Last reviewed 17 June 2020

Mike Sopp advises on the key issues for employers when managing workplace first-aid provision in the current crisis.

Under the Health and Safety (First Aid) Regulations 1981, employers must make appropriate first-aid arrangements for workplaces.

In doing so, employers should consider the circumstances of each particular workplace, workforce and the health and safety risks that may be present. This will inform decisions on what arrangements need to be put in place.

Employers have a duty of care to employees to provide first aid, which may be extended to others such as members of the public present on the premises. Potential liabilities (civil and criminal) could arise if:

  • an injured party comes to increased harm due to insufficient first-aid cover

  • an injured party comes to increased harm due to first-aid trained staff refusing to provide treatment due to fear of coronavirus transmission

  • a staff first aider contracts Covid-19 while undertaking first-aid duties.

In the current coronavirus crisis and the gradual return to work, employers will need to consider three key issues as follows.

  1. How to arrange first-aid cover with reduced staffing levels in buildings.

  2. First-aid certification expiration due to training cessation.

  3. The potential exposure of first-aid trained staff to Covid-19.

Covid-19 Secure risk assessments

Employers are required to review work-related risk assessments as part of the UK Government’s approach to safe working during the pandemic.

Health and Safety Executive (HSE) guidance states that when reviewing risk assessments, consideration should be given to refreshing first aid at work needs assessments.

The HSE further states that employers should discuss the risk assessment with first aiders so they are confident about providing the right assistance. This includes knowing what equipment they can use to minimise risk of infection transmission (see below).

It is therefore recommended that those responsible for first-aid provision review their arrangements in accordance with current best practice issued by the Health and Safety Executive.

First-aid cover

The HSE recognises that, during the pandemic, first-aid cover might be affected due to the absence of trained personnel from the workplace. A reduction in the number of workers on the premises will also reduce the need for first-aid cover.

Cover should reflect ongoing hazards and employee numbers present. The following chart will assist in determining what level and how many first-aid personnel are required.

Hazard level

Number of employees and/or pupils

Level of first-aid provision required

Low hazard (eg offices, shops, banks)

Less than 25

At least one appointed person


At least one person trained in Emergency First Aid at Work (EFAW)

More than 50

At least one person trained in First Aid at Work (FAW) for every 100 persons (or part thereof)

Higher hazard (eg with dangerous machinery, sharp instruments, chemicals used)

Less than 5

At least one appointed person


At least one person trained in EFAW or FAW (depending on risk assessment)

More than 50

At least one person trained in FAW for every 50 persons (or part thereof)

Where there are difficulties in meeting the above ratios, organisations should consider sharing cover with other organisations in shared occupancy environments, for example.

First-aid qualifications

During the Covid-19 lockdown period, first-aid training has been put on hold.

The HSE acknowledged this and has given extensions to those with expired certification in First Aid at Work (FAW) and Emergency First Aid at Work (EFAW).

Those holding a certificate that expires on or after 16 March 2020 who cannot access requalification training because of the coronavirus, may qualify for an extension. To qualify for the extension, the certificate holder must be able to:

  • explain why they haven’t been able to requalify

  • demonstrate what steps have been taken to access training, if asked to do so.

The HSE still strongly recommends that the practical elements of actual FAW, EFAW and requalification courses are delivered face to face, so that competency of the student can be properly assessed.

The first-aid training industry in England is confident that enough courses will now be available for all required requalification training to take place.

The HSE has therefore agreed a final deadline for requalification for these qualifications of 30 September 2020. This is likely to generate logistical issues for organisations as the majority of training is provided by an external third party either at the employer’s premises or in dedicated training facilities.

As such, employers will need to:

  • identify how many official first-aid certificate holders have a certificate that has expired or is likely to expire before 30 September 2020

  • liaise with third-party providers to determine feasibility of and plan future courses before the above date to enable revalidation.

First-aid treatment

The purpose of first aid is to preserve life and prevent the worsening of any condition. Employers should be aware that there will be concerns among those nominated to provide first aid in relation to exposure to the coronavirus.

In the current Covid-19 pandemic, the HSE guidance advises first aiders to “try to assist at a safe distance from the casualty as much as you can and minimise the time you share a breathing zone” and that if they are capable, to tell the injured or ill party to “do things for you”.

However, the HSE also states that “treating the casualty properly should be your first concern”.

Clearly, the risk of Covid-19 cross-contamination occurring is where close contact is necessary to preserve life and prevent worsening of a condition — in particular where a first-aid trained staff member is required to undertake cardiopulmonary resuscitation (CPR).

In respect of the use of personal protective equipment (PPE), the HSE guidance is as follows.

  • Before starting CPR, to minimise transmission risk, use a cloth or towel to cover the patient’s mouth and nose, while still permitting breathing to restart following successful resuscitation.

  • If available, use a fluid-repellent surgical mask, disposable gloves, eye protection, apron or other suitable covering.

  • Only deliver CPR by chest compressions and use a defibrillator (if available) — don’t do rescue breaths.

This reflects guidance from the Resuscitation Council UK.

Government guidance for “first responders” states that “the use of a fluid repellent surgical face mask is recommended and additional use of disposable eye protection (such as face visor or goggles) should be risk assessed when there is an anticipated risk of contamination with splashes, droplets of blood or body fluids”.

Employers should be ensuring that:

  • changes in the approach to any first-aid treatment approach, such as maintaining social distancing where possible, is made known to all first-aid trained employees

  • first aiders are provided with the appropriate PPE where necessary

  • all first-aid equipment provided (including defibrillators) are adequate, in working order and that single items’ “use by” dates are still valid.