First Aid at Work: UK Employer Requirements

Every year, thousands of workplace injuries and medical emergencies require immediate first aid response. The quality and speed of that response can mean the difference between a full recovery and a life-changing outcome — or between life and death. In the UK, the law places a clear duty on employers to ensure that adequate first aid provision is in place, and failure to meet this duty can result in enforcement action, civil liability and, in the most serious cases, prosecution.

Yet first aid at work remains one of the most commonly misunderstood areas of health and safety compliance. Many employers are unsure how many first aiders they need, what training is required, what equipment to provide, or how to assess their specific needs. This guide covers the full legal framework, the needs assessment process, training requirements, equipment standards and the record-keeping obligations that underpin it all.

The Legal Framework

Health and Safety (First-Aid) Regulations 1981

The Health and Safety (First-Aid) Regulations 1981 are the primary legislation governing first aid at work in England, Scotland and Wales. They are supported by the Approved Code of Practice and Guidance (L74), which was last revised in 2013.

The regulations are straightforward in their core requirement:

“An employer shall provide, or ensure that there are provided, such equipment, facilities and personnel 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.”

This single regulation (Regulation 3) encompasses everything: equipment, facilities and people. What is “adequate and appropriate” depends on the specific circumstances of each workplace — which is why a needs assessment is essential.

What the Regulations Do Not Cover

It is important to note what the First-Aid Regulations do not require:

• Employers are not legally required to provide first aid for non-employees (visitors, customers, members of the public). However, the HSE strongly recommends including them in your first aid provision, and other legislation — particularly the Health and Safety at Work etc. Act 1974 (Section 3) and the Occupiers’ Liability Acts — may impose a duty of care towards non-employees on your premises
• The regulations do not specify a fixed ratio of first aiders to employees. The requirement is based on a needs assessment, not a formula
• The regulations do not require employers to provide specific medical treatments or drugs. First aiders are trained to preserve life, prevent conditions worsening, and promote recovery — not to diagnose or treat medical conditions

The Approved Code of Practice (L74)

The Approved Code of Practice (ACOP) has a special legal status. While it is not law itself, if an employer is prosecuted for a breach of the First-Aid Regulations and has not followed the ACOP, a court will find the employer at fault unless they can demonstrate that they complied in some other equally effective way.

The ACOP provides practical guidance on:

• How to carry out a first aid needs assessment
• The number and type of first aid personnel
• First aid equipment and facilities
• Information for employees

The First Aid Needs Assessment

The cornerstone of first aid compliance is the needs assessment. This is not optional — it is how you determine what first aid provision is adequate and appropriate for your workplace.

Factors to Consider

The HSE identifies the following factors that should be considered in a first aid needs assessment:

1. The Nature of the Work

What hazards are present? A low-risk office environment has very different first aid needs from a construction site, a chemical plant, or a commercial kitchen. Consider:

• Are there hazards that could cause serious injury (machinery, working at height, electricity, vehicles)?
• Are hazardous substances used or stored on site?
• Is there a risk of burns, scalds or exposure to chemicals?
• Are there processes that could cause sudden illness (exposure to fumes, extreme temperatures)?

2. Workplace Hazards and Risks

Review your risk assessments to identify the types of injuries and illnesses that are foreseeable. This directly influences the type of first aid training and equipment you need.

3. The Size of the Organisation

Larger workforces generally require more first aiders, but size alone is not determinative. A workforce of 200 in an office building has different needs from a workforce of 200 on a construction site.

4. The History of Accidents and Ill Health

What injuries and illnesses have actually occurred? Your accident records and RIDDOR reports provide valuable evidence. If certain types of injury recur, your first aid provision should be able to respond to them.

5. The Needs of Travelling, Remote and Lone Workers

Workers who travel, work remotely, or work alone present particular challenges. They may be far from the nearest first aider or first aid equipment. Consider:

• Personal first aid kits for travelling workers
• First aid training for lone workers and their immediate colleagues
• Communication arrangements so that emergency services can be summoned quickly

See our lone worker safety guide for more detail on managing the risks to isolated workers.

6. Work Patterns

Do you operate shifts? Weekends? Nights? You must ensure adequate first aid cover at all times when employees are at work, not just during standard business hours. If your qualified first aider works 9-5 but you have a night shift, that night shift needs its own cover.

7. Annual Leave and Other Absences

What happens when your first aiders are on holiday, off sick, or away on training? You need enough trained first aiders to maintain cover even when some are absent. A single first aider for an entire site is not adequate if there is no cover when they are away.

8. Multi-Occupied Sites

If you share a building or site with other employers, you may be able to arrange shared first aid provision — but this must be formally agreed and documented. You cannot simply assume that another employer’s first aider will look after your employees.

