Emergency Medical Plan & First Aid - Cal/OSHA

When someone is badly hurt on a job site, the first ten minutes are decided long before the injury: who knows first aid, where the kit is, who calls, what number, what address, how the ambulance crew gets to the fourth floor. California writes that planning into law. This Cal/OSHA Emergency Medical Plan & First Aid Toolbox Talk covers Title 8, Section 1512 — the construction rule for emergency medical services — and what each part of it means for the crew.

Where the boundary of this talk sits#

This talk covers what Section 1512 requires employers to have in place before an injury. Giving first aid, using the kit, evacuation, and reporting serious injuries to Cal/OSHA belong to their own talks.

The anchor#

Here is the distinction that carries this whole talk: Section 1512 is a rule about the minutes before help arrives, and every piece of it has to exist before anyone is hurt — a written plan, people trained in first aid, a stocked weatherproof kit, a way to get the injured person out or help in, posted emergency numbers, and on tall or deep structures a litter and a two-way emergency call system — because none of those can be improvised during the emergency they are meant for; a crew that finds out where the kit is while someone is bleeding has found out too late.

A written plan, and everyone told#

Section 1512(i) requires the employer to have a written plan to provide emergency medical services, and the plan must specify how every applicable requirement in the section will be met. Section 1512(d) requires each employer to inform all of its employees of the procedure to follow in case of injury or illness.

That second requirement is the one crews can check. Every worker on site should be able to answer three questions: who do I tell, who calls for help, and where do I send the ambulance.

Federal OSHA's construction rule, 29 CFR 1926.50(b), requires that provisions be made before the project starts for prompt medical attention in case of serious injury. California goes further by requiring that the plan be written down.

Multiple employers, one plan allowed#

Section 1512(a) says that where more than one employer is involved in a single construction project, each employer is responsible for ensuring emergency medical services are available to its own employees. The employers may agree to share one program for the combined work force, but it must be adequate for everyone present. A shared plan has to be agreed and has to cover everyone — not an assumption that "the GC has it."

People trained in first aid#

Section 1512(b) requires each employer to ensure the availability of a suitable number of appropriately trained persons to render first aid. Employers on a site may pool trained people. The rule does not set a fixed ratio, so "suitable" depends on the size of the crew, how spread out the work is, and how far away help is.

The federal rule reads differently. 29 CFR 1926.50(c) requires a person with a valid first-aid certificate at the worksite only in the absence of an infirmary, clinic, hospital, or physician reasonably accessible in time and distance. California's Section 1512(b) contains no such condition — a nearby hospital does not remove the duty to have trained people on site.

The first-aid kit#

Section 1512(c) requires every employer working on or furnishing personnel on a construction project to provide at least one first-aid kit in a weatherproof container. The contents are either determined by an employer-authorized, licensed physician or follow the section's table, which scales the minimum contents with the number of employees — groups of 1 to 5, 6 to 15, 16 to 200, and more than 200. The contents must be inspected regularly so expended items are promptly replaced.

A kit that exists but is empty, locked in a gang box, or buried behind the seat of a truck three floors down does not do the job. Know where it is, and tell someone when you use something from it.

Getting help in, or getting the injured person out#

Section 1512(e) requires proper equipment for the prompt transportation of the injured or ill person to a physician or hospital, or an effective communication system to reach emergency services. It also requires the telephone numbers of these emergency services in the area to be posted near the job telephone or switchboard, or otherwise made available to employees where there is no job site telephone:

• a physician and at least one alternate if available;
• hospitals;
• ambulance services;
• fire-protection services.

Posting "911" is a start, but the rule asks for more: the numbers for the physician, hospital, ambulance, and fire services in the area. And the crew needs the site's actual address or gate location — "the job on Highway 99" does not get an ambulance to the right gate.

Eyewash and drench#

Section 1512(f) requires that where the eyes or body of any person may be exposed to injurious or corrosive materials, suitable facilities for drenching the body or flushing the eyes with clean water be conspicuously and readily accessible. On construction sites that includes wet cement, battery acid, and many chemicals. A water jug on the tailgate is not a drench facility.

Tall and deep structures: a call system and a litter#

Two requirements switch on at height or depth.

Section 1512(g) requires a two-way voice emergency communication system for buildings and structures five or more floors or 48 feet or more above or below ground level, to notify the persons designated in the emergency medical services plan.

