On a construction site, the ability to provide immediate first aid can mean the difference between a minor incident and a life-threatening emergency. Ontario law requires employers to maintain first aid equipment, supplies, and trained personnel on every construction project. This guide covers the legal requirements, HCMI's first aid standards, and essential emergency response knowledge for all site personnel.
In This Guide
1. Legal Basis & Regulatory Framework
First aid requirements for Ontario workplaces are established under two primary pieces of legislation:
- Ontario Regulation 1101 (First Aid Requirements) under the Workplace Safety and Insurance Act (WSIA): This regulation sets out the minimum first aid equipment, supplies, and trained personnel that employers must provide based on the number of workers and the type of workplace.
- Occupational Health and Safety Act (OHSA), section 25(2)(h): Requires employers to take every precaution reasonable in the circumstances for the protection of a worker — which includes ensuring access to first aid.
- O. Reg. 213/91 (Construction Projects), section 261: Specifies that on a construction project, a first aid station must be located in a clean and accessible area.
The Workplace Safety and Insurance Board (WSIB) administers O. Reg. 1101 and sets the standards for first aid kits, training, and record-keeping. Employers who fail to meet these requirements are in contravention of the regulation and may face penalties.
Regulatory Note: O. Reg. 1101 is made under the Workplace Safety and Insurance Act, 1997 — not the OHSA. However, OHSA compliance also requires attention to first aid as part of the employer's general duty. Both statutes apply simultaneously. Non-compliance with either may result in enforcement action.
2. Designated First Aiders & Staffing Requirements
Under O. Reg. 1101, the number of trained first aid personnel required depends on the number of workers per shift:
Schedule Requirements
- 1 to 5 workers: A first aid kit (Schedule 1) is required. No specific training requirement, but at least one worker should have valid first aid training.
- 6 to 15 workers: A first aid kit (Schedule 2) and at least one worker with a valid Standard First Aid certificate are required. A first aid station is required.
- 16 to 200 workers: A first aid kit (Schedule 3), at least one worker per shift with a valid Standard First Aid certificate, and a first aid room (where practicable) are required.
- Over 200 workers: A first aid room with a registered nurse or certified first aid provider on duty during all working hours is required.
On HCMI construction projects, the typical requirement is a Schedule 2 or Schedule 3 first aid kit with at least one designated first aider per shift. HCMI exceeds the minimum — see HCMI-specific policies below.
Designated First Aider Responsibilities
If you are a designated first aider on an HCMI site, your responsibilities include:
- Maintaining a current Standard First Aid and CPR/AED Level C certificate
- Knowing the location of all first aid supplies, the AED, and the emergency eyewash station
- Providing immediate first aid to any injured or ill worker
- Completing a Treatment Record (Form 82) for every first aid treatment provided
- Ensuring the first aid kit is stocked and supplies are not expired
- Communicating with emergency medical services (EMS) when called
3. First Aid Kit Requirements
O. Reg. 1101 specifies the minimum contents for each schedule of first aid kit. HCMI sites must maintain kits that meet or exceed the applicable schedule. The following is based on Schedule 2 (6-15 workers), which is the most common configuration on HCMI sites:
- 1 copy of a first aid manual
- 1 card of emergency telephone numbers (911, Poison Control, HCMI head office)
- 24 sterile adhesive dressings (assorted sizes)
- 6 sterile gauze pads (75mm x 75mm / 3" x 3")
- 4 rolls of sterile gauze bandage (50mm and 100mm widths)
- 2 sterile surgical pads (large compress dressings)
- 6 triangular bandages
- 2 rolls of adhesive tape (25mm wide)
- 1 pair of scissors
- 1 set of safety pins (12 pins)
- Disposable gloves (multiple pairs)
- 1 pocket face mask or CPR barrier device
- 1 blanket
- Cold packs (instant cold compress)
- Treatment Record forms (WSIB Form 82)
HCMI Addition: In addition to the regulatory minimum, HCMI first aid kits include eye wash solution (minimum 1 litre), burn gel packets, a SAM splint, extra nitrile gloves, and a blood-borne pathogen cleanup kit. These additions reflect the specific hazards present on construction sites.
4. The Emergency Response Chain
When a serious injury or medical emergency occurs on an HCMI site, the following emergency response chain must be followed:
- Ensure scene safety: Before approaching the injured worker, ensure the scene is safe for you. Do not become a second casualty. Eliminate the hazard if possible (e.g., shut off power, stabilize a load) without putting yourself at risk.
- Call for help: Direct a specific person to call 911. Do not say "someone call 911" — point to an individual and say "You — call 911 now." Have them report back to confirm the call was made.