9. Proximity to Emergency Medical Services

How long would it take for an ambulance to reach your site? Rural locations, sites with restricted access, or high-rise buildings where access is slow may need enhanced first aid provision to bridge the gap until paramedics arrive.

Documenting the Assessment

Record your first aid needs assessment and review it regularly — at least annually, or sooner if there is a significant change (new activities, new building, change in workforce size, an incident that reveals a gap in provision). A written record demonstrates compliance and helps you identify when your provision needs updating.

Types of First Aid Personnel

The regulations and ACOP recognise three main categories of first aid personnel, each with different levels of training and responsibility.

First Aider at Work (FAW)

A First Aider at Work holds a current First Aid at Work (FAW) certificate. This is the highest level of workplace first aid qualification and covers a wide range of injuries and illnesses.

FAW training covers:

• Assessment of the situation and the casualty
• Cardiopulmonary resuscitation (CPR) and use of an automated external defibrillator (AED)
• Treating an unconscious breathing casualty (recovery position)
• Choking in adults, children and infants
• Wounds and bleeding — controlling severe bleeding, treating minor wounds
• Shock
• Burns and scalds
• Fractures, sprains, strains and dislocations
• Spinal injuries
• Chest injuries
• Eye injuries
• Poisoning
• Anaphylaxis
• Asthma attacks
• Heart attacks
• Stroke
• Epileptic seizures
• Diabetic emergencies
• Hypothermia and heat exhaustion

The FAW course is typically 3 days (18 hours) for an initial qualification.

Emergency First Aider at Work (EFAW)

An Emergency First Aider at Work holds a current Emergency First Aid at Work (EFAW) certificate. This covers a more limited range of competencies, focusing on life-threatening conditions.

EFAW training covers:

• Assessment of the situation and the casualty
• CPR and AED use
• Treating an unconscious breathing casualty
• Choking
• Wounds and bleeding
• Shock
• Minor injuries

The EFAW course is typically 1 day (6 hours).

Appointed Person

An Appointed Person is not a trained first aider but is nominated to:

• Take charge of the first aid arrangements (maintaining equipment, calling emergency services)
• Look after first aid equipment
• Call an ambulance or other emergency services when required

An appointed person is the minimum provision for low-risk workplaces with small numbers of employees where a trained first aider is not required by the needs assessment.

How Many Do You Need?

The ACOP provides indicative guidance, but the actual number must be determined by your needs assessment:

Risk Category	Number of Employees	Suggested Minimum
Lower risk (offices, shops, libraries)	Fewer than 25	At least one appointed person
Lower risk	25-50	At least one EFAW
Lower risk	More than 50	At least one FAW per 100 employees
Higher risk (construction, manufacturing, chemicals)	Fewer than 5	At least one appointed person
Higher risk	5-50	At least one FAW
Higher risk	More than 50	One FAW per 50 employees

These are starting points, not definitive ratios. Your needs assessment may indicate more or fewer first aiders depending on the factors discussed above.

Training Requirements

Who Can Deliver Training?

First aid at work training must be delivered by an organisation whose training and qualifications are approved by the HSE. Since October 2013, the HSE no longer directly approves individual training providers. Instead, training and qualifications must be approved by a body that the HSE has recognised for this purpose. Currently, the HSE has recognised several Awarding Organisations, including:

• Highfield Qualifications
• Qualsafe Awards
• FAA Awards
• TQUK
• SQA (in Scotland)

Employers should check that their chosen training provider is delivering a course that leads to a qualification approved by one of these recognised bodies.

Requalification Cycle

First aid certificates are valid for 3 years. First aiders must complete a requalification course before their certificate expires to maintain their qualification. If the certificate lapses, the first aider must complete a full initial course again.

The HSE strongly recommends that first aiders undertake annual refresher training between their three-year requalification courses. While not a legal requirement, annual refreshers help maintain skills and confidence — particularly in CPR, where skill deterioration is well-documented.

Tracking Training and Certification

Managing first aid training across an organisation — tracking who is qualified, when their certificates expire, scheduling requalification courses, and ensuring adequate cover — can be complex, especially for multi-site employers. A training management system automates this process, alerting you to upcoming expiry dates and ensuring you never find yourself without adequate first aid cover because a certificate has lapsed.

First Aid Equipment

First Aid Kits — BS 8599-1

The contents of workplace first aid kits should conform to BS 8599-1:2019, the British Standard for workplace first aid kits. This replaced the previous HSE recommended contents list and provides a more comprehensive, risk-appropriate standard.

