OSHA Resources

This OSHA Resources page provides general, non-exhaustive information and primary government sources concerning workplace first-aid and cardiopulmonary resuscitation (CPR) training. [1] NCPRF provides online training and certification but does not determine the requirements for every employer, worksite, industry, jurisdiction, or intended use. Employers and users should identify and follow every requirement applicable to their circumstances.

Is There a Universal Federal OSHA Requirement for Hands-On or Practical CPR and First-Aid Training?

No. Federal OSHA has no overarching CPR statute or regulation that applies to all employment situations, and its regulations do not impose a universal hands-on or practical training requirement for CPR and first aid. The applicable standard controls. OSHA states that its requirements are “set by statute, standards, and regulations” and that interpretation letters “cannot create additional employer obligations.” [6] Consistent with that framework, the April 28, 2010, enforcement memorandum issued by David Michaels, Ph.D., M.P.H., Assistant Secretary for Occupational Safety and Health, to OSHA’s Regional Administrators provides the general meaning of training: “regardless of the precise regulatory language,” “train” and “instruct” mean to “present information in a manner that employees receiving it are capable of understanding.” [2] Comprehension therefore provides the general baseline for “training” and “instruction,” while the applicable standard may separately prescribe particular content, skills, methods, or other requirements. Among the mandatory federal OSHA CPR and first-aid provisions surveyed below, logging is the only provision that expressly requires practical exercise and both written and practical examinations. [21-22] Accordingly, where another applicable provision does not prescribe a hands-on or practical component, that method is not an express requirement of the provision. [2, 6]

See OSHA’s 2010 Enforcement Policy here: (https://www.osha.gov/laws-regs/standardinterpretations/2010-04-28)

The 2010 OSHA Training Standards Policy Statement

On April 28, 2010, David Michaels, issued the OSHA Training Standards Policy Statement to OSHA’s Regional Administrators—not to an outside requester. The memorandum states OSHA policy and provides “enforcement guidance” to its area and regional offices across agriculture, construction, general industry, and maritime. Its importance here is direct: it tells OSHA’s enforcement leadership what the agency means by its general training terminology and how compliance officers are to enforce individual training standards. [2]

OSHA begins by recognizing the different formulations in its standards. Some require “training” or “instruction”; others require “adequate” or “effective” training or instruction; still others expressly require an “understandable” manner or language. OSHA then gives all of those formulations a common starting point: [2]

“Regardless of the precise regulatory language,” “train” and “instruct” mean to “present information in a manner that employees receiving it are capable of understanding.” [2]

The word regardless is decisive to the framework. OSHA does not assign one baseline meaning to “training,” another to “instruction,” and an unstated practical method to “adequate” or “effective” training. “Adequate” and “effective” concern whether the instruction is sufficient and works for the employees, purpose, and conditions involved; neither word, by itself, says “classroom,” “online,” “demonstration,” “practical exercise,” or “examination.” The underlying act of training remains the understandable presentation of information.

OSHA then separately identifies standards that add requirements involving knowledge, skills, retraining, use, or interaction and tells employers to examine the standards applicable to their workplaces. Compliance officers are likewise directed to apply the language and purpose of the specific standard to the facts of the particular workplace. [2]

The structure is therefore clear: general training terminology provides a comprehension-based baseline, while the applicable standard may prescribe further requirements, including those concerning content, skill, method, or verification. OSHA may examine whether employees understood the instruction and could apply it to their workplace conditions. The word “train,” standing alone, does not prescribe a practical method; the governing provision must be examined for any further requirements, including those concerning method, skill, or verification or some other addition. CPR may involve physical performance, but that fact alone is not regulatory language prescribing how a CPR course must be delivered or tested. [2]

Later Official Applications Reinforce the 2010 Framework

  • In the 2015 Confined Spaces in Construction final rule, OSHA cited the 2010 memorandum, said employers must “ensure that the employee comprehends the training,” and described the policy as “applicable to all training requirements in all OSHA standards.” OSHA added express language-and-vocabulary wording to that rule “for clarity.” [3]

  • In the 2016 Walking-Working Surfaces and Personal Protective Equipment final rule, OSHA called the fall-protection training requirements “performance based,” stated that the provision “does not require or prohibit a specific format,” and said it “supports the use of different formats,” including “online, interactive computer-based, web-based” training. That rule does not govern CPR or first-aid training; it illustrates OSHA’s distinction between performance language and regulatory text specifying a format. [4]

  • OSHA’s 2024 inspection guidance for animal-slaughtering and processing establishments cites the 2010 memorandum and directs compliance officers to review training efforts “with emphasis on training effectiveness and worker understandability.” [5]

