Last reviewed 15 April 2021
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, employers with employees in the workplace will need to consider three key issues as follows.
How to arrange first-aid cover if they have reduced staffing levels in buildings.
The expiry of first-aid certificates.
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). You should also identify if any of your first-aiders would be classified as vulnerable employees.
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.
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.
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. Make sure they have the knowledge and availability to cover your business activities. You may also need to consider temporarily stopping higher-risk activities.
During the first Covid-19 lockdown period, first-aid training was put on hold. As such, the HSE gave extensions to those with expired certification in First Aid at Work (FAW) and Emergency First Aid at Work (EFAW), as well as the Offshore certificates. However, the temporary arrangements have come to an end.
Offshore Medic and Offshore First Aid Certificates must be current and in date.
FAW or EFAW certificates that expired on or after 16 March 2020 were valid until 31 October 2020 or six months from date of expiry, if later. All requalification training had to be completed by 31 March 2021.
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. Online training can be used for refresher courses.
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 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.