First Aid – Project sites Legislative Interpretations

Question:
When there is more than one contractor on a project site, who is responsible to ensure compliance with the First Aid Regulation?

Answer:
In a situation where there is a (principal) contractor and one or more sub-contractors, the contractor is responsible for compliance with the First Aid Regulation. To ensure compliance, the contractor should consider the following.

1. During the life of the project, the number of employees on the project site can vary significantly; the contractor should therefore take steps to ensure that the appropriate number of first aid kits, first aid providers and first aid room (if required) is provided for the number of employees on any given day.
2. It is possible for one project site to be very large, very long or have physical impediments that would affect the timely administration of first aid. The contractor should ensure that the location and number of first aid kits, first aid providers and first aid room (if required) is such that first aid can be administered to an injured employee in a timely manner.

Referenced legislation

4(2) Subject to subsection (3), where the place of employment is a project site, the contractor shall provide and maintain the first aid kits, first aid providers and first aid rooms in accordance with the standards established in subsection 7(0.1) and with Schedule A for all persons having access to the project site, and the provisions of this Regulation that apply to an employer apply to a contractor at every project site for which the contractor is responsible for the health and safety of persons having access to the project site.

"contractor" means
(a) a person who by contract undertakes all the work at a project site,
(b) an owner who undertakes all or part of the work at a project site, or
(c) an owner who by contract engages more than one person to undertake all or part of the work at a project site;

"sub-contractor" means a person who by contract undertakes part of the work at a project site.