This is not a drill: New first aid requirements under BC’s Occupational Health and Safety Regulation

Employers in British Columbia are legally obligated to provide their workers with “prompt, easily accessible and appropriate” first aid treatment. New amendments to Part 3 of the Occupational Health and Safety Regulation (“OHSR”), which come into effect on November 1, 2024, redefine and expand the actions that employers must take in order to meet this obligation (the “Amendments”).

Amendments to the OHSR

1. First Aid Training Standards

First aid requirements in BC have remained largely unchanged for the past two decades despite improvements in first aid training and the development of first aid standards by the Canadian Standards Association (“CSA”).

The Amendments require that BC first aid certifications align with the CSA Workplace First Aid Certification Standard Z1210-17 (“Standard”). This means that Occupational First Aid Levels 1, 2 and 3 will become Basic, Intermediate and Advanced, respectively. There will be a transition period to allow employers time to implement these changes. Valid Level 1, 2 and 3 certificates will be considered valid for the purposes of the Amendments until they expire, up to November 1, 2027.

2. First Aid Kits

The Amendments require employers to update their first aid kits to comply with the Standard, which sets out the type and amount of equipment that each first aid kit must contain. The OHS Guidelines include detailed lists of first aid supplies for each kit.

3. First Aid Assessments

The Amendments impose a duty on employers to conduct and document a two-part assessment to determine the amount of first aid resources, including equipment and services, required for each workplace. The two-part assessment first requires employers to provide the minimum required amount of supplies, facilities and first aid attendants, as set out in Schedule 3-A of the OHSR. The minimum requirements vary according to the class assigned to the workplace. Class is determined based on the number of workers and whether the workplace is considered “remote,” meaning it is located more than 30 minutes away from a BC Emergency Health Services ambulance station, or “less accessible,” meaning that emergency personnel cannot safely access the workplace. Secondly, the employer must provide any additional first aid equipment, supplies, facilities, first aid attendants and services that are necessary to ensure that any worker who suffers an injury on the job will promptly receive first aid and transportation to a medical treatment facility.

Employers must also prepare a written assessment (“Assessment”) detailing the number and locations of workers, the types of injuries that are most likely to occur, barriers faced by workers needing first aid treatment, and methods and availability of emergency transportation. The Assessment must be prepared in consultation with a committee or workers or a representative and must be reviewed on an annual basis.

4. Emergency Transportation

Under the Amendments, employers with remote workplaces will be required to provide emergency transportation that is capable of:

1. Safely transporting a first aid attendant and an injured worker secured to a stretcher;
2. Facilitating effective communication between the first aid attendant and the operator of the emergency transportation vehicle; and
3. Securing injured workers to minimize excessive jarring, protecting the injured worker from natural elements and dust, maintaining the injured worker’s normal body temperature and providing adequate space for the first aid attendant to safely administer first aid to the injured worker.

When air transportation is the primary or only method of emergency transport, employers must ensure that an appropriate aircraft, equipped with compatible stretchers, is available whenever work is being completed.

5. First Aid Drills

The Amendments mandate that employers must conduct first aid drills every year or whenever first aid procedures change. These drills are intended to ensure that first aid procedures are effective and that first aid attendants are capable of carrying out their duties.

Key Takeaways

As of November 1, 2024, employers must align their first aid programs with the standards required by the Amendments. Employers will need to consult with their joint health and safety committee or worker health and safety representative and conduct first aid assessments to determine what changes are necessary to bring existing first aid practices into compliance with the Amendments.

If you have questions about the amendments to first aid requirements or any other labour and employment issue, please reach out to a member of Miller Thomson’s Labour and Employment Group.