Section 1512(h) requires at least one basket or equally appropriate litter, equipped with straps and two blankets or similar warm covering, for each building or structure five or more floors or 48 feet or more above or below ground level.

Both exist for the same reason: on a tall building, a deep excavation, or a tunnel shaft, an injured worker cannot walk out, and a phone may not work where they fell.

Where the duty sits#

8 CCR 1512 carries the whole duty: (a) multiemployer sites; (b) first-aid trained persons; (c) weatherproof first-aid kits; (d) informing employees; (e) transportation or communication and posted emergency numbers; (f) eyewash and drench facilities; (g) two-way emergency communication at five floors or 48 feet; (h) basket litter at the same height or depth; (i) the written plan. For contrast, federal 29 CFR 1926.50 requires prompt medical provisions and first aid, but not a written plan.

What can go wrong?#

• The kit is empty because nobody restocked it after the last cut.
• The posted sheet says "911" and nothing else, and nobody knows the site address.
• A worker is hurt on the sixth floor, there is no litter, and cell service drops in the stairwell.
• A worker splashes cement in his eyes and the nearest water is in a cooler.
• Subcontractors assume the general contractor's plan covers them, and it doesn't.

How do we manage this properly?#

• Write the plan — and make sure it covers every requirement of Section 1512.
• Tell everyone the procedure — who to tell, who calls, what address.
• Keep enough trained first-aiders — for every shift and every area.
• Stock and check the kit — weatherproof, known location, restocked after use.
• Post the numbers — physician, hospital, ambulance, fire, plus the site address.
• Eyewash where there are corrosives — clean water, easy to reach.
• At five floors or 48 feet — a two-way emergency call system and a basket litter.

Before you start#

Ask three people at random: who is trained in first aid today, where is the kit, and what address would you give the ambulance. If anyone hesitates, fix it before work starts.

Talk it over#

• If the person next to you collapsed right now, what would you do first?
• Where is the nearest eyewash or drench station?
• How would we get an injured worker down from the highest point on this job?

The bottom line#

California requires every construction employer to plan for injuries before they happen, in writing. Have enough people trained in first aid, a stocked weatherproof kit, a way to get the injured person to care or care to them, posted emergency numbers, and eyewash where there are corrosives. On structures five floors or 48 feet above or below ground, add a two-way emergency call system and a basket litter.

Frequently asked questions about Cal/OSHA emergency medical services#

Does California require a written emergency medical plan for construction?

Yes. Section 1512(i) requires the employer to have a written plan to provide emergency medical services that specifies how all the applicable requirements of the section will be met.

Download the Cal/OSHA emergency medical plan toolbox talk PDF#

Download this Cal/OSHA Emergency Medical Plan & First Aid Toolbox Talk as a printable PDF in English and Spanish, and post it next to the emergency numbers.

Related toolbox talks#

• First Aid and AED
• First Aid Kit Familiarization
• Emergency Response
• Emergency Evacuation Routes

Sources#

• Cal/OSHA, Title 8 CCR §1512 — Emergency Medical Services ((a) each employer responsible on multiemployer projects, combined program allowed if adequate; (b) suitable number of appropriately trained persons to render first aid; (c) at least one first-aid kit in a weatherproof container, contents by licensed physician or table by headcount, inspected regularly; (d) inform employees of the procedure; (e) transportation or communication, posted numbers for physician and alternate, hospitals, ambulance, fire protection; (f) emergency washing facilities; (g) two-way voice emergency communication at five or more floors or 48 feet or more above or below ground; (h) basket litter with straps and two blankets at the same height or depth; (i) written plan; operative 10-5-2012): https://www.dir.ca.gov/title8/1512.html
• OSHA, 29 CFR 1926.50 (federal: (b) provisions before the project for prompt medical attention; (c) certified first-aid person where no infirmary, clinic, hospital, or physician is reasonably accessible; (d) kits checked before each job and weekly; (e) transportation or communication; (g) quick drenching or flushing facilities): https://www.osha.gov/laws-regs/regulations/standardnumber/1926/1926.50

Written by FieldSafetyTalk's safety professional — a CSP, ASP, CHST and OSHA Authorized Outreach Trainer with 14+ years of international construction safety experience across federal, heavy civil, and industrial projects.

Hazards covered