What is the Cal/OSHA Standards Board doing about first-aid kit requirements?
The latest proposal implementing changes to first-aid kit requirements in the Construction Safety Orders and the General Industry Safety Orders was presented at the monthly meeting of the Occupational Safety and Health Standards Board on January 15, 2026.
Among other requirements, the proposed revisions require that the location of first aid kits be indicated clearly in the workplace and that employees have ready access. The proposal aims to clarify and modernize the rules, according to Cal/OSHA.
The proposed changes are in the California Code of Regulations (CCR) Title 8, Section 1512, Emergency Medical Services, in the Construction Safety Orders, and in Section 3400, Medical Services and First Aid, in the General Industry Safety Orders.
The proposed revisions are drawn from existing data that has been available for many years — for instance, the requirements for Class A first-aid kits in American National Standards Institute (ANSI)/International Safety Equipment (ISEA) Z308.1-2021.
Separate Requirements
Cal/OSHA notes that the proposed rules will not apply where a CCR Title 8 vertical standard includes its own first-aid kit requirements, such as:
- Logging and Sawmill Safety Orders (Section 6251);
- Mine Safety Orders (Section 6969);
- Agriculture Operations (Section 3439).
Advisory Committee
The advisory committee convened to review the list of first-aid supplies required by Section 1512 noted that the existing list is outdated and that requiring employers to adjust the specific types and quantities of supplies based on the number of employees on a job makes compliance unnecessarily difficult.
The committee generally concurred with the recommendation to align the first-aid kit requirements in sections 1512 and 3400 with the ANSI/ISEA Z308.1 standard, which it said would improve both compliance and employee safety.
In conclusion the committee recommended that sections 1512 and 3400 include language about specialized first-aid supplies that might be needed to address unique hazards in the workplace; that is, hazards to which the minimum set of first-aid supplies required by the ANSI/ISEA Z308.1 standard might be inadequate.
New Terms/Updated Equipment
Please note that the proposed first-aid revisions to sections 1512 and 3400 are quite extensive and contain many new terms and references to updated equipment.
It is highly recommended that employers review carefully the proposal heard on January 15, 2026 as outlined in the Standards Board’s Informative Digest of Proposed Action/Policy Statement Overview.
More background and documents related to the history of the first-aid rulemaking are available on the Standards Board’s first-aid page.
Because of the prolonged process this rulemaking has undergone, there still could be some additional revisions waiting to be brought to the surface before the final version is presented to the Office of Administrative Law for approval.
Column based on questions asked by callers on the Labor Law Helpline, a service to California Chamber of Commerce preferred members and above. For expert explanations of labor laws and Cal/OSHA regulations, not legal counsel for specific situations, call (800) 348-2262 or submit your question at www.hrcalifornia.com.
