Should Cal/OSHA Eliminate the Physician Approval Requirement for First Aid Kits?
I believe the answer is yes.
The Cal/OSHA Standards Board is currently considering a proposal to modernize California's workplace first aid requirements by removing the long-standing requirement that first aid kits be approved by a consulting physician. Instead, employers would be able to comply by maintaining first aid kits that meet the nationally recognized ANSI/ISEA Z308.1 standard.
As an Environmental Health and Safety (EHS) professional, I support this proposal.
For years, the physician approval requirement has been one of California's more difficult compliance obligations—not because employers don't care about first aid, but because finding a physician willing to review and approve a workplace first aid kit can be challenging. Even when one is available, many physicians are not familiar with the day-to-day hazards found in manufacturing, aerospace, metal fabrication, warehousing, heat treating, or corrugated packaging facilities.
Safety professionals, however, evaluate workplace hazards every day.
We conduct hazard assessments, perform job hazard analyses, investigate injuries, evaluate emergency response procedures, and identify the types of incidents most likely to occur in a facility. Understanding workplace hazards is what we do.
That is why I believe this proposed rule is a practical, common-sense improvement.
The proposal does not reduce worker protections. Instead, it modernizes California's regulations by recognizing a nationally accepted standard while allowing employers to tailor their first aid supplies to the hazards identified in their own workplaces.
Rather than focusing on obtaining a physician's signature, employers can focus on what really matters—making sure employees have the right first aid supplies available when an injury occurs.
Moving Beyond the Standard Kit
One thing I've learned after years of conducting workplace hazard assessments is that too many first aid kits are designed to satisfy a checklist—not the hazards employees actually face.
An office, a warehouse, a machine shop, a heat treating facility, and a corrugated manufacturing plant do not have the same injury risks, yet many of them are stocked with nearly identical first aid kits.
The ANSI/ISEA Z308.1 standard provides an excellent foundation, and I encourage every employer to use it as the baseline for their first aid program. But compliance shouldn't stop there.
A hazard assessment should drive what goes into your first aid kit.
For example, facilities with significant thermal burn hazards should evaluate whether additional burn care supplies are appropriate. Operations involving machinery may require additional fingertip bandages, trauma dressings, or eye injury supplies. Chemical operations may need specialized decontamination supplies. Every workplace is different, and first aid preparedness should reflect those differences.
Prescription medications or specialized treatment products should always be evaluated in consultation with the employer's occupational health provider or consulting physician. However, identifying the workplace hazards that drive those decisions is exactly where safety professionals provide value.
A first aid kit should never be something that's purchased off the shelf and forgotten. Like PPE, machine guarding, emergency eyewash stations, and emergency action plans, it should be reviewed periodically to ensure it still matches the hazards present in the workplace.
My Perspective
One of the reasons I support the Standards Board's proposal is that it shifts the conversation away from paperwork and toward preparedness.
The ANSI standard establishes a strong minimum expectation for workplace first aid, but it should be viewed as the starting point—not the finish line. Employers should ask themselves a simple question:
"If an employee is injured today, do we have the supplies needed to respond to the injuries most likely to occur in our facility?"
If the answer is no, the first aid program deserves another look.
As safety professionals, our role is to anticipate hazards before injuries occur. That same philosophy should apply to workplace first aid. We should be building first aid programs around risk assessments, injury history, and the specific operations performed—not simply purchasing a generic first aid kit and assuming it will meet every need.
I applaud the Cal/OSHA Standards Board for considering this modernization. Aligning California's regulations with the ANSI/ISEA Z308.1 standard is a practical step that reduces unnecessary administrative burdens while maintaining a strong commitment to worker protection.
I'll continue following this rulemaking process closely and will share updates as the proposal moves forward. If adopted, I believe it will help California employers focus less on paperwork and more on what matters most: making sure employees receive the right first aid, at the right time, for the hazards they face every day.Start writing here...