First Aid Policy: Legal Requirements For Australian Workplaces

Keeping your team safe is good business-and in Australia, it’s also a legal obligation. Every person conducting a business or undertaking (PCBU) must make sure workers have access to first aid. That includes the right equipment, facilities and trained people to respond if someone is injured or becomes ill at work.

One common point of confusion? Whether a written “First Aid Policy” is legally required. The law doesn’t always mandate a standalone policy document, but you do need effective first aid arrangements that suit your risks. A clear, written policy is strongly recommended to prove compliance, guide your team and make sure nothing falls through the cracks.

In this guide, we break down what the law actually requires, how many first aiders you need, what to put in your kits and procedures, and how to keep everything current-so you can protect your people and your business with confidence.

What Is A Workplace First Aid Policy?

A workplace First Aid Policy is a practical document that explains how your business prevents harm and responds when incidents happen. It typically covers how you assess first aid risks, what equipment and facilities you’ll provide, who your first aiders are, the training they receive and the steps everyone should follow in an emergency.

Think of it as your roadmap for fast, effective action. It helps you brief new starters, coordinate across sites and shifts, and demonstrate that you’ve taken reasonable steps to keep people safe.

Strictly speaking, most WHS laws do not prescribe that you must have a written policy by that name. However, regulators expect you to have clear first aid arrangements that reflect your risks, and documenting those arrangements is best practice (and often essential) to meet your duty of care as an employer.

What Does The Law Actually Require In Australia?

Australia doesn’t have a single “First Aid Act”. Instead, first aid duties sit within work health and safety (WHS) laws that vary by state and territory.

• Most jurisdictions have adopted the Model WHS Act and Regulations. These require PCBUs to ensure the health and safety of workers, including providing adequate first aid equipment, facilities and trained first aiders.
• Victoria has its own regime under the Occupational Health and Safety Act 2004 (Vic) and regulations, which impose similar duties to provide adequate first aid.
• Safe Work Australia’s “First Aid in the Workplace” Code of Practice provides practical guidance on how to meet these duties. State regulators (like SafeWork NSW, WorkSafe Victoria and WorkSafe Queensland) also publish local guidance.

The takeaway: you must ensure suitable first aid arrangements for your specific risks. A generic kit or a single trained person won’t be enough if it doesn’t match your workplace.

Key legal expectations across Australia typically include:

• First aid equipment: accessible, properly stocked kits that suit your hazards and locations.
• Facilities: suitable areas to treat injuries, which may include a first aid room in larger or higher-risk workplaces.
• Trained first aiders: workers who can provide immediate first aid, in sufficient numbers for your risk profile and headcount.
• Information for workers: clear signage, inductions and details on who the first aiders are and where to find kits and facilities.

Importantly, you’ll be judged on what is “reasonably practicable” for your business-so your size, risk level, work patterns and location all matter.

How Many First Aiders, Kits And Facilities Do You Need?

There’s no one-size-fits-all rule. The numbers depend on your risks, headcount, layout and work patterns (including shifts and remote or isolated work). As a starting point, the national Code of Practice suggests these indicative ratios:

• Low-risk workplaces (for example, offices or retail): at least one first aider for every 50 workers.
• High-risk workplaces (for example, manufacturing, construction, warehousing): at least one first aider for every 25 workers.

If you run multiple sites or shifts, you’ll need enough coverage at each site and on every shift. For remote or isolated workers, consider personal first aid kits, communications tools (e.g. satellite phones) and response plans tailored to delayed emergency access.

First Aid Kits: What To Include And Where To Put Them

Your kits should reflect your hazards. Most workplaces will stock items like bandages, antiseptics, gauze, adhesive dressings, saline eyewash, burn treatments, instant cold packs, scissors, and disposable gloves.

Higher-risk settings often need extras-think hydrofluoric acid antidotes for certain manufacturing environments, or specialized burn dressings in commercial kitchens. If you use hazardous chemicals, check the safety data sheets (SDS) for specific first aid requirements.

Place kits where they’re quick to reach, such as near high-risk areas, in vehicles for mobile teams, and on each floor of larger buildings. Assign someone to check kits regularly, track expiry dates and restock after incidents.

First Aid Rooms And Other Facilities

Many regulators recommend a first aid room for larger or higher-risk workplaces (for example, typically where worker numbers are high-often referenced around 200+ in low-risk or 100+ in high-risk workplaces). Even if a dedicated room isn’t required, you may still need a private, clean space with a couch or bed, hot and cold water, and easy access for paramedics.

As always, base your decision on a risk assessment: a small, low-risk office won’t need the same facilities as a heavy manufacturing plant.

Appointing And Training First Aiders (Including Who Pays)

You’ll need to nominate a sufficient number of first aiders, ensure they complete accredited training, and keep their skills current. In practice, that means:

• Choosing first aiders who are willing and able to respond quickly in an emergency.
• Funding accredited first aid training (for example, HLTAID011 Provide First Aid) and annual CPR refreshers.
• Keeping training up to date-first aid certificates generally renew every three years, while CPR is refreshed every 12 months.
• Maintaining a register of current first aiders and copies of certificates.
• Making first aider names, locations and contact details visible to staff (posters near kits, intranet pages, onboarding materials).

