First Aid at Work in Ontario — What the Regulation Actually Requires

Ontario Regulation 1101 under the Workplace Safety and Insurance Act is the single source of truth for first aid kit contents, trained personnel counts, and the first aid room threshold. It scales everything off one number: workers per shift. OHSA section 25(2)(h) makes it the employer's legal duty to take every reasonable precaution for worker safety — and a first aid program is the baseline that every other safety measure builds on. Get this wrong and a MOL inspector writes an order before they even look at the rest of the site.

The scaling table — 1-5, 6-15, 16-199, 200+ and what changes at each tier

Regulation 1101 uses four tiers, each keyed to the maximum number of workers on any single shift. At 1 to 5 workers, the requirement is a basic Kit #1 and one worker trained in Emergency First Aid (EFA, an 8-hour course). Kit #1 covers the essentials: adhesive dressings, gauze bandages in two widths, adhesive tape, scissors, triangular bandages, pressure dressings, a splint set, abdominal pads, surgical gloves, and a resuscitation pocket mask with a one-way valve. It is enough to manage a cut, stabilize a fracture, and keep a casualty breathing until paramedics arrive — assuming the hospital is close. At 6 to 15 workers, the kit upgrades to Kit #2 (expanded quantities plus a blanket, stretcher access, and additional gloves) and the training standard jumps from EFA to Standard First Aid (SFA, 16 hours) plus CPR-C. The CPR-C upgrade matters because it covers child and infant CPR on top of adult — relevant in any workplace that employees' families might visit, and mandatory for the SFA certificate. At 16 to 199 workers, Kit #3 adds an eyewash station, even larger supply quantities, cold compresses, and a second stretcher. The trained-aider count stays at one per shift, but the training must be SFA + CPR-C. The real jump hits at 200 workers on a single shift: Kit #3, one SFA + CPR-C trained worker per 100 workers per shift, and a dedicated first aid room with specific equipment. That room is not optional — it must have a cot, blanket, sink with hot and cold running water, Kit #3, stretcher, treatment record book, posted certificates, posted emergency numbers, adequate lighting and ventilation, and a lockable door for patient privacy. If your headcount floats near 200, track it carefully — the day you cross the threshold, the room requirement activates.

EFA vs SFA vs CPR-C — what each covers, how long, what it costs

Emergency First Aid (EFA) is the entry-level course: 8 hours, typically one full day. It covers CPR-A (adult resuscitation only), choking management, control of severe bleeding, shock recognition and treatment, and unconscious casualty management. The certificate is valid for 3 years from a WSIB-approved provider. Cost runs $80 to $120 per person depending on the provider and location. Standard First Aid (SFA) doubles the course to 16 hours — usually delivered across two days. It covers everything in EFA plus CPR-C (adult, child, and infant resuscitation), AED use, bone and joint injuries (splinting, slings), burns and scalds, poisoning and substance exposure, chest injuries, head and spinal injuries, eye injuries, and medical emergencies like diabetic crises, seizures, allergic reactions, and asthma attacks. Cost runs $130 to $180 per person. CPR-C is not a separate course — it is built into SFA. The C level means the rescuer can perform CPR on an adult, a child, and an infant, and can use an AED. CPR-A (adult only) is the level included in EFA. For any workplace with 6 or more workers per shift, SFA + CPR-C is the floor. For workplaces more than 30 minutes from a hospital, upgrade to SFA + CPR-C regardless of headcount — an EFA-trained aider managing a spinal injury for 45 minutes until the ambulance arrives is not the position you want to be in. The WSIB-approved providers are St. John Ambulance, Canadian Red Cross, Heart and Stroke Foundation, and the Lifesaving Society. Other providers can qualify if they are WSIB-recognized — check before booking, because a certificate from an unrecognized provider does not satisfy the regulation.

