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First-aid medical personnel and emergency eyewash guidance

Summary A correspondent asked OSHA to define available medical personnel and quick-drenching equipment under its first-aid standard. OSHA said qualified medical advice must be readily available but it did not set a single qualification test; for eyewash details it referred to a consensus standard and existing interpretation letters. OSHA archives the letter and warns it may no longer represent current policy.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1994-03-31-5
Date issued
March 31, 1994
Status
Archived by the agency
OSHA labels this an archive document and warns that it may no longer represent current policy.
Status last verified October 9, 2026

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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

March 31, 1994

Ms. Gretchen M. Mendez-Vilella, Esq.
[Recipient address omitted]
Dear Ms. Mendez-Vilella:

Thank you for your inquiry of February 27, requesting an interpretation of standard 29 CFR 1910.151, Medical Services and First Aid.

You specifically requested the following items:

  1. Definition and/or standards for the term "available medical personnel" included in the standard 29 CFR 1910.151(a).

Response: Advice and consultation on matters of plant health must be readily available from qualified medical professionals. Because of the wide range of medical requirements, the Occupational Safety and Health (OSHA) does not set criteria as to what is a qualified medical professional.

  1. Definition and/or standards for the term "quick drenching or flushing supplies" included in the standard 29 CFR 1910.151(c).

Response: Enclosed is a copy of ANSI 358.1-1990, American National Standard for Emergency Eyewash and Shower Equipment and a letter of interpretation stating that ANSI 358.1-1990 is acceptable to OSHA.

  1. Copies of CPLs or Compliance "guidelines" pertaining to the referenced 29 CFR 1910.151 terms or standards.

Response: Enclosed are several letters of interpretation and CPL 2-2.53, Guidelines for First Aid Training Programs, addressing various questions pertaining to standard 29 CFR 1910.151.

  1. Copy of (American National Standard Institute Inc.) ANSI Z358.1-1990.

Response: Already enclosed for item # 2.

  1. Copies of OSHA letters issued by the Office of Compliance Programs which set additional standards in documents #1 and #2 and pertaining to the aforementioned inquiry.

Response: The Office of Compliance Programs does not set standards. We only interpret existing standards. Copies of letters of interpretation are already enclosed for item # 2.

We appreciate your interest in employee safety and health. If we can be of further assistance, please contact David Garcia on 202-219-8031 x 121.

Sincerely,
John B. Miles, Jr., Director
Directorate of Compliance Programs

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