Under WHS laws, the business is responsible for providing what’s necessary to meet its duties-so you should cover the cost of first aid training, not the employee. If acting as a first aider is part of someone’s role or there’s an allowance, you can note that in their Employment Contract so expectations are clear.

A written policy also helps managers plan coverage across shifts and sites, and makes it easier to onboard new first aiders as your headcount changes.

Procedures, Record-Keeping And Privacy

Your first aid arrangements aren’t complete without clear procedures and proper records. These should be simple to follow under pressure and consistent with your broader WHS processes.

Incident And Emergency Procedures

Set out step-by-step guidance for workers and first aiders. At a minimum, cover:

• How to call for help (internal contacts and how/when to call 000).
• Immediate response steps for common injuries (e.g. burns, cuts, chemical exposure), including any site-specific hazards.
• Evacuation and handover to paramedics when required.
• How to secure the area and preserve the scene if a notifiable incident has occurred.

Display this information in visible locations and include it in inductions. If you have lone or remote workers, make sure procedures reflect delayed emergency response times and communications limits.

Recording First Aid Incidents

Keep a simple register of first aid treatments and workplace injuries. Accurate records help you spot trends, review risks and demonstrate compliance if a regulator asks questions.

If an incident meets the “notifiable incident” threshold in your state or territory (for example, serious injury, illness or a dangerous incident), you must notify the regulator promptly and preserve the site as required by law.

Health Information And Privacy

First aid and incident records can include health information, which is sensitive personal information under the Privacy Act. If you collect or store any personal information about workers or visitors, make sure you have an up-to-date Privacy Policy and a clear Privacy Collection Notice explaining what you collect and why.

Be mindful of how you share first aid details internally-only those who need to know should have access. If you require a worker to share medical information (for example, a clearance to return to work after an incident), a tailored Medical Release Consent Form can help you obtain informed consent appropriately.

It’s also wise to align your retention practices with your broader data retention obligations, so records are kept for the right period and then securely destroyed.

Do You Need A Written Policy And How Often Should You Review It?

While a standalone “First Aid Policy” is not explicitly required by law in every jurisdiction, documenting your arrangements is one of the simplest ways to ensure they’re sensible, consistent and easy to follow. It also helps you prove that you’ve taken reasonably practicable steps to protect workers.

A practical policy typically includes:

• How you assess first aid risks (and who is responsible for reviews).
• Your ratios and coverage plan for first aiders across sites and shifts.
• Training requirements and who pays (your business should budget for this).
• What goes in your kits and how you maintain them.
• When a first aid room or other facilities are required, based on your risks.
• Clear procedures for response, reporting and regulator notifications.
• Record-keeping, privacy and data retention settings.

Review your arrangements at least annually or whenever something changes-new sites, growth in headcount, different processes or new hazards. Lessons learned from incident reviews should feed straight back into your risk assessment and policy updates.

Many businesses include first aid within a broader WHS management system and publish the key parts in their staff resources. If you’re refreshing your core documents, it can also be a good time to update your broader workplace policies and your Employee Handbook so everything is consistent and easy to find.

Common Pitfalls To Avoid

• Assuming a single kit or a single trained person is enough regardless of headcount, shifts or layout.
• Buying a kit and never checking it again-expired or missing items are a compliance risk.
• Forgetting remote or isolated workers who can’t access on-site first aid quickly.
• Not keeping training current-CPR refreshers are typically annual.
• Overlooking privacy when recording incident details.

Practical Tips To Lift Your First Aid Readiness

• Map your sites and shifts, then layer your first aider coverage to suit actual worker movements.
• Run short drills so people know what to do when seconds matter.
• Use signage and QR codes near kits to show first aider names, locations and procedures.
• Integrate first aid checks into your routine WHS inspections so it doesn’t get forgotten.

Key Takeaways

• All Australian businesses must provide suitable first aid equipment, facilities and trained first aiders that reflect their risks-this duty applies under state and territory WHS/OHS laws.
• A written First Aid Policy isn’t always prescribed by law, but documenting your arrangements is best practice and helps you meet your duty of care.
• Indicative ratios from the national Code of Practice are one first aider per 50 workers in low-risk workplaces, and one per 25 workers in high-risk workplaces-adjust for your sites, shifts and remote work.
• Employers should fund accredited training and CPR refreshers, keep a current register of first aiders and make coverage visible to staff; note any allowances or expectations in the Employment Contract where relevant.
• Keep clear, practical procedures for emergencies, maintain a first aid treatment register, and manage health information in line with your Privacy Policy and Privacy Collection Notice.
• Review your first aid arrangements at least annually and after any incident or major change; align updates with your broader workplace policies and Employee Handbook.

If you’d like a consultation about first aid arrangements or any other workplace health and safety requirements, you can reach us at 1800 730 617 or team@sprintlaw.com.au for a free, no-obligations chat.