The first aid room at 200+ — what goes in it, where to put it

Once you hit 200 workers on a single shift, Regulation 1101 requires a dedicated first aid room. This is not a storage closet with a kit on the shelf — it is a purpose-built treatment space. The room must contain a cot or bed (not an air mattress on the floor), a blanket and pillow, a sink with both hot and cold running water (not a water jug — plumbed), a fully stocked Kit #3, a stretcher, a treatment record book, posted emergency phone numbers, and posted first aid certificates. It must have adequate lighting and ventilation, a lockable door for patient privacy, and clear signage identifying it as the first aid room. It cannot double as a break room, storage room, or office during working hours. Location matters: it should be as close to the main work area as practicable, on the same level as the majority of workers if possible, and accessible by stretcher — meaning the path from the work floor to the room must be wide enough and free of obstructions for two people carrying a stretcher. On a construction site this often means a trailer dedicated to first aid, positioned near the main entrance so EMS can find it quickly. On an industrial floor it means a walled-off room adjacent to the production area, not tucked behind the shipping dock. Budget $2,000 to $5,000 for a compliant setup including the cot, plumbing (if not already in place), supplies, and signage.

Remote workplaces — why more than 30 minutes to hospital changes the game

Regulation 1101 sets the baseline by headcount, but the regulation assumes reasonable proximity to a hospital. When the workplace is more than 30 minutes from the nearest hospital or medical clinic — forestry operations, mining sites, pipeline construction, rural utility work, remote construction camps — the practical reality overrides the minimum. An EFA-trained worker managing a compound fracture or a cardiac event for 45 minutes to an hour before an ambulance arrives is operating well beyond the scope of their 8-hour course. The standard practice for remote workplaces is to upgrade everyone to SFA + CPR-C regardless of worker count, add supplementary equipment beyond the Regulation 1101 kit (tourniquet, hemostatic gauze, spine board, AED, emergency blankets, burn sheets), and establish an emergency communication plan that includes satellite phone or radio contact with dispatch, a landing zone for helicopter evacuation if terrain permits, and a written casualty evacuation procedure that every worker has been briefed on. O. Reg. 213/91 (Construction Projects) adds specific first aid requirements for construction-specific hazards — section 261 requires at least one worker with valid first aid certification on the project at all times, regardless of crew size. Remote and high-hazard sites should treat Regulation 1101 as the floor, not the ceiling.

Kit inspection — the quarterly minimum and why kits expire

Regulation 1101 requires first aid kits to be inspected at least quarterly and contents replenished as they are used. In practice, monthly inspections are the standard on active job sites and in industrial settings where kit contents get used or damaged regularly. The inspection is not complicated — open the kit, check every item against the contents list, verify nothing is expired, verify the container is intact and clean. Adhesive tape dries out. Gauze packaging can degrade. Latex and nitrile gloves crack after prolonged heat or cold exposure. Resuscitation masks with one-way valves have expiry dates stamped on the packaging — an expired valve may not seal. Eyewash solution in Kit #3 typically has a shelf life of 2 to 3 years. If you find anything expired, damaged, or missing, replace it before closing the kit. Keep an inspection log — date, inspector name, items replaced — in the kit or posted beside it. During a MOL inspection, the inspector will open the kit, and an empty or expired kit is one of the easiest orders to write. The cost of keeping a kit current is trivial: $20 to $50 per quarter for consumables. The cost of a kit that is empty when someone needs it is not.

Common failures — expired training, empty kits, and missing postings

The three most common Regulation 1101 violations that MOL inspectors write are expired training certificates, depleted or expired kit contents, and failure to post required information. Training certificates expire after 3 years. If your only trained first aider's certificate lapses and someone gets hurt, the employer is non-compliant with both Regulation 1101 and OHSA s. 25(2)(h). Track expiry dates in a calendar and book recertification at least two months before expiry — course availability fills up fast, especially in smaller communities. The second failure is the kit itself: band-aids used up and not replaced, gloves that cracked from sitting in a hot truck, eyewash past its expiry date, resuscitation mask missing entirely. Assign someone to own the quarterly inspection and make it a standing calendar item. The third failure is posting. The regulation requires all valid first aid certificates to be posted where workers can see them, along with emergency phone numbers (ambulance, fire, police, poison control) and the name, address, and phone number of the nearest hospital or medical clinic. On a construction site, these go in the site trailer or on the safety board at the main entrance. In an office or industrial setting, they go in the break room or near the kit. If the hospital changes (new facility, old one closes, route changes), update the posting immediately. A worker having a medical emergency should not be searching a phone for the closest ER — that information should be on the wall, in large print, visible from across the room. All of this costs almost nothing to maintain. The cost of not maintaining it — an MOL order, a WSIB surcharge, or a worker who does not get the care they need — is orders of magnitude higher.