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
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: http://www.labour.gov.on.ca/english/hs/pubs/ohsa/index.php. For a
PDF copy of the Regulation 1101 First Aid Requirements, go to www.wsib.on.ca. For
information on the Canada Labour Code go to: www.justice.gc.ca
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 www.sja.ca.