Work Health and Safety (First Aid in the Workplace) Code of Practice 2015

The Work Health and Safety (First Aid in the Workplace) Code of Practice 2015 is an approved code of practice made under section 274 of the Work Health and Safety Act 2011. It is a practical guide to achieving the standards of health, safety and welfare required under the WHS Act and the Work Health and Safety Regulations.

The Code is not a separate set of standalone rules that replaces the Act or Regulations. Instead, it explains practical ways a duty holder can meet first aid obligations at work. The Code itself says that, in most cases, following an approved code of practice would achieve compliance with the health and safety duties in the WHS Act for the subject matter covered by the code.

The Code also explains that compliance may be achieved by another method, such as a technical or industry standard, if that method provides an equivalent or higher standard of work health and safety than the code. That matters for businesses with specialised operations, but it also means you should not depart from the Code casually. If you use a different approach, you should be confident it delivers at least the same level of protection.

Courts may regard a code of practice as evidence of what is known about a hazard, risk or control and may rely on it in deciding what is reasonably practicable. Inspectors may also refer to an approved code of practice when issuing an improvement or prohibition notice. For a business owner, the practical message is simple: if your first aid arrangements are weak, outdated or not matched to your actual risks, this Code is likely to be one of the first reference points used to assess your systems.

The Code applies to persons conducting a business or undertaking, often called PCBUs, in workplaces covered by the WHS Act. It applies to all types of work and all workplaces covered by that Act, including workplaces that are outdoors, mobile or remote.

A PCBU has the primary duty to ensure, so far as is reasonably practicable, that workers and other persons are not exposed to health and safety risks arising from the business or undertaking. The WHS Regulations place specific obligations on a PCBU in relation to first aid. Those obligations include providing first aid equipment, ensuring access to facilities for administering first aid, and ensuring that an adequate number of workers are trained to administer first aid or that workers have access to an adequate number of other trained people.

Officers, such as company directors, also have duties. They must exercise due diligence to ensure the business or undertaking complies with the WHS Act and Regulations. Workers have duties too. They must take reasonable care for their own health and safety, avoid adversely affecting others, comply with reasonable instructions, and cooperate with reasonable workplace policies and procedures, including first aid and injury reporting procedures.

When working out who needs access to first aid, the Code says you should consider not only direct employees but also contractors, subcontractors and volunteers you engage. You should also consider other people at the workplace, such as students or members of the public, where relevant to the workplace.

This instrument is in force on the Federal Register of Legislation and is administered by the Department of Employment and Workplace Relations. It was developed by Safe Work Australia as a model code of practice for adoption by the Commonwealth, state and territory governments.

That means businesses should be careful about assuming the same code applies in exactly the same way everywhere in Australia. The Code is intended for jurisdictions that have adopted the model WHS laws. If your business operates across multiple jurisdictions, you should confirm whether this exact code, or a local equivalent, applies where your workers are located. This is particularly important before relying on the page for operations outside the Commonwealth model WHS setting.

For businesses operating nationally, the safest approach is to treat this Code as a strong practical benchmark for first aid planning, then check the local WHS regulator or local legislation for any jurisdiction-specific differences before finalising your systems.

The Code says first aid requirements vary from one workplace to the next. You must take into account the nature of the work, the type of hazards, the workplace size and location, and the number of people at the workplace. Regulation 42 is specifically identified as requiring a PCBU to consider all relevant matters including the nature of the work being carried out, the nature of the hazards, the size, location and nature of the workplace, and the number and composition of workers.

The Code uses a risk management approach. In practical terms, that means you should identify hazards that could result in work-related injury or illness, assess the type, severity and likelihood of injuries and illness, provide appropriate first aid equipment, facilities and training, and then review your requirements regularly or when circumstances change.

Common trigger points include hazardous machinery, hazardous substances, work at height, electrical risks, extreme temperatures, violence risks, biological hazards, animal-related risks, dispersed work areas, multiple floors, remote work, shift work, overtime, and workplaces where members of the public are present. Records of injuries, illnesses and near misses should be used to help decide what first aid arrangements are appropriate. If hazardous chemicals are handled, used or stored, the safety data sheet should also be checked for first aid requirements and health effects.

The practical obligations described in the Code fall into several connected areas. First, all workers must be able to access a first aid kit. At least one first aid kit will be required at the workplace, but many businesses will need more than one depending on risk, layout and workforce size. Kits should be based on a risk assessment and should be located where they can be retrieved quickly, especially near higher risk areas.

Second, you must ensure access to facilities for administering first aid. In some workplaces, a clean and quiet area with privacy may be enough. In others, a dedicated first aid room may be recommended. The Code recommends a first aid room for low risk workplaces with 200 workers or more, and high risk workplaces with 100 workers or more. Access to a telephone or emergency call system should be provided as part of all first aid facilities.

Third, you must ensure that an adequate number of workers are trained to administer first aid, or that workers have access to an adequate number of other trained people. The Code recognises that this can be done by training your own workers or arranging access to trained people from another business or service, provided access is available when your workers are working.

Fourth, first aid information and procedures need to be workable in real conditions. Equipment, facilities and first aiders must be accessible whenever workers work, including night shifts and overtime. If your workers are mobile, portable kits may be needed in vehicles. If your workers are remote or isolated, communication systems and emergency response planning become more important because ambulance or hospital access may be delayed.

Fifth, consultation is part of the legal framework. You must consult workers, and if represented, involve health and safety representatives when making decisions about first aid facilities, kit numbers and locations, procedures and the number of first aiders. If other duty holders share responsibility for the same matter, you must consult, cooperate and coordinate with them.

