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First aid is the provision of initial care for an illness or injury and is usually performed by a non-expert person to a sick or injured person until definitive medical treatment can be accessed. This definition, courtesy of Wikipedia, sounds simple enough.
The Occupational Safety and Health Administration (OSHA) clarifies the employer's obligations in Regulation 1910.151.(b) In the absence of an infirmary, clinic, or hospital in near proximity to the workplace which is used for treatment of all injured employees, a person or persons shall be adequately trained to render first aid. Adequate first aid supplies shall be readily available. It is the word "adequate" that should give employers pause. What is adequate when it comes to well drillers working at remote sites?
First Aid for Well Drillers
OSHA has specified that if you're not within three minutes of medical help, you should have adequate onsite resources. But the adequacy of those resources will vary according to the nature of the work being performed.
Well drilling operators experience a wide range of injuries on the job site such as being struck by a drill bit or a piece of equipment or are subjected to general cuts and scrapes when dealing with an auger. For the well driller, a standard first aid course that teaches control of bleeding and perhaps immobilization of joints and the use of splints and slings, should be sufficient. Also, as well drillers may come in contact with high power lines, providing first aid for burns and standard wound care, as well as performing CPR will also be required, and this is all part of a basic first aid course. These courses are offered by the National Safety Council, the Red Cross, and generally, local hospitals and fire department/ambulance squads. Another aspect that should be considered is exposure to nature. Sunburns, bee stings, poison ivy, or dog bites should be anticipated and prepared for.
Who Should be Trained
Who should be selected for first aid/CPR training is an important decision and one that might carry liability issues. Best practices typically call for a minimum of two persons, fully qualified in first aid procedures, to be at each drill site.
Some employers offer first aid/CPR training to all their employees, but are those employees volunteering or are they being paid to perform first aid services and being told that it is part of their job description to respond to medical emergencies to the best of their training. That distinction makes a big difference in employer liability. Most workers are fairly well protected from liability under states' Good Samaritan laws which indicate that as long as it can be shown that the first aid provider acted in good faith and performed actions to the best of their ability within the scope of their training, they are generally held immune from civil suits. Employers do not enjoy that same protection.
It's fine to offer employees first aid training as a benefit with the understanding that it is their decision if they wish to volunteer to help in an emergency situation, so long as there are other employees for whom it is required that they have this training. These designated employees must have the first aid requirement included in their job description and they must pass the training. Otherwise, the employer will be liable for not providing adequate first aid services as defined by OSHA. The question that will be asked after an incident has occurred is "Was the employer prepared for all reasonably anticipated conditions? ".
In order for an employer to determine if they are providing adequate first aid services for all reasonably anticipated conditions, they must know what the standard of care is in the well drilling industry. It is up to the business owner to know what prudent employers with the same size business, performing the same type of drilling operations have done in similar situations. This information may be gained through resources such as case studies, presentations or articles made available through trade associations like NGWA or by simply by talking to other well drilling operators. Unfortunately, the answer to that question will not be up to the employer if a civil case arises. It will be the opinion of the jury whether or not you acted responsibly.
CPR - Compression or Not
There has been a growing reluctance on the part of the general public to have mouth to mouth contact when providing rescue services. This reluctance has been shown to create significant delays and sometimes refusal, in providing first aid to strangers. As a result, CPR certification organizations recommend at a minimum that hand compressions be performed.
However, recent studies have shown that there is no increase in the rate of success of CPR, with or without rescue breathing. It has been determined that the amount of compression in the lungs with each hand stroke is adequate to force the air out of the lungs and when the ribs bounce back, an adequate supply of new air is drawn into the lungs. In addition, that fresh air is 21 percent oxygen as opposed to exhalation air that contains only about 16 percent oxygen - a minimum amount required under normal conditions. At this time, the official standards have not changed for most CPR certification organizations, but they have been meeting regularly and comparing studies and are currently drafting new certification requirements.
I believe this is a good development. Compression-only CPR will provide more effective compression and will increase the amount of voluntary aid from the public.
First Aid Kits - Only As Good as Their Functionality
First aid kits are my current pet peeve. This is typically what I find when I inspect clients' first aid kits. Dates of use have expired rendering lotions, first aid and bacterial creams and eye wash water useless and iodine and alcohol wipes have dehydrated. Kits must have a recorded inventory complete with expiration dates which must be checked monthly by a designated individual and that kit check must be recorded along with any items changed or replaced.
I also find no record of the use of first aid items. If someone takes a band aid out of the kit, there should be a record of who took it, when, and why. A small thing like a cut or abrasion is not an OSHA recordable incident, but weeks later that cut may become infected and require additional care and then it is a recordable incident.
A first aid kit should be selected based on the size of the population it will serve as well as the types of injuries likely to occur and the level of training of the first aiders. For instance, it's unwise to have a kit with a tourniquet if no employees have been trained in the appropriate use of a tourniquet.
And finally, employers should be aware that a first aid kit may contain over the counter medications such as aspirin, antacids or decongestants. If so, the employer now becomes liable if an employee ingests one of those medications and has an allergic or other adverse reaction or even a normal reaction that leads to a mishap. For instance, many decongestants cause the user to become tired and inattentive, thereby increasing the likelihood of an accident.
First aid and CPR compliance may seem complicated and fraught with the possibility of liability, but in reality, it's an easy requirement to comply with. All that may be required of most small business owners is that they provide the opportunity for designated employees to gain the necessary training and they purchase an off-the-shelf first aid kit that is routinely checked, updated and documented.
Jack Glass is the Principal Consultant for J Tyler Scientific Company and has more than 20 years of experience as an safety training and environmental health consultant. He has consulted on toxic exposures, risk management, and indoor air quality. He is the past president of the NJ Industrial Hygiene association and past chair of the American Industrial Hygiene Association Construction Committee. In addition, he has provided litigation support in several areas including mold, asbestos, indoor air quality and confined space entry.
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