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June 4, 2009

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Acceptable in the eighties

The Health and Safety (First Aid) at Work Regulations 1981 have, for the most part, served industry well by setting a basic standard for first-aid provision in the workplace. But, prompted by changes in the world of work, revised guidelines are due to be implemented in October this year. Maria Grundy considers how the new requirements will impact on employers.

The Health and Safety (at Work) Regulations 1981 (FAW) came into force on 1 July 1982 and so have been operational now for more than 25 years. Casella Winton was commissioned in 2001 to provide a report1 on how employers view the Regulations and what factors influence whether they comply with them. The report was published in 2003 and provided the framework for a more focused consultation with employers, training providers, and other stakeholders.

A different world of work

When the FAW regulations came into force the UK was still predominantly a manufacturing-based economy. Hence, the Regulations, along with the accompanying Approved Code of Practice (ACoP)2 and guidelines, were written to reflect the needs at that time.

Since then, however, the emphasis has moved away from manufacturing towards a more service-based economy, with a heavier weighting of small and medium-sized enterprises than previously existed. Concurrent with this shift in industry has been a considerable development of workplace safety regulation, resulting in safer work practices and a reduction of risk in the workplace, while the response times of the emergency services have also improved. All these trends illustrate how the requirements for first aid at work have altered significantly since the inception of the FAW regulations.


In addition to these changes in industry and the workplace, the Casella Winton report identified a number of key aspects for consideration in the review of the regulations: 

  •   The difficulty of smaller organisations to release employees to attend a four-day first-aid at work course – not so much from a cost aspect but from the loss of employee work days;
  • A level of confusion exists about the role and training requirements of an appointed person. Some organisations have been using their appointed person as a first-aider after they have attended just a one-day training course.
  • Both training providers and first-aiders highlighted ‘skills decay’ as an issue, where many attendees of first-aid courses show a significant depletion in the retained information only a short period after training. An HSE review of scientific and medical literature on the issues of skills and knowledge-retention3 added further weight to this issue, by suggesting that, even two months after their training, some attendees cannot adequately perform basic life support.

Based on these findings the HSE published a Discussion Document in 2003,4  requesting views from stakeholders on a range of topics, including first-aid legislation, training, approval of first-aid at work training organisations, first-aid equipment, and medications. In general, the responses and views received confirmed the findings of the earlier report.

Need for clarification

This feedback from the stakeholders enabled the HSE to firm up the proposals and develop a paper5 detailing the proposals for change. The proposals included the need for further assistance on understanding how to implement the FAW regulations; and more detailed clarification in the guidance to facilitate understanding of such aspects as: making an assessment of need, defining roles and responsibilities, and advice on new topics and developments as they arise.

To address a range of issues, changes to the structure of first-aid training courses were also recommended, including a reduction in the contact hours for the First Aid at Work qualification, introducing annual refresher training, and adding a new approved qualification.

In essence, what the HSE found was that stakeholders felt the regulations and ACoP were still relevant and addressed the need for first-aid provision in the workplace, and that neither required any changes to be made. However, the guidelines needed some significant alterations to bring them into line with current workplace requirements, and to offer more clarification on their implementation.

A flexible approach

The major change to the guidelines is in the first-aid training requirements. Currently, to comply with the FAW regulations a workplace must have an appointed person, or a first-aider (or multiples thereof). The training course for a first-aider is four days in duration and must be approved by the HSE, while the training for an appointed person is generally one day and is not regulated.

The new training guidelines will introduce the following:

  • a new first-aid course – Emergency First Aid at Work (EFAW), which will last one day and enable a first-aider to give emergency first aid to someone who is injured, or becomes ill at work;
  • a reduced minimum training requirement of three days for the First Aid at Work (FAW) course. FAW covers all that EFAW does, as well as how to deal with a range of specific illnesses or injuries; and
  • a strong recommendation by the HSE that first-aiders undertake annual refresher training of half a day during the FAW/EFAW three-year certification period.

As with the FAW course, the EFAW course will be delivered by an HSE-approved organisation. However, an awarding body recognised by either Ofqual or the Scottish Qualifications Authority can also deliver the course.

So, why are these changes being brought in, how are they expected to help employers, and how will they address the issues raised in the initial consultation process? The EFAW course is being introduced to allow employers to provide a more proportionate response in line with their needs. For example, a risk assessment may show that some level of first aid is required but that a FAW first-aider would be surplus to needs. The EFAW aims to give the duty-holder a choice of approved courses, thereby ensuring that adequate first aid is available without placing excessive burdens on business.

The EFAW course also aims to formalise the training and role of employees with basic first-aid training, especially where FAW training may have been deemed surplus to needs. By providing a viable option to FAW it aims to reduce the incidence of appointed persons being incorrectly used as first-aiders.

Further addressing the burdens placed on businesses is the reduction in the duration of the FAW course, which is being brought in as a response to the concerns raised by employers (especially of small and medium-sized businesses) about losing employees for four days. A reduction to a minimum of three days will ease the onus on employers without impacting too negatively on the quality of training.

Skills decay

Maintaining the skills learnt on the FAW/EFAW courses and keeping abreast of changes to first-aid procedure were also identified in the consultation process as being areas where improvements were needed. Here, the introduction of annual refresher training for both courses should ensure that both levels of first-aiders do not suffer from the identified problems associated with ‘skills decay’, and will therefore be able to administer effective first aid, when required.

It is important to stress that, despite these changes to the guidelines, the Approved Code of Practice and Regulations will not change – nor will the minimum requirement for organisations to select an appointed person. The new guidelines will come into force on 1 October 2009, although employers will be pleased to note that any FAW certificates current at that time will remain valid until their expiry date.

The guidance for employers on the changes to first-aid training will be published in an updated version of L74 First Aid at Work: Approved Code of Practice, which is due to become available in October. One of the key proposed changes to the document is the replacement of a table of the suggested numbers of first-aid personnel with a flow chart aimed at assisting employers in deciding what their requirements are in terms of first-aid provision. The flow chart should help employers take account of all the factors that affect first-aid needs, such as shift workers, previous accidents, special hazards, and so forth, in a bid to ensure that first-aid provision is both adequate and relevant.


After 25 years without change, the first-aid training requirements in the UK are due to undergo their biggest shake-up since their inception. Employers and employees alike are set to benefit through more appropriate training guidelines designed with the needs of modern businesses in mind. A reduced burden on employers through more training options and shorter courses, alongside annual refresher training, should see the provision of first aid in the workplace become more appropriate and up to date.

References and further reading

1     Casella Winton (2003): Evaluation of the Health and Safety (First-Aid) Regulations 1981 and the Approved Code of Practice and guidance, HSE research report 069,
2   HSE (1997): First aid at work. The Health and Safety (First-Aid) Regulations 1981, Approved Code of Practice and Guidance (L74), HSE Books, ISBN 0 7176 1050 0
3   Woods, M (2002): First-aid training: retention of skills and knowledge. A summary of the literature, HSE (can be obtained from the Corporate Medical Unit of HSE)
4   HSE (2003): A review and evaluation of the effectiveness of the Health and Safety (First-Aid Regulations 1981), DDE 21,
5   HSC (2004):

For more information on the new first-aid training requirements, go to:

Maria Grundy is business development manager at First Aid International.



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