On March 4, 2022, the Board published the first set of proposed revisions to the First Aid in General Industry and Construction standards. On October 12, 2022, additional changes were published in a 15-Day Notice of Proposed Modifications. Revisions to First Aid requirements were originally prompted by a Board decision in 2011 to grant a petition that requested the requirement for a physician’s approval of the contents in first aid kits be removed.
PRR members were generally supportive of the March 2022 proposal and the positive revisions made by the Board to modernize and simplify the first aid kit requirements. However, the modifications in the 15-Day Notice were unexpected and raised major concerns; PRR subsequently submitted written comments on October 28, 2022, and advocated the Board remove the new onerous requirement to have specific ANSI/ISEA compliant containers for all first aid kits and suggested a phased-in effective period to allow members time to prepare and implement weekly inspection requirements for first aid kits.