California employers should take a fresh look at their first aid programs as the California Division of Occupational Safety and Health (Cal/OSHA) has approved first aid requirement updates applicable to both general industry and construction employers, marking one of the most significant changes to these rules in years.
These new first aid regulations are expected to become effective January 1, 2027, pending the Office of Administrative Law’s final approval.
Overall, these revisions shift an employer’s first aid programs’ focus from a physician-approved supply model to a more structured, hazard-based approach that emphasizes kit contents, accessibility and workplace-specific planning.
General Industry Employers
General industry employers have three main changes:
- Updated requirements for the contents of first aid kits;
- Accessibility to first aid resources for employees; and
- Evaluation of specific workplaces.
First Aid Kits
These new rules establish clear requirements for first aid kits. Rather than simply maintaining “adequate” first aid materials, employers must ensure that a sufficient number of kits are available to employees. Employers may follow the American National Standards Institute’s (ANSI) Z308.1-2021 Class A standard for kit contents or work with an authorized physician (or other licensed health care professional) to determine appropriate supplies.
First Aid Kit Accessibility
The changes also create new employer obligations aimed at improving employee access to first aid resources. Covered employers must communicate the location of first aid kits and, where feasible, identify those locations through signage, labeling or other visible means. In addition, first aid kits must include a first aid guide that aligns with ANSI standards or is selected by an authorized healthcare professional.
Workplace Evaluation
Perhaps the most important development is the requirement for employers to evaluate their workplaces and determine whether standard first aid supplies are enough. Employers must consider both employee work locations and the nature of workplace hazards when determining the number of kits needed. When a workplace presents unique or potentially serious hazards, additional specialized first aid supplies may be required. Depending on the environment, these could include supplies intended to address chemical exposures, heat-related illnesses, trauma injuries or other foreseeable risks.
Construction Employers
While construction employers will see many of their existing first aid requirements remain in place, these new rules add several operational responsibilities. Construction employers must ensure that:
- Enough first aid kits are available based on employee access needs;
- Verify kit contents when a kit is placed into service; and
- Keep supplies readily available throughout the project.
These requirements may be especially challenging on large jobsites, multi-employer projects or worksites where crews regularly move from one location to another.
Construction employers must also communicate first aid kit locations to workers and make those locations visible through signage or similar methods whenever practicable. Like general industry employers, construction employers must evaluate workplace hazards to determine whether additional kits or specialized supplies are necessary.
The updated regulations also create compliance considerations for employers that stock chemical injury treatment supplies in first aid kits. If those supplies are available, employers should ensure that emergency procedures, Safety Data Sheets and employee trainings are consistent with kit contents and anticipated workplace hazards.
Steps Employers Should Consider Now
Employers should start preparing for these new regulations, including:
- Review existing first aid kits and compare them against ANSI-based standards.
- Evaluate whether current kit locations provide employees with prompt access.
- Add signage or other methods to clearly identify kit locations.
- Conduct a workplace hazard assessment to determine whether specialized first aid supplies are needed.
- Review hazard communication procedures and chemical emergency response protocols.
- Update emergency action plans, first aid programs and emergency medical services procedures as necessary.
- Review and update their Injury and Illness Prevention Plan (IIPP) as needed.
The revised regulations underscore Cal/OSHA’s expectation that first aid preparedness should reflect each workplace’s specific risks. For HR professionals and business owners, compliance will likely require more than purchasing new supplies. Employers should also evaluate accessibility, communication, training and hazard-specific planning to ensure their first aid programs meet the new standards and effectively support employee safety.
Shannon Claire, J.D., Employment Law Expert, CalChamber
CalChamber members can read more about minimum workplace safety requirements, IIPP, and employer obligations to provide personal protective equipment, or review their safety programs with HR California’s Safety Program Self Audit Checklist. Not a member? Start your free 7-day trial membership today!
