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How does British Columbia's Amendments to First Aid Regulations affect your Organization?

Writer's picture: Jennie Hogan, B.A.ScJennie Hogan, B.A.Sc

Updated: Dec 6, 2023


The requirement to provide First Aid services appropriate to the workplace is a basic responsibility of all employers. After 20 years with minimal changes, the requirements for First Aid outlined in BC’s Occupational Health and Safety Regulation have been amended to align with Canadian Safety Association standards Z1210-17 First Aid training for the workplace - Curriculum and quality management for training agencies and Z1220-17 First Aid kits for the workplace. These amendments will take effect November 1, 2024, granting employers time to obtain any required First Aid training, documentation, and equipment needed to ensure compliance.


In this article, we will explore the key changes made to British Columbia's First Aid Regulations and their impact on organizations. A highlight of changes include, but are not limited to:

  • The additional contemplation of a “less accessible workplace;”

  • Revision to the definition of “remote workplace," which determines the need for emergency transport;

  • How the definitions of “less accessible workplace” and “remote workplace” impact the resulting Schedule 3 tables outlining the First Aid minimum requirements;

  • Increases in the number and training level of First Aid attendants;

  • In addition to the Schedule 3 minimum First Aid requirements, the need for employers to also perform a written risk assessment for each workplace, in consultation with workers, to determine any additional equipment, supplies, facilities, attendants, and services necessary to ensure injured workers can be promptly provided First Aid and transported to medical treatment;

  • Additional points to contemplate when creating First Aid procedures to ensure injured workers can be promptly provided First Aid and transported to medical treatment; and,

  • Making the need to have First Aid procedure drills explicit.


Less Accessible Workplace

While First Aid requirements have previously contemplated number of workers located at a workplace; the hazard rating (low, moderate, or high), and ‘remoteness’ to emergency care, there is now a requirement to contemplate how accessible the workplace is. A “Less-accessible workplace” is defined as workplaces with a work area that cannot be safely accessed by ambulance personnel. A “less accessible workplace” includes two parameters to consider. In one, there may be a work area, such as a confined space, work at height or underground that cannot be safely accessed by ambulance personnel. In another situation, the workplace may be in a location that cannot be safely reached by an ambulance.


Remote Workplace

Whether a workplace was considered a “remote workplace” was determined based on surface travel time from a hospital, the amended definition describes workplaces where, under normal travel conditions, an ambulance (that is a motor vehicle) cannot drive to within 30 minutes from its base. The basis for determining whether an employer must provide emergency transportation is now based on travel time for an ambulance from its base to the workplace, not a hospital to the workplace. WorkSafeBC explains that its intent for this change is to allow more employers to rely on ambulances which provide safer means of transport for injured workers.


Minimum First Aid Requirements as per Schedule 3-A

With these definitions outlined, we can now look at Schedule 3-A, which sets out minimum First Aid requirements based on four classes of workplaces and are defined as follows:

  • “Class 1 workplace” is a workplace other than a class 2, 3, or 4 workplace, i.e. one that is neither less-accessible nor remote. In the case of a class 1 workplace, minimum First Aid requirements are set out in Table 3-1;

  • “Class 2 workplace” is a workplace that is remote but not less-accessible. In the case of a class 2 workplace, minimum First Aid requirements are set out in Table 3-2;

  • “Class 3 workplace” is a workplace that is less-accessible but not remote. In the case of a class 3 workplace, minimum First Aid requirements are set out in Table 3-3; and,

  • “Class 4 workplace” is a workplace that is both remote and less-accessible. In the case of a class 4 workplace, minimum First Aid requirements are set out in Table 3-4.

In comparison to WorkSafeBC’s current requirements, after November 1st, 2024, additional First Aid attendants are required for moderate and high-hazard rating workplaces and for all larger workplaces. WorkSafeBC explains that its' intent of these amendments is to allow for trained assistance to be available and to account for situations where the injured worker is the First Aid attendant. Also, higher levels of certification is required under some categories providing a broader scope of training so that attendants are better able to deal with a wider range of injuries.


Written Assessment

In addition to the minimum requirements set out in these tables, WorkSafeBC will require employers to complete a written assessment, in consultation with workers, that considers potential situations where the minimum requirements would not ensure that workers who suffer an injury at work can be promptly provided First Aid and promptly transported to medical treatment. WorkSafeBC’s intent of these additions is for an employer to consider whether workers may be in locations (e.g. confined space, at height, underground etc.) where an attendant would not be able to promptly provide First Aid and to consider available methods of transportation to medical treatment. The assessment should consider whether the location changes the hazards and risks faced by workers and thus the corresponding First Aid services needed. The assessment must be prepared, reviewed and updated in consultation with the joint committee or the worker health and safety representative, as applicable to your organization.


First Aid Procedures

While having up-to-date, written First Aid procedures is not new, as of November 1, 2024 procedures, similar to the assessment, need to contemplate:

  • if there any barriers to First Aid being provided to injured workers, how an injured worker will be accessed and moved; and,

  • if emergency transportation is required, the location of the method of emergency transportation.


WorkSafeBC explains that its' intent of the additions is for an employer to consider:

  • any barriers to First Aid being provided and to have appropriate procedures for how a First Aid attendant can access an injured worker;

  • procedures for how an injured worker can safely be moved in order to be transported to medical treatment if there is a work area that cannot be accessed by ambulance personnel; and,

  • if an employer is required to provide emergency transportation, the location of the emergency transportation, such as where an emergency transportation vehicle is parked or where a helicopter may land.


Drills

Although many organizations included First Aid drills in their required emergency drills, the First Aid requirements have been updated to make the need for drills explicit. Drills are conducted to ensure that the First Aid procedures are effective and workers, First Aid attendants, and other persons authorized to call for transportation are capable of fulfilling their roles and responsibilities. Drills are required at least once each year and whenever the procedures change.


If you require assistance on creating or updating your First Aid Assessment and/or Procedures as well as supporting documentation, please contact:

Jennie at Hogan Safety Consulting

Phone/text: 250.641.9575

Website at hogansafety.ca



The information provided in this article is intended for informational and educational purposes only. It is not to be considered as legal or consulting advice.
The content of this article is based on general knowledge and research available up to October 2023, and it may not reflect the most current legal or regulatory developments. Laws and regulations can change, and their interpretation can vary based on specific circumstances.
If you require legal or consulting advice regarding British Columbia's First Aid Regulations or any related matters, it is crucial to consult with a qualified legal professional, regulatory authority, or industry expert. They can provide guidance tailored to your specific situation and ensure that you are in compliance with all relevant laws and regulations.
Reliance on the information provided in this article should not replace seeking professional advice when dealing with legal, regulatory, or consulting matters. The author and publisher of this article disclaim any liability for actions taken or not taken based on the information provided herein.

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