Getting Compliant: The Latest Updates for BC’s Occupational First Aid Regulations

WorkSafeBC has been working with BC Emergency Health Services (BCEHS) in the amended first aid regulations. As indicated in the guideline, under G3.16 First Aid Assessment, Determining additional first aid service requirements — Section 3.16(1)(b):

Employers must consider known barriers that may affect BCEHS response time, or time to transport to hospital such as hours of operation, doctor availability, hospital diversion protocols, or routine closures of BCEHS stations that would significantly impact transport time to hospital. These factors may be temporary or permanent, but when they are known or reasonably foreseeable, they should be factored into the employer’s risk assessment. “Reasonably foreseeable” includes those that are known to the employer or workers through previous experience or observation, or that are widely publicized in the news or social media outlets. Where barriers to transport are identified, the employer should take all reasonable measures to eliminate or otherwise minimize the impact of these barriers on the time it may take to transport a worker to medical treatment. Consider providing supplemental emergency transportation to safely transport an injured worker to hospital or to meet BCEHS enroute and/or a higher level of first aid attendant and equipment to better manage injuries while waiting for BCEHS. First aid procedures should be updated as well to consider these barriers (e.g., in the event of a worker injury, consider hospital emergency room availability in transport decisions).

BCEHS working towards more ambulance services - More ambulance services coming soon to rural and remote communities across B.C. (bcehs.ca)

The definition of “remote” in the amended regulation is:

A workplace to which, under normal travel conditions, an ambulance that is a motor vehicle cannot travel from its base in 30 minutes or less but does not include a ferry.

An ambulance base means an ambulance station; therefore, you cannot calculate the distance to/from your worksite to the nearest hospital. Note: If the distance from the nearest ambulance station to your worksite is impacting you by moving you into a different workplace class (due to now being considered remote), then the distance from the nearest hospital would (e.g., from Class 1 to Class 2), you may consider applying for a variance.

It is permissible to drive an employee to medical services for a minor injury. However, the employer must create procedures for transporting an injured worker. First aid attendants receive training on when to refer workers to medical aid. First aid procedures should include procedures for:

• How an injured worker will be transported to hospital or medical services (e.g., walk-in clinic) if the worker is ambulatory and their condition in stable and not life-threatening
• How an injured worker will be transported to hospital if the worker is not ambulatory, or their condition is unstable or life-threatening (per rapid transport criteria [link to come])

Methods of transportation may include, a taxi, ride-hail, or by a co-worker in a company (or other) vehicle that is appropriately insured, maintained, and meets any other applicable requirements of Part 17 of the Regulation. Employers retain responsibility for ensuring the injured worker is safely transported without undue delay and must be able to show due diligence in this regard.

It may change your first aid procedures. Review all your first aid procedures and make any necessary changes. Conduct a first aid drill to ensure your procedures are effective.

WorkSafeBC has been working with BCEHS in the amended first aid regulations. BCEHS is working towards more ambulance services - More ambulance services coming soon to rural and remote communities across B.C. (bcehs.ca)

“Normal travel conditions” should be determined by the average time it takes to drive to (or from) the nearest ambulance station by a motor vehicle following the rules of the road, during the normal working hours of the employer’s workplace. Employers must consider known barriers that may affect BC Emergency Health Services (BCEHS) response time, such as road conditions which may make a workplace inaccessible to BCEHS or other barriers such as train crossings, lift bridges, temporary road closures, construction zones, etc. Where barriers to transport are identified, the employer should take all reasonable measures to eliminate or otherwise minimize the impact of these barriers on the time it may take to transport a worker to medical treatment.

Employers must consider additional barriers that could potentially limit or delay a worker’s access to first aid. If a particular barrier is known, such as BC Emergency Health Services (BCEHS) will not enter the area without police escorts, then employers must consider this in their assessment and first aid procedures.

All three conditions must be met to be considered "not less accessible." Workplaces that are remote or that cannot readily be reached by an ambulance travelling by land, or where BC Emergency Health Services (BCEHS) cannot safety access such as back country, down steep embankments, rough terrain, where high risk of avalanche, flood, etc. exist, will fall in this category regardless if the workplace has alternative provisions in place to safety rescue workers from hazardous areas. Workplaces where workers may be working in hazardous areas should be considered less accessible, unless:

1. The workplace is not remote, nor otherwise less accessible, and
2. The employer has developed alternative provisions to safely rescue workers in accordance with the requirements of section 4.13 of the Regulation. For the purpose of this section, “safely rescue” will be taken to mean:

• Moving the injured worker from the hazardous area to an area accessible to BCEHS in a way that will not cause additional injury or further exacerbate pre-existing injuries or illnesses. This will generally include packaging and transporting an injured worker in accordance with the practices taught in the transportation endorsement course, unless impractical to do so (for example, for workers working in a bucket truck that can be lowered to the ground, or workers working in confined spaces who remain on a harness that allows them to be pulled from the hazardous area)
• Where practicable to do so, and without putting the first aid attendant at unreasonable risk, nor delaying transport to an area accessible to BCEHS, provide immediate and on-going first aid to the injured worker during the rescue. The level of first aid provided during rescue should be sufficient to address injuries likely to arise in the less-accessible area.

