Are Changes To Your First Aid at Work Policy Now Required?

health and safety documents in ring binder on shelf related to first aid

Following recent changes to the HSE’s online first aid guidance regarding mental health first aiders, now might be the right time to consider updating your first aid at work policy. If you don’t have a policy the information provided should give a steer as to what to include.

First Aid Legal Requirements

Under the Health and Safety (First-Aid) Regulations 1981(HSFR) employers are required to assess the needs for first aid in their business and provide personnel, facilities and equipment accordingly. The HSFR are supported by an official guide: The Health and Safety (First-Aid) Regulations 1981, Guidance on Regulation. In 2018 this was updated to include information on the use of Automated External Defibrillators (AEDs) and the contribution of “blended learning” in first-aid training.

The HSE has also changed its online first aid guidance to add information on “mental health first aid”.

These updates should at least trigger a review of your First Aid at Work Policy and where required you should make the necessary amendments.

Policy Document

The policy should begin with a statement explaining who is covered by your first aid arrangements, to what level and when. You may wish to include an acknowledgement that first aiders may treat visitors and passers-by as part of their role. This ensures that such activities are regarded as part of their job, removing any scope for concern that treating non-employees creates a personal liability for the first aider.

The legal basis for providing first aid should be outlined, making it very clear what the law requires.  A key requirement is to ensure that an assessment of first aid needs is completed.

A list of some of the factors to be considered in the employer’s assessment of first aid needs are listed below:

  • size of the business
  • type of business
  • building layout
  • past history of accidents
  • proximity of business location to emergency medical services
  • needs of travelling and/or lone workers
  • first aid cover in times of sickness or annual leave

Once this assessment is complete it’s recommended that you include details of where the document is held and who is responsible for keeping it up to date.


If should be clear in the policy the responsibilities of first aiders especially if you have a mix of Emergency First Aid at Work and First Aid at Work first aiders.  See our article  covering the difference.  However, some key responsibilities are listed below:

  • providing treatment promptly when requested
  • obtaining further assistance if needed
  • only carrying out treatment for which they have been trained, i.e. knowing their limitations
  • staying with and monitoring the casualty as long as required
  • making reports of treatment provided and completing accident reports
  • carrying out a monthly check of first aid kits; and
  • keeping up to date with developments in first aid.

If you have no need for first aiders (as per your assessment of first aid needs) the minimum requirement is to appoint a person to look after your first aid arrangements (“appointed person”).  Include their responsibilities.  Essentially, this role involves taking charge in an emergency and calling an ambulance where necessary. They might also look after first aid equipment.

Mental Health First Aid Arrangements

Following changes to the HSE’s online first aid guidance, you should consider including details on mental health first aid.   Training courses for mental health first aiders is becoming more popular because of the prevalence of this type of ill health in the workplace.

If you decide to provide mental health first aiders in the workplace, it is important that the wording in the policy is chosen carefully.  The principle is that the provision of mental health first aiders is not compulsory.

The provision of mental health first aiders must be based on the outcome of completing an assessment of your first aid needs and based on that you have determined that it’s necessary to appoint personnel as  mental health first aiders for the wellbeing of those on site.

You may also choose to indicate in the policy that the role of mental health first aiders involves identifying the symptoms of mental ill health and providing support to those suffering from it.

Action in an emergency

General procedures to be followed by staff in the event of a medical emergency should be included in your policy.  Consideration should be given to the following:

  • emphasise that untrained staff should not attempt to give first aid treatment;
  • cover practical details such as whether an ambulance should be called, the use of taxis to transport those with minor injuries, using first aid kits and equipment for mobile workers;
  • Provide details of how to deal with ill health or injury to visitors and passers-by.

As we’ve already described, it’s a good idea to include this type of information in your policy.  It makes it clear that these first-aid activities are part of your “undertaking” and therefore if treatment is given it should automatically fall within the terms of your public liability policy.


Specify how first aiders will be trained and who will be responsible for organising the courses. Although you can choose bespoke courses, the majority of organisations stick with the standard options:

  • Emergency First Aid at Work – generally delivered as a one-day course with continuous assessment; and
  • First Aid at Work – usually run over three days with an end of course assessment.

To accommodate the potential for mental health first aiders in your business, you should include details of the number of personnel trained in this type of emergency response. You should also describe any additional training given to first aiders such as for the treatment of electric shock or the use of AEDs.

You’ll also need to describe how training is arranged for your first aid personnel. You should outline how re-qualification courses are organised and how you will encourage first aiders to keep their knowledge up to date.

And finally

Indicate how first aid arrangements will be publicised around the workplace. Suggested means of communicating first aid details include:

  • writing the information in a staff handbook
  • signs and notices
  • training during staff induction.

Amendments to HSE guidance cover automated external defibrillators, the use of e-learning as part of your first aid training, and mental health first aiders. These are all optional, but if any of these topics are relevant to your business, use our revised template to bring your policy up to date.

Help & Support

We have assisted many organisations to put together various health and safety policy documentation.  If you require our help to create a first aid at work policy or any other aspect of  health and safety do get in touch.  We offer a free 15-minute consultation without any obligation.  If you prefer you can call on 07875 53 5558.

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