Association Voices Concerns at Cal/OSHA Hearing on First Aid Kit Revisions

At last week’s California Occupational Safety and Health Standards Board public hearing, the Board heard recommendations for revisions to the proposed First Aid kit Standard, particularly the inclusion of naloxone (Narcan) and the removal of detailed kit content tables from regulation.
 
During public testimony the Association’s Assistant Vice President Priscilla Rodriguez addressed the Board regarding the practical challenges of requiring naloxone, commonly known as Narcan, in first aid kits. Rodriguez explained that naloxone must be stored in a cool temperature to maintain stability, a requirement that would be extremely difficult to meet in farming and agricultural operations. She noted that first aid kits are commonly stored in supervisors’ vehicles or in shaded area environments that routinely exceed recommended storage temperatures. As a result, compliance could prove nearly impossible.
 
Rodriguez also opposed the proposal to remove the table listing required first aid kit contents and instead rely solely on reference to the ANSI first aid kit standard. She emphasized that eliminating the detailed list from the regulation would require employers to purchase the ANSI standard to determine what is required for compliance. “Workplace safety regulations should be accessible to all employers,” she testified, noting that regulated parties should not have to buy a private standard in order to understand legal requirements.
 
The Associations formally opposed both the inclusion of naloxone in mandated first aid kits and the removal of explicit kit content language from the regulation. The Standards Board will continue deliberations as part of its broader effort to revise California’s first aid kit standard.