How Many First Aiders Do I Need?

What does the law require?

The Health and Safety (First-Aid) Regulations 1981 require employers to provide adequate and appropriate equipment, facilities and personnel so that employees can receive immediate attention if they are injured or become ill at work.²

What is adequate and appropriate depends upon the circumstances of the workplace. Employers should therefore assess their first-aid needs rather than treating a numerical ratio as the legal requirement.

Core employer duties

In practical terms, employers should ensure that they:

• assess their first-aid needs, considering the work, hazards, workforce and working arrangements;
• provide suitable equipment and facilities, including a suitably stocked first-aid container whose contents reflect the needs assessment;
• appoint someone to take charge of the first-aid arrangements, whether or not trained first aiders are also required; and
• inform employees about the arrangements, including how to obtain assistance and where equipment is located.³

First-aid boxes should be readily identifiable; HSE guidance specifies a white cross on a green background.⁴

The important distinction is between having first-aid arrangements and having arrangements that are actually adequate.

On the face of matters, an organisation may appear well provided for because it has a first-aid kit and several employees hold certificates. On closer inspection, those arrangements may provide scant protection if nobody appropriately trained is available on a particular shift or if the equipment bears little relationship to the foreseeable injuries within that workplace.

What should a first-aid needs assessment consider?

A first-aid needs assessment should reflect the actual organisation, rather than a generic model.

Relevant factors include:

• the type of work carried out;
• workplace hazards and the injuries or illnesses that might reasonably arise;
• workforce size;
• how employees are distributed across the workplace;
• shifts, nights, weekends and staggered hours;
• holidays, sickness and other absences;
• previous accidents and first-aid incidents;
• lone, travelling and remote workers;
• multiple buildings, floors or sites;
• proximity and access to emergency medical services;
• shared or multi-occupancy premises;
• visitors, customers, service users and members of the public; and
• characteristics or known needs within the workforce that may affect appropriate provision.⁵

Two organisations employing exactly the same number of people may therefore require quite different arrangements.

What about employees or customers with additional needs?

The assessment should consider the people who actually work in or regularly use the workplace, rather than simply the number of names on a payroll.

Relevant considerations may include disability, known health conditions and other individual or workforce characteristics that could reasonably affect first-aid needs. HSE specifically notes that known health issues can be relevant to the needs assessment and, with an employee’s permission, first aiders may need awareness or additional training in relation to particular conditions.⁶

This should be approached sensitively. It does not mean making assumptions about somebody’s health or capability because of their age or disability.

Is there a first aider-to-employee ratio?

No. There is no statutory first aider-to-employee ratio.

HSE publishes indicative guidance to help employers identify a starting point, but it expressly states that there are no hard and fast rules on exact numbers.⁷

Important: these figures are HSE’s suggested starting points, not statutory ratios. The needs assessment must still take account of the actual workplace, workforce, hazards, shifts, absences, site layout and other relevant circumstances.⁸

Think about coverage, not just certificates

One of the easiest mistakes to make is to count qualified first aiders without considering their actual availability.

An employer may have three first aiders on its records:

• one works from home two days each week;
• another works mornings only; and
• the third works in a separate building.

On paper, there are three. At 4.30 pm on Tuesday, there may effectively be none.

What about holidays and sickness?

Employers should plan for both planned and unplanned absence. Annual leave, training, meetings and sickness can all reduce effective first-aid cover.

HSE specifically requires holidays and other absences to be considered. An appointed person can provide emergency cover within their role and competence where a first aider is absent unexpectedly, but HSE makes clear that annual leave is not an unforeseen absence.⁹

This may mean training more people than the apparent minimum simply to maintain reliable cover.

What if we operate shifts?

Each shift should be considered. Adequate provision at 10 am does not automatically mean adequate provision at 10 pm.

What if we have several floors or buildings?

A first aider being technically “on site” does not necessarily make them readily accessible. Large warehouses, factories, multi-floor offices and dispersed sites may require provision across different areas.

What about lone, travelling or remote workers?

Employees working away from the main site should not disappear from the assessment.