- Provide first aid: The designated first aider provides immediate care within the scope of their training. Do not exceed your training — focus on ABCs (airway, breathing, circulation), controlling severe bleeding, and preventing further injury.
- Send a guide: Direct someone to meet the ambulance at the site entrance and guide EMS to the injured worker's location. On large construction sites, this can save critical minutes.
- Notify HCMI management: The site supervisor must notify HCMI management immediately for any injury requiring medical attention.
- Secure the scene: If the injury is critical (as defined in O. Reg. 834), do not disturb the scene. The MLITSD must be notified immediately by telephone (OHSA s.51).
- Documentation: Complete the WSIB Treatment Record (Form 82) and the HCMI Workplace Incident Report. If the worker seeks medical attention, a WSIB Form 7 (Employer's Report of Injury/Disease) must be filed within 3 business days.
Critical Injury Definition
Under O. Reg. 834, a critical injury includes:
- An injury that places life in jeopardy
- An injury that produces unconsciousness
- Substantial loss of blood
- Fracture of a leg or arm (not a finger or toe)
- Amputation of a leg, arm, hand, or foot (not a finger or toe)
- Burns to a major portion of the body
- Loss of sight in an eye
Important: For a critical injury, the employer must immediately notify the MLITSD by telephone, preserve the scene, and provide a written report within 48 hours (OHSA s.51). On HCMI sites, the supervisor must also notify HCMI management immediately. Do not disturb the scene until an MLITSD inspector gives permission — unless doing so is necessary to save a life or relieve human suffering.
5. CPR & AED Overview
CPR (Cardiopulmonary Resuscitation) and AED (Automated External Defibrillator) use are core components of Standard First Aid Level C certification. While hands-on training is required for certification, the following overview reinforces key concepts:
CPR for Adults (Level C)
- Check the scene: Ensure safety. Put on gloves if available.
- Check responsiveness: Tap the person's shoulder and shout "Are you okay?" If no response, call 911 (or direct someone to call) and get the AED.
- Open the airway: Tilt the head back and lift the chin (head-tilt chin-lift).
- Check for breathing: Look, listen, and feel for no more than 10 seconds. If the person is not breathing normally (gasping is not normal breathing), begin CPR.
- Begin compressions: Place the heel of one hand on the centre of the chest (lower half of the sternum), place the other hand on top. Compress hard and fast — at least 5 cm (2 inches) deep at a rate of 100-120 compressions per minute.
- Give breaths: After 30 compressions, give 2 rescue breaths using a pocket mask or CPR barrier. Each breath should make the chest visibly rise. If you are unwilling or unable to give breaths, continue compression-only CPR.
- Continue: Repeat cycles of 30 compressions and 2 breaths until EMS arrives, the person starts breathing normally, you are too exhausted to continue, or an AED is ready to use.
AED Use
- Turn on the AED: Open the case and press the power button. The device will give voice prompts.
- Apply pads: Expose the chest. Peel the pads and place them as shown on the pads — one on the upper right chest below the collarbone, one on the lower left side below the armpit.
- Clear the person: Ensure no one is touching the person. The AED will analyze the heart rhythm.
- Deliver shock if advised: If the AED says "Shock advised," ensure everyone is clear and press the shock button.
- Resume CPR: Immediately after the shock (or if no shock is advised), resume CPR for 2 minutes. The AED will prompt you to stop for re-analysis.
Key Point: An AED cannot harm a person — it will only deliver a shock if the heart rhythm requires it. Do not hesitate to use an AED. Early defibrillation dramatically improves survival rates for sudden cardiac arrest. Every minute without defibrillation reduces the chance of survival by approximately 10%.
6. Common Construction Site Injuries & First Aid
The following are the most common injury types on construction sites and the appropriate first aid response:
Cuts and Lacerations
- Apply direct pressure with a clean dressing to control bleeding
- Elevate the injured limb if possible
- For deep cuts, puncture wounds, or cuts that won't stop bleeding, seek medical attention
- Do not remove embedded objects — stabilize them in place and seek medical attention
Fractures and Sprains
- Immobilize the injured area — do not attempt to straighten or set a fracture
- Apply a splint if trained and if doing so does not cause additional pain
- Apply ice (cold pack) wrapped in cloth to reduce swelling
- Seek medical attention for all suspected fractures
Burns
- Cool the burn with cool (not cold) running water for at least 10 minutes
- Do not apply ice, butter, toothpaste, or any home remedy
- Cover with a sterile, non-adhesive dressing
- For chemical burns, flush with water for at least 20 minutes and refer to the SDS
- Seek medical attention for burns larger than the person's palm, burns on the face, hands, feet, genitals, or joints, and all third-degree burns
Heat-Related Illness
- Heat exhaustion: Move the person to a cool, shaded area. Loosen clothing. Apply cool, wet cloths. Give small sips of water if conscious and not nauseous. Seek medical attention if symptoms do not improve within 15-20 minutes.