The Code says the contents of first aid kits should provide basic equipment for administering first aid for injuries including cuts, scratches, punctures, grazes and splinters, muscular sprains and strains, minor burns, amputations or major bleeding wounds, broken bones, eye injuries and shock. The exact contents should be based on your risk assessment.

Each kit should be large enough to contain the necessary items, be immediately identifiable with a white cross on a green background, contain a list of contents, and be made of material that protects the contents from dust, moisture and contamination. Kits should be kept in a prominent and accessible location, and access should also be ensured in security-controlled workplaces.

The Code gives practical location guidance. If a workplace occupies several floors in a multi-storey building, at least one kit should be located on every second floor. Emergency floor plans should include the location of first aid kits. Portable first aid kits should be provided in the vehicles of mobile workers where the vehicle is their workplace, and those kits should be stored safely so they do not become a projectile in an accident.

A person should be nominated to maintain each kit, usually a first aider. Used items should be replaced as soon as practicable. Regular checks should be carried out after each use or, if the kit is not used, at least once every 12 months. The inventory list should be signed and dated after each check, and items should be in good order, within expiry dates, and sealed where sterile.

Beyond standard kits, the Code says businesses should consider whether other first aid equipment is necessary. It specifically discusses automated external defibrillators, eye wash equipment and shower equipment. An automated external defibrillator can reduce the risk of fatality from cardiac arrest and is described as a useful addition where there is a risk of electrocution or where there are large numbers of members of the public. Eye wash equipment should be provided where there is a risk of hazardous chemicals or infectious substances causing eye injuries. Shower equipment may be needed where there is a risk of hazardous chemical exposure, infectious contamination, or serious burns to a large area of the face or body.

A risk assessment will help determine the type of first aid facilities needed. For some workplaces, a clean, quiet area that affords privacy may be suitable and practicable. For others, especially where serious injury or illness is more likely, a dedicated first aid room may be appropriate.

The Code recommends a first aid room for low risk workplaces with 200 workers or more and high risk workplaces with 100 workers or more. The contents of the room should suit the hazards specific to the workplace. The room should allow easy access and movement of injured people, including by stretcher or wheelchair where needed.

The Code lists items that should be provided in a first aid room, including an appropriate first aid kit, hygienic hand cleanser and disposable paper towels, an examination couch with waterproof surface and disposable sheets, an examination lamp with magnifier, storage, waste disposal containers, a sharps container, a bowl or bucket, electric power points, a chair and table or desk, a telephone or emergency call system, and the names and contact details of first aiders and emergency organisations.

The room should be near a sink with hot and cold water where that is not provided in the room, near toilet facilities, offer privacy, be accessible to emergency services, be well lit and ventilated, have an appropriate floor area, and have an entrance clearly marked with first aid signage. The Code also discusses health centres staffed by a registered health practitioner or paramedic for some high risk workplaces.

The WHS Regulations require an adequate number of workers to be trained to administer first aid at the workplace, or for workers to have access to an adequate number of other trained people. The Code recognises more than one way to meet this requirement. You can train your own workers, or arrange for another trained person to administer first aid to your workers, such as first aiders from another business sharing the workplace or other qualified people.

If you rely on another business's first aiders, you need to consult, cooperate and coordinate access arrangements and make sure access is available at the times your workers carry out work, including where shift work is involved. This is especially important in shared buildings, shopping centres, labour hire arrangements and host workplace settings.

The Code says first aiders should hold nationally recognised Statements of Attainment issued by a Registered Training Organisation for the nationally endorsed first aid units of competency. The extract specifically refers to Provide First Aid as covering competencies to recognise and respond to common life-threatening injuries or illnesses, including life support using CPR, and to manage the casualty and incident until medical or other assistance arrives.

The number of first aiders needed is not fixed by a single rule in the Code extract provided here. It depends on the risk assessment, the nature of the workplace, the number and composition of workers and others, and when work is performed. Businesses should make sure trained coverage exists whenever workers are present, not just during standard daytime hours.

The Code places real emphasis on consultation. A PCBU must consult, so far as is reasonably practicable, with workers who carry out work for the business or undertaking and who are, or are likely to be, directly affected by a work health and safety matter. If workers are represented by a health and safety representative, that representative must be involved in the consultation.

For first aid, consultation should include the number, location and contents of first aid kits and other equipment, the type of first aid facilities that may be needed, first aid procedures, and the number of first aiders. This is not just good practice. It is part of the legal framework described in the Code.

The Code also deals with overlapping duties. If you share responsibility for health and safety with other business operators involved in the same activities or sharing the same workplace, you must consult, cooperate and coordinate activities with them so far as is reasonably practicable. The Code gives labour hire as an example. In that setting, both the labour hire business and the host business have duties, and they must discuss hazards and risks and ensure the host business has appropriate first aid arrangements that the labour hire workers can access.

In shared workplaces, you may be able to rely on another business's first aiders, equipment or facilities, but only after working through what arrangements are needed, how equipment and facilities will be shared, and how access to first aiders will operate in practice.

The Code says first aid requirements should be reviewed on a regular basis or as circumstances change. This is part of the risk management approach. First aid is not something you set once and forget.

In practice, a review should be triggered when there are changes to the work being done, new hazards, changes in workforce numbers or composition, changes to the workplace layout, incidents or near misses, changes to emergency response times, or changes in who else shares the workplace. Reviews should also pick up whether kits are still correctly stocked, whether first aiders are still available across all working hours, and whether facilities remain suitable for the actual risks.

For businesses, the practical check is whether your current arrangements still match the real conditions of work. If your business has grown, moved, added shifts, introduced hazardous chemicals, started field work, or begun sharing premises with others, your first aid arrangements may need to change as well.