CHAPTER 6 - FIRST AID EQUIPMENT, MEDICATIONS AND
RELATED MEDICAL ISSUES
First Aid Kits and Other First Aid Materials
1.
FAW is very specific
in describing the duties of employers:
“An employer shall provide, or ensure that
there are provided, such equipment and facilities as are adequate and appropriate
in the circumstances for enabling first aid to be rendered to his employees
if they are injured or become ill at work”.
2.
The FAW Approved
Code of Practice (ACoP) requires that the first aid equipment “shall include
at least one first aid container supplied with a sufficient quantity of first
aid materials suitable for the particular circumstances”, and the associated
guidance goes on to suggest a suitable minimum list of contents for the first
aid box. The minimum content is mostly directed towards the treatment of minor
cuts, the control of bleeding from major wounds and the protection of eye
injuries.
3.
Unfortunately, the
guidance appears to cause confusion in two ways. On the one hand the suggested
contents list is often interpreted as a legal requirement. This has given
rise to the erroneous concept of an "HSE approved" first aid kit,
and many suppliers of first aid equipment sell kits with this description.
However, this may result in employers purchasing items which are not appropriate,
either in type or in numbers, to their particular circumstances. This interpretation
has sometimes been carried to the level of interpreting the suggested dimensions
of dressings in the HSE guidance as an absolute legal requirement, thus discriminating
against the use of similar products, which might be entirely fit for purpose.
4.
On the other hand
the guidance may be interpreted to mean that no items except
those in the minimum list may be kept in a first aid box. As a result employers
are often reluctant to supply commonly used and quite appropriate first aid
materials, even if their first-aiders consider that they would be useful in
the employer's particular circumstances.
Options
5.
HSE would like to
ensure that its advice is clear and unambiguous but would not wish this to
result in an unnecessary extra burden on employers or first-aiders. The following
are a number of options for consideration.
Option 1 Retain the present system, where the Regulation
is non-prescriptive and the ACoP focuses guidance and advice on helping the
employer decide on suitable contents for their own workplace circumstances.
Option 2 Retain the current Regulation and ACoP, but
replace the suggested contents list in the current guidance with expanded
guidance, this to include case studies and examples to assist employers to
provide the most appropriate contents for their first aid box.
Option 3 Amend the ACoP to specify
a mandatory basic contents list for first aid boxes. This would not necessarily
be appropriate to all employers’ workplace requirements so there would still
be a need for employers to conduct an assessment of whether additional materials
were required.
Questions
Q14. Which option do you think will help employers identify
the most appropriate contents for a first aid kit in their particular workplace?
Q15. What advice do employers and others expect from
HSE?
6.
Whatever approach
is adopted, and for very practical reasons, it might be appropriate to introduce
a recommendation that employers consult with their first-aiders to review
the provision of equipment from time to time. (The first-aiders know what
they actually use or do not use, and what additional materials they might
find helpful.)
7.
Many employers have
suggested to HSE that first-aiders should be able to dispense common over-the-counter
(OTC) medicines to employees with minor illnesses, for example paracetamol
to people with headaches.
8.
The use of medicines
is normally considered to be outside the scope of first aid. Current HSE
guidance reflects this position and recommends that medicines should not be
kept in the first aid box. Strictly speaking, there is no legal bar to employers
making medicines available to employees and many do so. This may be achieved
either by direct sale to employees (e.g. from vending machines) or by placing
the medicines in the care of a responsible person, who is often a first-aider.
Keeping them in the first aid box is simpler, but using another container
emphasises that they are not really within the scope of first aid treatment.
HSE does have concerns about placing this responsibility onto first-aiders
because it implies that they have medical diagnostic skills, which are not
normally covered within first aid courses.
9.
There is also a
potential for litigation against employers/first-aiders if first-aiders are
asked to administer medications (even if trained).
10.
While it is true
that first-aiders may be more knowledgeable about the treatment of
minor illness than most other employees, first aid training does not extend
to the administration of medicines.
Questions
Q16. Are there any circumstances in which first-aiders
should be responsible for the distribution of over the counter medicines to
employees?
Q17. If medicines were made available for supply by
first-aiders, should they be kept in the first aid box, in a separate container
or somewhere else?
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