All workers who regularly attend a workplace must be included in the worker count for that workplace, even if they are on-site only briefly. When determining the minimum first aid requirements for a workplace, employers should count dispatched or transient workers as follows:

• Count as one worker each dispatched worker who stays within 10 minutes' surface travel time from the workplace for more than 50% of the shift.
• Count one-quarter of the number of workers who travel more than 10 minutes' surface travel time from the workplace more than 50% of the shift.
• Pro-rate the number of transient workers based on an estimation of the time they attend the workplace. For example, if a warehouse has eight loading bays that are serviced by a fleet of delivery trucks throughout the day, the employer may determine that it is reasonable to include an additional eight workers for the purpose of determining first aid requirements at the warehouse, if that is the maximum number of delivery drivers that are likely to be at the workplace at any given time.

Separate first aid assessment(s) are required for dispatched workers when they are not present at the central location.

Separate first aid assessments would be required at each worksite because each site may have a different number of workers present, and a different distance to/from an ambulance station. To determine the workplace class for that site, a first aid assessment must be conducted. The second part of an employer’s 2-part duty is to determine and list any additional first aid services that may be required at that site – this would be documented on page 4 of the First Aid Assessment Worksheet.

The hazard rating assigned by WorkSafeBC should be considered the minimum acceptable hazard rating for workplaces of employers assigned to that CU, with the following exception, multiple-employer workplaces where the work is phased and not all phases have the same hazards present. E.g., A prime contractor in residential construction classification unit 721027 (House or Other Wood Frame General Contracting, Construction, or Renovation Work) with hazard rating of high is providing first aid services when the only work being conducted is painting with hazard rating of medium – a hazard rating of medium may be used. No other subtrades must be conducting any other work at the time of the painting when the medium hazard rating is used. A separate first aid assessment must be documented using this lower hazard rating. If multiple employers are doing work at the same time, the hazard rating of the prime contractor must be used - it is the prime contract’s responsibility to coordinate the safety at the worksite which includes provisions for first aid.

A National Lifeguard designation will not be considered equivalent to an Intermediate or Advanced first aid certificate unless the National Lifeguard course has been submitted, reviewed, and accepted by WorkSafeBC as an equivalent first aid course. If/when the National Lifeguard courses are submitted for acceptance by WorkSafeBC and align to the CSA Z1210-17 and B.C. Plus, WorkSafeBC will provide equivalency at that time. First aid attendant certification - WorkSafeBC

There is no prerequisite for taking the Intermediate First Aid training. Competency will be assessed throughout the duration of the 2-day course by the course instructor.

First aid training providers can either develop their own curriculum; aligned to CSA Z1210-17, and have it approved by WorkSafeBC, or enter into a training agreement and use the WorkSafeBC developed first aid curriculum. First aid training providers are subject to periodic quality assurance audits to ensure that WorkSafeBC requirements and standards are adhered to. WorkSafeBC approved training providers: Workplace First Aid Training Providers | WorkSafeBC

Drills provide workplace parties with a chance to practice their roles and responsibilities, which helps to ensure an effective response in the event of a real emergency. Drills also provide an opportunity to identify and resolve potential challenges or deficiencies in the employer’s written first aid procedures. A first aid drill should include mock scenarios that support the evaluation of the effectiveness of the procedures. First aid drills should include all workplace parties that have duties outlined in the employers first aid procedures. Drills should reasonably approximate the expected response to an incident requiring first aid, up to the point of transport by Emergency Transporation Vehicle (ETV). Drills should be designed in such a way that they do not pose an undue hazard to workers or the public and first aid attendants participating in the drill. Where necessary to ensure worker safety, dummies may be used to simulate injured workers when testing procedures for transporting an injured worker to an ETV or area accessible to BC Emergency Health Services (BCEHS). If a drill of a particular first aid procedure poses an undue hazard to workers or others, a table-top exercise may be used to supplement drill activities, if it will allow for an effective evaluation of the employers’ procedures. Note: Reviewing a real incident requiring first aid will not generally be considered an acceptable alternative to a drill as this practice may discourage the identification of deficiencies and/or introduce privacy or other concerns for injured workers, first aid attendants, and employers. First aid drills can be incorporated into emergency drills if this is the procedure you are evaluating. Make sure to document the details for first aid and emergency evacuation so you can provide evidence of both drills to a WorkSafeBC officer. If performing both drills together, ensure you take into consideration the potential for a real first aid emergency and have a plan in place should this occur during the drill.

Drills should be conducted as soon as practicable after the implementation of the updated regulations on November 1st, 2024.

There are no first aid drill templates available on the WorkSafeBC website. A first aid drill template should be like an emergency evacuation drill template, at a minimum, logging the date/time of the drill, the drill scenario, who was involved, was the drill successful or were deficiencies identified, are there action items and/or corrections required, and who is assigned the corrective items and by what date. WorkSafeBC will consider creating a generic first aid drill template as a future reference resource. MSABC has a table top exercise that may be used, however, tabletop exercises alone or reviewing an incident alone is not sufficient, an actual response drill must be done. MSABC encourages businesses to include these in their fire drill, evacuation, confined space mock rescues. Table top exercise documents can be used as guidance on what to do, record, and discuss. MSABC also has a generic fire drill template document that can be adjusted sufficiently to record first aid drills. If you are looking for support in running drill scenarios, please reach out to an MSABC Safety Advisor at [email protected].