- Heat stroke: This is a medical emergency — call 911 immediately. Move the person to a cool area. Cool rapidly by any means available (cold water, wet sheets, fanning). Do not give fluids. Monitor breathing and be prepared to perform CPR.
Eye Injuries
- For foreign particles: flush with clean water or saline using the eyewash station for at least 15 minutes
- For chemical splashes: flush continuously for at least 20 minutes. Remove contact lenses if present.
- For embedded objects: do not remove. Cover both eyes to prevent movement and seek immediate medical attention.
7. Certification & Renewal
Standard First Aid and CPR/AED Level C certification requirements:
- Training provider: Certification must be obtained from a WSIB-approved training provider (e.g., Canadian Red Cross, St. John Ambulance, Heart and Stroke Foundation, or other approved providers)
- Course duration: Standard First Aid with CPR/AED Level C is typically a 16-hour (two-day) course
- Certification validity: Valid for 3 years from the date of completion
- Renewal: A recertification course (typically 8 hours) must be completed before the certificate expires. If the certificate has expired, a full course must be taken again.
- CPR Level C: Covers adult, child, and infant CPR, plus AED use — this is the level required by HCMI
Regulatory Note: O. Reg. 1101 specifies that the first aid certificate must be valid and issued by a training agency recognized by the WSIB. An expired certificate does not meet the regulatory requirement. HCMI tracks certification expiry dates and will notify designated first aiders 90 days before expiry to arrange recertification.
8. HCMI First Aid Station Requirements
HCMI maintains the following standards for first aid on all project sites, which in several areas exceed the regulatory minimum:
- Minimum first aiders: At least two workers per shift on every HCMI project must hold valid Standard First Aid and CPR/AED Level C certification. This exceeds the O. Reg. 1101 minimum to ensure coverage during breaks, when workers are in different areas, or if one first aider is off site.
- AED on site: An Automated External Defibrillator must be available on every HCMI project site where workers are regularly employed. The AED must be in a clearly marked, accessible location known to all workers.
- First aid station location: The first aid station must be in a clean, heated (in winter), and accessible area — typically in the site trailer. The location must be clearly marked with a green cross sign visible from the main work areas.
- Eyewash station: A plumbed or portable eyewash station must be available wherever workers may be exposed to chemicals, dust, or debris. Portable stations must be checked weekly and replaced per manufacturer's instructions.
- First aid kit inspection: The designated first aider must inspect the first aid kit at least weekly and restock used or expired supplies immediately. A kit inspection log must be maintained.
- Emergency contact board: Every HCMI site trailer must display a clearly visible emergency contact board listing: 911, the nearest hospital name and address, Poison Control (1-800-268-9017), HCMI head office (519-509-6363), the site supervisor's phone number, and the names of designated first aiders on site.
- Treatment records: All first aid treatments must be documented on the WSIB Treatment Record (Form 82). These records must be retained for the duration of the project plus one year.
- Training cost: HCMI covers the full cost of Standard First Aid and CPR/AED Level C certification and recertification for all designated first aiders.
9. First Aid Readiness Checklist
Confirm the following for your HCMI project site:
- At least two workers per shift hold valid Standard First Aid and CPR/AED Level C certificates
- Copies of first aid certificates are on file in the site trailer
- The first aid kit meets or exceeds the applicable O. Reg. 1101 schedule and is fully stocked
- The first aid station is in a clean, accessible, clearly marked location
- An AED is on site, charged, and in a marked, accessible location
- An eyewash station is available where chemical or dust exposure may occur
- The emergency contact board is posted and current
- All workers know the location of the first aid station, AED, and eyewash station
- All workers know who the designated first aiders are on their shift
- The emergency response chain (scene safety, call 911, first aid, guide EMS, notify management) is understood by all workers
- WSIB Treatment Record forms (Form 82) are available at the first aid station
- The first aid kit inspection log is up to date
- The site-specific emergency plan includes directions to the nearest hospital and is posted in the site trailer
HCMI Policy: First aid certification records are maintained by the HCMI Safety Department. If your certification is approaching expiry, contact office@churchbuilder.ca to arrange recertification. Remember — an expired certificate means you cannot serve as a designated first aider, and the site may fall out of regulatory compliance.
