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The Law on First Aid

A company’s management may not realize that there is a law on first aid in the workplace until a serious injury occurs on the job or a Workplace Safety and Insurance Board (WSIB) audit comes their way. Neither scenario is a pleasant way to find out that your company is not in compliance with the Ontario law on first aid.

All employers who are subject to the Occupational Health and Safety Act must comply with Regulation 1101. Who is covered by this Act? Almost every worker, supervisor, employer and workplace in Ontario is required to comply. The only exclusions are work done by the owner or occupant, a servant in a private residence and workplaces under federal jurisdiction. Federal workplaces are covered under a different law: the Canada Labour Code.

Regulation 1101, First Aid Requirements, outlines the obligations of employers to provide first aid expertise and first aid supplies on the work site for the care of sick and injured workers. Information respecting first aid stations, first aid kits, first aid training, the requirements for each industry, the contents of first aid boxes, what to do in cases of injury and disease and reporting of incidents are all detailed in this regulation.

The regulation provides guidelines for small, medium and large workplaces, each having increasing expectations based on the number of employees. For example, workplaces with less than five people require employees certified in Emergency First Aid (a 6.5 hour program). Workplaces with more than five people, require employees certified in Standard First Aid (a 13 hour program).

The regulation is specific with respect to the types of first aid training, and the types of equipment that must be on hand, but it does not indicate how many employees you must certify to be in compliance. This is the confusing part for most employers.

The decision on how many employees to train in first aid will take into consideration a number of factors. How many work areas does your company have? Any area with restricted access can be considered a separate work area. Consider shift work, holidays, sick days and the possibility that the first aider on site could be the one needing help. For each first aid station, you may need to train four or five employees or more in order to cover yourself for each situation. Remember a certified first aider must be available at all times that work is in operation and they must work in the vicinity of the first aid station. Their certification card must be posted at the first aid station so other employees know who to go to for help.

Many employers use the three minute rule for guidance when setting up first aid stations: If the injured worker can be discovered and assisted within three minutes then you have a good response time, because in four minutes, a non-breathing casualty starts to suffer brain damage. More information on first aid requirements can be found on the web.

For a PDF copy of the Guide to the Occupational Health and Safety Act, go to the Ontario Ministry of Labour website: For a PDF copy of the Regulation 1101 First Aid Requirements, go to For information on the Canada Labour Code go to:

Byline: Submitted by Dianne Rende, Executive Director of St. John Ambulance, Peel Dufferin Branch. As Canada’s leading authority in first aid, St. John Ambulance is dedicated to improving health and safety at work, at home and at play. For more information visit
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