Refer to the guideline to see the Advanced first aid kit (based on CSA Z1220 Type 3: Intermediate first aid kit — medium, includes oxygen kit) contents list. Reference: OHS Guidelines for Part 3 - Occupational First Aid | WorkSafeBC

Refer to the guideline to see the content requirements for the basic, intermediate, and advanced first aid kits. Reference: OHS Guidelines for Part 3 - Occupational First Aid | WorkSafeBC

Medium refers to the name of the CSA kit. When purchasing new first aid kits, ensure you buy the CSA compliant kit with the description of Medium; not Small for a Type 2 or Type 3 kit. Reminder, you do not need to get rid of your OFA kits; but you do need to acquire any supplemental items to be compliant with the CSA kits.

If it is determined through a first aid assessment that a kit is required, employers must have one kit (at minimum), readily available to the designated first aid attendant. Employers are also able to provide additional kits or equipment to supplement basic requirements. As part of the process in conducting a first aid assessment and involving JHSC/worker consultation, determine what would be the most ideal location for portable first aid kits, e.g., possibly located near, or outside of hazardous areas.

Any additional first aid supplies are based on the specific workplace and work processes; not the workers themselves and any confidential underlying medical issues they may have. If a worker voluntary discloses a medical condition requiring specific medications, it is the decision of that worker to disclose, and provide, the medication they may require. They should also explain the administration instructions to the first aid attendant. Medical information disclosed to the First Aid attendant is voluntary, and it must remain private and confidential.

Employers that have a confined space must be compliant with Part 9 of the Occupational Health and Safety Regulation. Reference: WorkSafeBC Your first aid procedures should address how a worker injured in the confined space will be removed before first aid is initiated. Depending on the nature of the hazards in the confined space, you should consider likely injuries and methods available for safely removing the worker from the confined space. You should have a plan to remove the worker from the confined space that won’t further exacerbate likely injuries. This would also be a procedure to test with a drill.

No, generic first aid procedure templates will not be provided by WorkSafeBC. First aid procedures are very specific to your work location and work processes. Manufacturers and businesses need to create their own specific templates that includes several first aid procedures—at minimum those marked by an asterisk:

• Coordination of multiple attendants (e.g., major/minor injuries)
• Location of, and how to summon first aid (e.g., regular work, evacuations)
• * Responding to a first aid call (i.e., how to leave assigned duties)
• Authority of attendant over treatment of injuries (worker/public)
• Reporting injuries/illness to WorkSafeBC
• * Where injured not accessible how to treat and move for BCEHS
• * Transporting worker to medical services if not ambulatory (remote)
• * Maintaining the first aid program including equipment, supplies, facilities, services (i.e., coverage, scheduling, inspections, etc.)

Work with your health and safety association for assistance with creating procedures specific to your workplace. MSABC does not have First Aid procedure templates as these are created for each client by an MSABC Safety Advisor. The MSABC First Aid Program does address all the content noted above and is provided upon request. Connect with a MSABC Safety Advisor to find out what resources may be available for your use. Email [email protected] for details.

The contractor is responsible to ensure first aid is provided to their workers. If the plant only has one worker, the plant is unlikely to require a first aid attendant. Yes, as the owner and de facto prime of the workplace the plant employer has a responsibility to ensure appropriate first aid is provided, but the level of first aid required by the contractor might be different than the level provided by the plant, in which case it is on the contractor to ensure an appropriate assessment is conducted and first aid services provided.

Small workplaces that do not have a designated joint health and safety committee or designated safety representative can involve workers at safety meetings or during a toolbox talk. In the first aid assessment template there is a field to provide the name(s) of the worker(s) consulted.

Some workplaces may require multiple first aid attendants. The purpose of multiple attendants is to ensure adequate response to major incidents and to ensure adequate first aid coverage. When multiple designated attendants are present, the following should be considered and incorporated in the written procedures:

• In workplaces where first aid attendants have different levels of certification, procedures should state that the designated attendant with the higher certification should be the lead attendant for serious incidents and serious injuries. For minor injuries, any designated attendant may provide care and complete the required documentation. Lower level attendants should consult with the higher level attendant to ensure that the higher level attendant has no additional treatment options to offer the injured worker prior to discharge.
• For work locations with multiple attendants with the same level of certification, procedures should include instructions on how to determine which attendant will be the lead attendant for major events, serious incidents, or serious injuries (for example, person who has been attendant for longest, first on scene, etc).
• Where a workplace has multiple first aid attendants, procedures should identify how attendants are to respond (for example, attendants working and responding on different floors of a building). For major events, serious incidents, and serious injuries, all designated attendants should respond, or the employer should develop alternative procedures to ensure sufficient attendants respond to provide optimal first aid treatment to injured workers.