Depending upon the risk, arrangements could include:

• personal first-aid equipment;
• reliable communication;
• emergency procedures;
• additional training; or
• specific arrangements for obtaining assistance.

What about customers, visitors or members of the public?

The Health and Safety (First-Aid) Regulations primarily impose duties relating to employees. They do not create a specific duty under those Regulations to provide first aid to every customer or visitor.

However, HSE strongly recommends that non-employees are included when employers consider their first-aid provision.¹⁰

This can be particularly relevant in:

• retail;
• hospitality;
• churches and community organisations;
• leisure settings;
• educational premises;
• care and support services; and
• other public-facing workplaces.

Who is responsible for workplace first aid?

There is no rule requiring workplace first aid to be managed by one particular department or job title.

Across organisations, responsibility may sit with:

• Health and Safety;
• HR;
• Operations;
• Production;
• Facilities;
• an Office Manager;
• a General Manager;
• a director; or
• the business owner.

What matters is not the title, but whether responsibility has been clearly allocated and meaningfully discharged.

The underlying legal duty rests with the employer. Day-to-day administration can be delegated, but that does not make the employer’s responsibility disappear.

On the face of matters, responsibility may appear to have been dealt with because “HR looks after first aid” or “the Production Manager handles it”. On closer inspection, that only works if the person concerned has sufficient information, authority, resources and organisational support to make the arrangements effective.

Can individual managers or directors be prosecuted?

Potentially. Under section 37 of the Health and Safety at Work etc Act 1974, individual liability may arise in certain circumstances where a corporate health and safety offence was committed with an officer’s consent or connivance, or was attributable to their neglect.¹¹

That does not mean an HR Manager automatically becomes personally liable because they administer first-aid training. Responsibility, authority and the circumstances of the particular offence matter.

Do we need a trained first aider or an appointed person?

Not every workplace necessarily requires a formally trained first aider.

Where the needs assessment concludes that trained first aiders are unnecessary, the minimum personnel provision is an appointed person.

Their role includes taking charge of the arrangements, looking after equipment and facilities and calling the emergency services where necessary. HSE says an appointed person must be available whenever people are at work.¹²

An appointed person is not automatically a trained first aider and should not provide first aid beyond their competence.

What does a workplace first aider actually do?

A workplace first aider provides immediate assistance when somebody becomes injured or ill.

Depending upon their training and the circumstances, this may involve:

• checking that it is safe to approach;
• assessing what has happened;
• identifying immediate priorities;
• providing appropriate first aid;
• arranging professional medical assistance;
• monitoring and reassuring the casualty; and
• handing over relevant information to professional responders.

Their role is to provide immediate first aid, not to diagnose conditions or replace professional medical treatment.

What makes a good first aider?

Technical knowledge matters, but a good first aider is not simply the person who remembers the most procedures.

A doctor once described it to us particularly well:

That does not mean preventing every deterioration in the casualty’s condition. Sometimes that will be impossible.

It means helping prevent the scene itself becoming unsafe, chaotic or confused.

A good first aider can:

• remain as calm as possible;
• identify priorities;
• summon help early;
• give clear instructions;
• ask a specific person to call 999 or retrieve the AED;
• control unnecessary crowding;
• communicate reassuringly;
• protect the casualty’s privacy and dignity;
• recognise the limits of their own competence; and
• provide a clear handover when professional assistance arrives.

The first aider can therefore become a temporary coordinator of the immediate scene, as well as the person administering care.

Protecting dignity and privacy during an emergency

A serious incident can quickly attract attention, particularly in a public-facing workplace. Increasingly, somebody may also take out a mobile phone.

Where practicable, the organisation should consider the casualty’s privacy and dignity as part of scene management.

This may include:

• moving unnecessary bystanders away;
• using screens or other means of creating privacy;
• restricting access to the immediate area;
• asking people not to photograph or film;
• redirecting customers; and
• ensuring sensitive information is not casually disclosed.

The casualty’s medical needs remain the priority. They should not be moved simply to create privacy where movement could be unsafe.

Should a shop or public venue close?

Not necessarily.

