examples:

Example 1: Low hazard work, close work site, 201 workers at the work site per shift.
Referring to Table 5 of Schedule 2, the employer would require one emergency first aider, two standard first aiders, PLUS one standard first aider for each additional increment of one to 100 workers above 200 workers. In the case of 201 workers, the employer would therefore be required to provide one emergency first aider and three standard first aiders.

Example 2: Medium hazard work, distant work site, 201 workers at the work site per shift.
Referring to Table 6 of Schedule 2, the employer would require two emergency first aiders, two standard first aiders, either one nurse or one EMT-P, PLUS one standard first aider for each additional increment of one to 100 workers in excess of 200 workers. In the case of 201 workers, the employer would therefore be required to provide two emergency first aiders, three standard first aiders, and either one nurse or one EMT-P.

Example 3: High hazard work, isolated work site, 201 workers at the work site per shift.
Referring to Table 7 of Schedule 2, the employer would require four standard first aiders, one advanced first aider, either one nurse or one EMT-P, PLUS one standard first aider for each additional increment of one to 100 workers in excess of 200 workers. In the case of 201 workers, the employer would therefore be required to provide five standard first aiders, one advanced first aider, and either one nurse or one EMT-P.

These are minimum requirements and the employer is free to have additional trained first aiders.