First Aid, CPR, and AED Certification: OSHA Requirements and What Employers Need (2026)

Most employers know they need first aid training. Fewer know exactly what OSHA requires, which certifications actually count, or how many people they need trained to satisfy the standard. Those gaps lead to either over-training (expensive) or under-training (a compliance problem and a real risk to workers).

Here’s what the standard actually says and how to apply it.

What OSHA’s 1910.151 Actually Requires

The core of OSHA’s General Industry first aid standard is at 29 CFR 1910.151(b): “In the absence of an infirmary, clinic, or hospital in near proximity to the workplace which is used for the treatment of all injured employees, a person or persons shall be adequately trained to render first aid.”

Two things matter in that sentence. First, the “near proximity” test. OSHA has clarified through letters of interpretation that near proximity generally means within 3 to 4 minutes response time. If your facility can’t count on emergency services or a medical facility arriving within that window, you need trained personnel on-site during all working hours. Most manufacturing facilities, construction sites, and remote worksites don’t meet that threshold.

Second, the word “adequate.” OSHA doesn’t define adequate numerically. It means enough trained people to respond to the foreseeable injuries at your facility, during all hours of operation. That interpretation has teeth: if an inspector reviews your training records and finds gaps in shift coverage, that’s a citation.

Construction has its own first aid standard at 29 CFR 1926.50. Maritime operations have a separate requirement. Some states with their own OSHA plans, including California, Washington, and Michigan, have standards that go beyond the federal floor. Check your state’s requirements if you’re in a state plan state.

One point about CPR specifically: 1910.151 doesn’t mention CPR by name. OSHA’s interpretation, confirmed in multiple letters, is that “adequately trained” first aid personnel should be capable of responding to cardiac emergencies, which includes CPR competency. The practical standard is a full first aid and CPR certification, not a first aid-only certificate.

AHA vs. Red Cross vs. Other Providers

American Heart Association (AHA) and American Red Cross are the two recognized providers employers rely on most. Both are credible, both align with ILCOR (International Liaison Committee on Resuscitation) guidelines, and both require hands-on skills evaluation for full certification.

The AHA splits its courses by audience. BLS (Basic Life Support) is the healthcare-provider standard and includes one and two-rescuer CPR techniques, bag-mask ventilation, and team dynamics. For workplaces outside healthcare, AHA’s Heartsaver First Aid CPR AED is the right choice. It covers adult, child, and infant CPR, AED use, bleeding control, choking response, and basic first aid. Certification is valid for two years.

Red Cross Workplace First Aid and CPR covers comparable content. It’s also ILCOR-aligned and two-year certification. Red Cross tends to have strong group training infrastructure and can often deploy instructors to your facility for on-site training sessions.

ASHI (American Safety and Health Institute) is a third credible option. Their curriculum is also ILCOR-aligned. Some industries accept ASHI certifications without issue. Others specify AHA or Red Cross by name. Check your specific industry requirements or insurance requirements before defaulting to ASHI.

Avoid online-only certificates that don’t include a hands-on skills component. A certificate that says “CPR Trained” from a course where the student only watched videos and clicked through a quiz won’t hold up under OSHA scrutiny, and more importantly, it doesn’t prepare someone to actually perform CPR.

What Gets Covered in Training

A standard AHA Heartsaver or Red Cross Workplace course covers CPR for adults, children, and infants. That includes compression depth, rate, and the rescue breathing sequence. AED operation is covered in detail: how to power it on, electrode placement, recognizing when to use it, and understanding what the device does.

First aid content covers bleeding control and wound care, choking response for conscious and unconscious victims, shock recognition and management, and the ability to recognize signs of cardiac events and stroke. The stroke recognition piece matters: knowing the FAST acronym (Face drooping, Arm weakness, Speech difficulty, Time to call 911) and acting on it quickly makes a real difference in outcomes.

Many employers also add Stop the Bleed training alongside first aid CPR. Stop the Bleed, developed from military trauma research, focuses specifically on tourniquet application and wound packing for severe bleeding emergencies. It’s a separate two-hour course, not bundled into standard first aid CPR. For high-hazard workplaces or any site with significant laceration or amputation risk, adding Stop the Bleed to your training program is worth doing.

AED Programs: The Maintenance Problem

OSHA doesn’t require AEDs specifically. OSHA’s position, stated in letters of interpretation, is that AEDs are encouraged but not mandated under 1910.151. The standard only requires that trained first aid personnel are available.

But many state laws do require AEDs in specific occupancies, including schools, fitness facilities, and in some states, large employers above a certain headcount. Check your state’s AED statute. This is an area where state law often goes further than federal OSHA.

If you have AEDs, you have an equipment maintenance obligation. AED electrode pads and batteries both have expiration dates. Pads typically expire every two to four years depending on the manufacturer. Batteries can last several years in standby mode but need regular verification. The device status indicator (usually a green light or checkmark) tells you if the unit is ready, but that indicator only checks the battery, not pad expiration.

Put AED checks on a monthly or quarterly calendar. Create a physical inspection log. When you train new designated responders, walk them to the AED cabinet locations. The number of facilities that have bought AEDs, done initial training, and then let the pads quietly expire is not small. That’s a real liability and a real risk.

For more on what workplace first aid incidents trigger formal recordkeeping, see the OSHA 300 log and recordkeeping requirements.

How Many People to Train

OSHA’s “adequate” standard gives you no precise number, which means you have to reason it out yourself.

The practical baseline: at least one trained first aider on-site during all working hours, per work area. For a single-building 40-person facility on one shift, that means at least one trained person present during that shift. For a three-shift operation with workers in multiple buildings, you need coverage across all shifts in each location.

Factor in turnover. If you train only the minimum number, a round of turnover can leave you non-compliant without anyone noticing. Training 150% of your minimum coverage target gives you a buffer.

High-hazard environments need more. A facility with significant fall risk, operating heavy equipment, or working with energized equipment should have multiple trained first aiders per shift. The injury potential is higher, and a single trained person may be the one who gets hurt.

Remote sites need special attention. A crew working 30 minutes from the nearest hospital with only one trained first aider is technically compliant if that person is on-site, but practically exposed if that person is the victim.

For the full picture on what OSHA requires employers to provide in terms of training across different hazard categories, see the employer safety training requirements guide.

Training Logistics and Records

Group rates from AHA and Red Cross are significantly lower than per-person registration. Most providers can send certified instructors to your facility for on-site training, which reduces employee time away from work and often costs less than sending 20 people to an off-site class.

OSHA requires you to document training. Training records for first aid certification should include employee name, date of training, trainer’s name and credentials, and the certification expiration date. Keep these records accessible. If an OSHA inspector asks whether your workforce has current first aid coverage, you need to be able to show it.

Bloodborne pathogens training is a separate OSHA requirement under 29 CFR 1910.1030 that applies to workers with occupational exposure to blood or other potentially infectious materials. First aid responders typically qualify for that exposure category. Many employers bundle bloodborne pathogen training with first aid CPR renewal to simplify scheduling, but note that it’s a distinct standard with distinct documentation requirements. Don’t let the bundling create a gap in your BBP records.

Schedule renewal training before certifications expire. AHA and Red Cross both issue certification cards with expiration dates. Put those dates in your safety calendar and start scheduling renewal two to three months out. If even one trained person’s certification lapses and an injury happens during that period, you have a compliance gap.

The AED is the piece most employers get wrong: they buy the equipment, run the initial training, and then the batteries and pads expire before anyone checks. Put AED maintenance on a quarterly calendar reminder. That’s it.