A minor incident in one area of a large store may require little disruption. A cardiac arrest or serious traumatic incident in smaller premises may justify temporarily restricting access to part or all of the site so that first aid can be delivered safely, ambulance access remains clear and the casualty has a reasonable degree of privacy.

The response should be proportionate to the circumstances.

If somebody begins filming, the first aider should not become distracted by confrontation. Another employee or manager can deal with bystanders while the first aider concentrates upon the casualty.

Staff should not attempt to seize phones or delete images.

The speed with which images can reach social media creates an additional concern: relatives may potentially see or hear about an incident before appropriate communication has taken place. Scene management, internal communications and privacy should therefore form part of wider emergency planning.

Is a valid first-aid certificate enough?

A valid qualification is important where a trained first aider is required. But a certificate and continuing competence are not necessarily the same thing.

FAW and EFAW certificates normally remain valid for three years. HSE also expects first aiders to remain competent to perform their role and strongly recommends annual refresher training.¹³

Yet a workplace first aider may go months, or even years, without using some of their most important emergency skills.

They may never have to:

• perform CPR;
• use an AED during cardiac arrest;
• manage life-threatening bleeding;
• deal with anaphylaxis; or
• manage an unconscious casualty.

That is obviously fortunate. It also creates a competence challenge.

Why annual refresher training matters

Refresher training gives first aiders an opportunity to:

• practise skills they rarely use;
• rehearse CPR and AED use;
• revisit serious emergency scenarios;
• correct forgotten or poor technique;
• learn about changes in first-aid practice;
• rebuild confidence; and
• make decisions under simulated pressure.

In our experience, annual refresher training is still overlooked by many organisations.

That can leave a first aider holding a perfectly valid certificate but being asked to perform a rarely practised skill under considerable pressure.

Should first aiders practise workplace emergency scenarios?

We recommend considering simple workplace role plays and emergency scenarios in addition to formal training.

The aim is not to catch employees out. It is to discover problems before a real emergency exposes them.

For example:

• somebody collapses in the warehouse;
• a visitor becomes unconscious in reception;
• there is severe bleeding in production; or
• somebody suffers cardiac arrest in a remote part of the building.

Ask:

• Who notices first?
• Who calls 999?
• Who retrieves the AED?
• Who brings the first-aid kit?
• Who deals with the casualty?
• Who manages everybody else?
• Who meets the ambulance?
• What happens if the usual first aider is absent?

A short exercise can reveal problems no training certificate will identify: inaccessible equipment, uncertainty over roles, locked doors, poor communication or several people each assuming somebody else called the ambulance.

What about fire drills?

Fire drills provide an opportunity to consider how emergency roles operate together. A first aider may, for example, report to a nominated assembly point after evacuation and remain available if anybody has been injured or becomes unwell.

Their role should not interfere with safe evacuation, and a first aider should not remain in or re-enter an unsafe building simply because somebody may require assistance.

Can a first aider also be a fire warden?

Yes, potentially.

In some workplaces that may be entirely sensible. However, the organisation should consider whether the two roles could conflict during an emergency.

Can a first aider be sued for trying to help?

People sometimes worry that becoming a first aider could expose them to legal action if something goes wrong.

A civil claim can in principle be brought where negligence is alleged, but an adverse medical outcome does not itself establish negligence. HSE describes legal action against a first aider using the training they have received as very unlikely.¹⁴

In England and Wales, the Social Action, Responsibility and Heroism Act 2015 requires courts considering relevant negligence or breach-of-statutory-duty claims to take account of certain circumstances, including social action, a predominantly responsible approach and heroic intervention in an emergency.¹⁵

The Act does not give first aiders blanket immunity.

The sensible approach is to:

• work within training and competence;
• follow recognised first-aid practice;
• obtain professional assistance where required;
• continue appropriate care until help arrives; and
• report the incident accurately afterwards.

First aiders should not be discouraged from providing appropriate assistance because of an exaggerated fear of litigation.

EFAW or FAW?

The needs assessment should also determine the level of training required.

