THE COHEN GROUP
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The Cohen Group Newsletter - Volume 6  Issue 2, Article 3.  April, 2004

 First Aid Kits - Over-the-Counter Medications

Tim Bormann, CIH

While over-the-counter medications are commonly provided in first-aid kits, there are some guidelines that should be closely followed.  Over-the-counter medications typically include analgesics, medications approved by the Federal Drug Administration (FDA) as pain reliever/fever reducers for over-the-counter use, and to a lesser extent, cold/sinus tablets.

  The regulations regarding first-aid kits for general industry can be found in 8 CCR §3400. According to Cal/OSHA general industry safety order (Title 8 California Code of Regulations, Section 3400), there must be “adequate first-aid materials, approved by the consulting physician, readily available…”   In the Cal/OSHA construction standard [§1512(c)(3)], it states: “Drugs, antiseptics, eye irrigation, solutions, inhalants, medicines or propriety preparations shall not be included in the first aid unless specifically approved, in writing by an employer authorized, licensed physician.” Therefore, before over-the-counter medication may be provided in your first-aid kits, it must be approved by a physician.

The American National Standard has developed Z-308.1-2003 (Minimum Requirements for Workplace First Aid Kits), which updates and expands ANSI Z308.1-1998, to provide guidance for minimum performance levels of first-aid kits for all types of uses and situations in the work environment.

Kits in compliance with this standard will provide a basic range of products to deal with most types of injuries encountered in the workplace.  The assortment of required contents was developed based on treatment for the following potential injuries:   major wounds, minor wounds (cuts and abrasions), minor burns and eye injuries.  The list of recommended contents has been expanded to include analgesics, burn dressings, and CPR barriers.  This standard also takes into account all types of packaging of first aid products, along with containers for use in indoor and outdoor, mobile and stationary settings.

ANSI recommends that oral analgesics included in a first aid kit be "packaged in a single dose, tamper evident, package with full labeling as required by FDA regulations and should contain no ingredients which are known to cause drowsiness".  The ANSI standard, however, makes no specific mention regarding over-the-counter cold/allergy remedies.

Though most first-aid equipment suppliers claim the risks of liability to employers are minimal, the obvious concerns are the potential for medical complications, adverse reactions, overdosing, adverse interaction with other medication, etc.  If you are providing over-the-counter medications here are a few things to consider:

·         As required by Cal/OSHA regulations, get physician approval for the types and amounts of over-the-counter medications that will be provided.  In addition, the medication should be in single dose, tamper evident packages as recommended by ANSI.

·         Purchase over-the-counter medications through a reputable first aid supplier.

·         Consider controlling your site's dispensing of medications only on direct request by the employee and limiting the dispensing to the recommended dosage only.  Record the dispensing in a first aid log.

·         Develop a written policy on the use and abuse of over-the-counter medications and communicate that policy to employees.  The caution and warning statements on the medication packages should also be communicated.

·         Monitor expiration dates and discard those medications that reach the expiration date.

·         Place no more than one pack of analgesic in any first aid kit.