First aid support for hazardous substance emergency response

July 17, 1991

Mr. John Pompei
Administrator
Oregon Occupational Safety and Health Division
Department of Insurance and Finance
[Recipient address omitted]
Dear Mr. Pompei:

This is an update to our response to your inquiry to Mr. James Lake concerning the intent of "advance first-aid" mentioned in section 29 CFR 1910.120(q)(3)(vi) of the Hazardous Waste Operations and Emergency Response standard. Please accept my apology for the long delay in this reply.

The referenced standard is as follows: "...Advance first-aid support personnel, as a minimum, shall also stand by with medical equipment and transportation capability." Both of the training levels addressed in your letter meet the intent of the standard. They do, however, go further than our requirements.

Advanced First Aid Per 29 CFR 1910.120

+--------------+----------------+----------------+--------------+
|
| TRAINING LEVEL | TRAINING HOURS | AMBULANCE |
+--------------+----------------+----------------+--------------+ | State of | Advance Life | >110 hours | YES |
| Oregon | Support | | |
| | (EMT-3) | | |
+--------------+----------------+----------------+--------------+
| Emergency | Basic Life | 110 | YES |
| Responders | Support | | |
| | (EMT-1) | | |
+--------------+----------------+----------------+--------------+
| OSHA | Advance First | No Specified | NO |
| | Aid | | |
+--------------+----------------+----------------+--------------+

*"Advance first aid" means advance first aid as evaluated by a competent professional. Training must be tailored to the specific needs of the workplace conditions. Individuals trained to this level should be capable of providing basic first aid involving maintenance of the airway, control of bleeding, immobilization of fractures, CPR and similar duties which do not require the use of the medical equipment carried on ambulances. An example of a course which meets the intent includes the U.S. Department of Transportation's Emergency Medical Services: First Responder Training Course.

To further assist you, we have enclosed a copy of OSHA Instruction CPL 2-2.53, Guidelines for First Aid Training Programs.

We hope this information is helpful. Again, we apologize for the delay in this response.

Sincerely,
Patricia K. Clark, Director
Directorate of Compliance Programs
Attachment

[The requester's February 14, 1990 letter reproduced on the OSHA page is omitted here.]