BS 8599-1 specifies three sizes of kit:

Small Workplace Kit (1-25 employees, lower risk)

• 1 x guidance leaflet
• 4 x individually wrapped sterile adhesive dressings
• 1 x triangular bandage
• 2 x safety pins
• 1 x large sterile unmedicated wound dressing (18cm x 18cm)
• 6 x individually wrapped moist cleansing wipes
• 2 x pairs of disposable gloves
• 1 x finger dressing (3.5cm x 3.5cm)
• 1 x conforming bandage (7.5cm x 4.5m)
• 1 x resuscitation face shield
• 1 x foil blanket
• 1 x burn dressing (10cm x 10cm)
• 2 x clothing cutters/shears
• 1 x microporous tape (2.5cm x 5m)

Medium Workplace Kit (25-100 employees, lower risk)

Increased quantities of the above items, plus additional dressings and bandages proportionate to the larger workforce.

Large Workplace Kit (100+ employees, lower risk)

Further increased quantities. Higher-risk workplaces may need additional kits or supplementary items specific to the hazards present (e.g. eye wash stations where there is a risk of chemical splashes, burn gel sachets where there is a risk of thermal burns).

Additional Equipment

Depending on your needs assessment, you may also need:

• Automated External Defibrillator (AED) — not a legal requirement under the First-Aid Regulations, but strongly recommended. The Resuscitation Council UK recommends AEDs in all workplaces where it is likely to be used (i.e. most workplaces). An AED can be used by anyone — you do not need to be a trained first aider
• Eye wash stations — where there is a risk of chemical or dust exposure to the eyes
• Burns kits — where there is a risk of thermal or chemical burns
• First aid room — required in large workplaces or where the needs assessment identifies a need. Must be easily accessible, clearly identified with signage, and equipped with a couch, a chair, a sink with hot and cold water, drinking water, soap, paper towels, smooth-topped work surfaces, a telephone, and a first aid kit

Inspection and Replenishment

First aid kits must be regularly checked to ensure they are complete, in date, and in good condition. Use digital checklists to schedule and record inspections. A common failing identified by the HSE is first aid kits that are incomplete, contain expired items, or have been used and not replenished.

Record-Keeping

What Records to Keep

While the First-Aid Regulations do not explicitly mandate specific record-keeping (beyond the general requirements of the Management Regulations), good practice — and the ACOP — requires you to maintain:

• First aid needs assessment — documented, dated, reviewed regularly
• First aider details — names, qualifications, certificate numbers, expiry dates
• Training records — course dates, training providers, qualification details
• First aid treatment records — a record of all first aid treatment administered at work. This serves two purposes: it helps identify trends that may indicate a need to review risk assessments, and it provides evidence of the care provided if any legal claim arises
• Equipment records — inspection dates, replenishment records, replacement dates

Data Protection Considerations

First aid records contain personal health data and must be handled in accordance with the UK GDPR and Data Protection Act 2018. Records should be stored securely, access should be restricted to those who need it, and retention periods should be appropriate (typically the same as accident records — at least 3 years, or longer where long-latency conditions are possible).

Self-Employed Duties

Self-employed workers must provide adequate first aid equipment if they work in a workplace where the First-Aid Regulations apply. In practice, this usually means carrying a personal first aid kit appropriate to the work being undertaken.

Self-employed workers on construction sites or other shared workplaces should be covered by the site operator’s first aid arrangements, but it is good practice to carry basic first aid equipment as a supplement.

Common Compliance Failures

HSE inspectors and auditors commonly identify these first aid failings:

1. No needs assessment — relying on a generic formula instead of conducting a workplace-specific assessment
2. Insufficient first aiders — particularly on shifts, at weekends, or when first aiders are absent on leave
3. Expired certificates — first aiders whose qualifications have lapsed without requalification
4. Incomplete first aid kits — items used and not replaced, expired items, kits in poor condition
5. No information — employees not informed of who the first aiders are, where first aid kits are located, or what to do in an emergency
6. No cover for absences — a single first aider with no backup when they are on holiday or off sick

You can review our workplace inspection checklist for a broader framework that includes first aid provision as part of your regular workplace audits.

Ensuring Your First Aid Provision Is Adequate

First aid at work is not a tick-box exercise — it is a genuine, practical safety measure that can save lives. The regulations deliberately avoid prescribing rigid ratios and kit contents, because every workplace is different. The needs assessment is the mechanism that ensures your provision matches your actual risks.

Get the assessment right, train enough people to the right level, maintain your equipment, keep your records up to date, and review regularly. Use a training management system to track first aider qualifications and certification expiry dates, and digital checklists to schedule regular inspections of your first aid equipment and facilities.

When an emergency happens, the quality of your preparation determines the outcome. Make sure your organisation is ready.