Many businesses inherit their first-aid arrangements: a green box appears on the wall, one employee has an old certificate and nobody can explain why that provision is adequate. UK law does not give every employer the same ratio or shopping list. It requires an arrangement that is adequate and appropriate for the circumstances. A first-aid needs assessment is how the employer reaches and records that decision.
The legal duty is an outcome—not a fixed number
Regulation 3 of the Health and Safety (First-Aid) Regulations 1981 requires employers to provide adequate and appropriate equipment, facilities and personnel so employees can receive first aid if they are injured or become ill at work. Regulation 4 requires employees to be informed of the arrangements. The duty applies to workplaces of every size; it does not begin only when a business reaches five employees.
HSE does not prescribe one universal ratio of first-aiders to employees. A ten-person engineering workshop may need more capable cover than a larger low-hazard office. The employer must assess the workplace, workforce, hazards and practical response needed, then maintain suitable cover whenever people are at work.
Related guide: five signs risk assessments are not reaching the workplace →
Start with how the business really operates
Do not begin by choosing a course. Map the work first. Consider normal operations, cleaning and maintenance, early starts, late finishes, weekend work, travel and temporary changes. Review accident history, near misses and credible events even if they have not happened yet.
The assessment should cover the following decision points:
- Work activities, hazards and the likely severity of harm.
- Workforce size, distribution and people who may need particular consideration.
- Shift patterns, overtime, annual leave, sickness and training absences.
- Separate buildings, floors, yards, vehicles and remote locations.
- Travelling, lone, home and hybrid workers.
- Distance from emergency medical services and access for responders.
- Shared premises, contractors, visitors, customers and members of the public.
- The equipment, facilities, communication and trained people needed for foreseeable incidents.
Appointed person, EFAW or FAW: decide from the risk
Every employer needs somebody to take charge of first-aid arrangements. An appointed person looks after equipment and facilities and calls the emergency services. They do not need formal training, but they are not a trained first-aider and should not provide treatment beyond their competence.
Where the assessment identifies a need for trained first-aiders, the employer must decide what competence is required. Emergency First Aid at Work may suit some lower-hazard settings. First Aid at Work provides broader training that may be appropriate where hazards, likely injuries or workplace circumstances demand it. Additional training may be needed for risks such as life-threatening bleeding or where a specific workforce requires a different response.
HSE no longer approves first-aid training providers. The employer must check that the selected provider is competent and that the training meets the needs identified.
Coverage must survive the rota
A certificate held by somebody who works Monday to Thursday does not cover Friday. Test the proposed arrangements against shifts, breaks, leave, sickness, off-site work and the time needed to reach an incident. Large or split sites may need trained people in more than one area even where the total headcount looks modest.
For example, a Stockton office and an adjoining workshop should not automatically share one first-aider because they sit under the same company name. Machinery, vehicle work, noise, access between areas and the likely injuries may justify different competence, equipment and response times. The assessment should explain the decision rather than rely on an informal expectation that somebody will be available.
Test your first-aid arrangements against every shift and work area.
HR + SAFETY can complete or review the needs assessment, identify coverage gaps and give you a proportionate schedule for trained personnel, equipment and facilities.
Discuss a first-aid needs assessmentChoose equipment and facilities after assessing the need
The contents and location of first-aid kits should follow the assessment. HSE provides a suggested minimum list for low-risk work, but employers must add or adjust provision where their risks require it. BS 8599 can be a useful purchasing benchmark; compliance with that standard is not itself a legal requirement and does not prove the kit is suitable for the workplace.
Consider whether kits must be portable, held in vehicles or protected from contamination. Decide who checks stock and expiry dates and how used items are replaced.
Also consider whether a first-aid room or automated external defibrillator is appropriate. An AED is not a universal statutory purchase, but HSE says employers should consider one when assessing their needs. If provided, it must be accessible and maintained.
Include physical and mental health response
HSE’s current L74 guidance emphasises that employers should consider employees’ mental health within the first-aid needs assessment. This does not mean every business has to appoint a ‘mental health first aider’, and that role does not replace risk assessment, competent management or access to professional help.
Decide what managers and staff should do when somebody becomes acutely distressed, discloses a concern or appears to be in immediate danger. Provide clear escalation routes, emergency contacts and suitable training. Keep that response connected to wider arrangements for work-related stress, welfare, absence and occupational health.
Do not forget people away from the main site
A remote worker may need a personal kit, a reliable way to call for help and enough location information for responders. Low-hazard home work may need little beyond domestic provision, while mobile engineering or long-distance driving may require specific arrangements.
The Regulations focus on employees, but HSE strongly recommends including customers, visitors and children in the assessment. On shared premises, decide in writing who provides what. Do not assume another occupier has accepted responsibility.
Record the reasoning and set review triggers
HSE says the findings do not have to be written down, but a concise record is the clearest way to show how the provision was decided and keep it consistent. Record the hazards considered, operating hours, coverage calculation, required competence, equipment, facilities, information arrangements and any action still outstanding.
Review it after an accident, significant change to work, staffing or premises, new hazards, altered shifts, repeated gaps in cover or a failed response. Set a routine review date and act before training expires.
Eight checks for an SME manager
If the answer depends on one reliable employee always being present, the arrangement is fragile. Build cover around the operation, not around one person.
- Can we explain the hazards and workforce factors used to decide our provision?
- Is suitable cover available during every shift and foreseeable absence?
- Can trained personnel reach each work area quickly enough?
- Do training levels match the injuries and illnesses we may face?
- Are kits, facilities and any AED accessible, checked and maintained?
- Do remote workers have workable arrangements?
- Do employees know who to contact and where equipment is kept?
- Is there a named owner and a clear date or trigger for review?
First-aid needs assessment support across the North East
HR + SAFETY helps SMEs across Teesside, Stockton-on-Tees, Middlesbrough, Darlington, County Durham, Sunderland, Newcastle and the wider North East assess first-aid needs against their actual hazards, staffing and working patterns.
The output is a practical schedule of required cover, competence, equipment, facilities, employee information and review actions. It gives the employer a sound basis for selecting training and buying equipment without treating either purchase as the assessment itself.
Assess the workplace before buying the course or kit. Decide the people, competence, equipment, facilities and coverage your real operating pattern needs, record the reasoning and review it before changes or absences leave employees without an effective response.
This guide provides general information for UK employers. It is not legal advice and should not replace advice based on the facts of a specific matter.