Emergency First Aid at Work (EFAW) provides competence in emergency first aid when somebody is injured or becomes ill at work.

First Aid at Work (FAW) covers a broader range of workplace injuries and illnesses.

Higher-risk workplaces are consequently more likely to identify a need for FAW-trained personnel, but the decision should reflect the foreseeable needs of the workplace rather than employee numbers alone.

How long is a first-aid certificate valid?

FAW and EFAW qualifications normally remain valid for three years.¹³

Maintaining a current register containing:

• first aider name;
• qualification;
• expiry date;
• refresher activity; and
• usual work area or shift

is sensible practice.

Do employees know the arrangements?

First-aid provision is of limited value if employees do not know how to access it.

Employees should know:

• who the first aiders or appointed persons are;
• how to contact them;
• where first-aid equipment is;
• where the AED is, if one is provided; and
• how emergency medical assistance is summoned.

Information should also be accessible to people with relevant language, literacy or communication needs.

What happens after a serious first-aid incident?

A serious workplace incident may affect the casualty, witnesses, colleagues, managers and the first aider who responded.

Who looks after the first aider?

A first aider may just have dealt with a colleague who was critically injured, in cardiac arrest or dying. Being trained for that possibility does not make somebody immune from its effects.

Managers should consider:

• Does the first aider need time away from normal duties?
• Would finishing early be appropriate?
• If they perform safety-critical work, are they sufficiently composed to return to it safely?
• Has somebody spoken privately with them?
• Will somebody check on them again later or the following day?
• Do they know where further support is available?

There should not be a rigid rule that every responder must automatically be sent home. People react differently.

Equally, somebody who has just performed prolonged CPR should not automatically be returned immediately to driving an HGV, operating dangerous machinery or another safety-critical activity without somebody considering whether they are fit to continue.

A follow-up matters

The first conversation immediately afterwards may not tell the whole story. Somebody who appears fine that afternoon may sleep badly and feel very differently the next morning.

A simple follow-up can give them permission to say: “Actually, I keep thinking about what happened.”

Operational and human debriefing

A post-incident discussion can consider both:

Operationally:

• What worked?
• What did not?
• Was equipment available?
• Did people know their roles?
• Does the emergency plan need changing?

And personally:

• How are you feeling?
• Is anything troubling you?
• Is there anything you would like to talk through?

Can an employer be fined for inadequate first-aid provision?

Yes.

Inadequate first-aid arrangements can form part of health and safety enforcement action and, where the circumstances warrant it, prosecution.

There is no standard fine for “too few first aiders”. Enforcement and sentencing depend upon the particular circumstances, including the seriousness of the failures and the risk created.

Why good first-aid provision matters beyond compliance

There are legal, financial and moral reasons for managing health and safety well.

But the consequences of serious workplace injury should not be reduced to regulatory penalties and spreadsheet costs.

An accident may affect a person’s:

• health;
• ability to work;
• income;
• independence;
• family life; and
• long-term quality of life.

In the gravest circumstances, somebody may never work again, or may not return home.

The consequences can extend to partners, children, colleagues and families.

For the employer there may also be:

• absence and replacement staffing;
• recruitment and retraining;
• loss of skills and experience;
• investigation and management time;
• operational disruption;
• legal and compensation costs;
• insurance consequences; and
• damage to reputation and workforce confidence.

There is also an important distinction between the original incident and what happens afterwards.

An employer cannot necessarily prevent every sudden illness or every workplace injury. But inadequate assistance after an event may compound its consequences.

Worked examples

Work out what your organisation needs

Related First Aid Advice

This guide forms part of The Hive Collaborative’s First Aid Advice & Guidance resource.

Further guides will include:

• First Aid Needs Assessment
• Appointed Person or First Aider?
• Emergency First Aid at Work or First Aid at Work?
• Maintaining First-Aider Competence
• Testing Workplace First-Aid Arrangements
• Workplace First Aid Kits
• First Aid for Lone and Remote Workers
• Managing Privacy and Bystanders During a Workplace Emergency
• Supporting a First Aider After a Serious Incident

Links will be added as individual guidance pages are reviewed and published.