Standards, Interpretations, and Recommendations

OSHA states: “OSHA requirements are set by statute, standards and regulations.” Interpretation letters explain how existing requirements apply to particular circumstances, but they “cannot create additional employer obligations” and therefore cannot independently establish requirements beyond those imposed by the applicable statute, standard, or regulation. [6] OSHA further explains that interpretation letters provide supplementary guidance for applying existing policies or procedures to specific workplace situations and may not “establish or expand OSHA policy.” [26] OSHA also cautions that federal interpretations may not apply to OSHA-approved State Plans, which may impose different or additional requirements. [6]

OSHA’s Best Practices Guide: Fundamentals of a Workplace First-Aid Program says it is “not a standard or regulation,” “creates no new legal obligations,” and is “advisory in nature.” It introduces its teaching recommendations as “Program elements to be considered.” [7] OSHA’s current First Aid Programs webpage states: “OSHA recommends that CPR training include having trainees develop ‘hands-on’ skills” through mannequins and partner practice. A recommendation may inform program design; it is not regulatory text mandating that method for every CPR or first-aid provision. [8]

What the Federal Standards Say

The question here is narrow: whether the cited CPR or first-aid clause itself prescribes a practical training method or practical examination. Every express certification, equivalency, content, availability, or workplace requirement remains controlling.

Selected General First-Aid Provisions

  • General industry—29 C.F.R. § 1910.151(b). The provision speaks to sufficiency and objective: when its proximity condition applies, a person or persons must be “adequately trained to render first aid.” The text does not identify a delivery or testing method and does not mention CPR, demonstration, practical exercise, or examination. [9]

  • Construction—29 C.F.R. § 1926.50(c). The rule requires an available person with “a valid certificate in first-aid,” when the specified medical resource is not reasonably accessible. It does not mention CPR or prescribe a practical training or testing method. [10]

  • Telecommunications—29 C.F.R. § 1910.268(c). Where training is required, the rule says it “shall consist of on-the-job training or classroom-type training or a combination of both.” It does not require a practical exercise or practical examination for that instruction. [11]

Provisions Expressly Addressing CPR

The provisions below require specified CPR or first-aid training, certification, or availability. Unless stated otherwise, the cited clauses do not prescribe a practical exercise or practical examination.

  • Permit spaces—29 C.F.R. §§ 1910.146(k)(2)(iii) and 1926.1211(b)(3). Section 1910.146 requires employers to “[t]rain affected employees in basic first-aid and cardiopulmonary resuscitation (CPR)”. [12] Section 1926.1211 imposes parallel training and certification requirements. [20]

  • Electric-power work—29 C.F.R. § 1910.269(b)(1) and (x), and §§ 1926.951(b) and 1926.968. Section 1910.269(b)(1) states that, for specified energized work, “persons with first-aid training shall be available.” [13] Its definition includes “cardiopulmonary resuscitation” within first-aid training. [14] The construction rule likewise requires “persons with first-aid training.” [18] Its definition also includes “cardiopulmonary resuscitation” within first-aid training. [19] None of these provisions prescribes a practical exercise or practical examination.

  • Commercial diving—29 C.F.R. § 1910.410(a)(3). The rule states that “[a]ll dive team members shall be trained in cardiopulmonary resuscitation and first aid.” [15] The text does not itself prescribe a delivery method or practical examination.

  • Shipyards—29 C.F.R. §§ 1915.12(e)(1) and 1915.87(c)(4)-(5). Section 1915.87 requires first-aid providers to be “trained to render first aid, including cardiopulmonary resuscitation (CPR).” [17] None of these provisions prescribes a practical exercise or practical examination.

Logging Expressly Prescribes Practical Methods and Content

Logging uses materially different text. Section 1910.266(i)(7) requires covered employees to receive “first-aid and CPR training” meeting mandatory Appendix B. [21] Appendix B expressly requires “lecture, demonstration, practical exercise and examination (both written and practical).” [22]

That direct wording shows how OSHA states, “practical exercise” and practical “examination” when it places them in an operative first-aid and CPR rule, which the other regulations above omit.

General First-Aid Benchmarks

OSHA identifies “the fundamentals of first aid” and places assessment of workplace needs on the employer. MSHA’s general first-aid regulations for surface and underground metal and nonmetal mines require current training and specified first-aid capabilities but prescribe no training method.

  • First-aid fundamentals and employer determination. OSHA recognizes “any nationally accepted and medically sound first aid program that covers the fundamentals of first aid” as meeting § 1910.151. [23] It is “the responsibility of the employer to make an assessment of the workplace and determine all first aid needs,” and the employer “must satisfy him/herself that the course adequately covers” the injuries and illnesses likely to be encountered. [24]
  • MSHA metal and nonmetal mines—30 C.F.R. §§ 56.18010 and 57.18010. MSHA’s general first-aid regulations require an individual to be “currently trained and have the skills to perform” specified first-aid functions and state: “First aid training shall be made available to all interested miners.” The regulations prescribe no training method and do not mention hands-on training, practical exercise, or practical examination. [25]

Apply the Specific Standard

OSHA’s sources direct the inquiry to the applicable standard. The April 28, 2010, Assistant Secretary memorandum states that, “regardless of the precise regulatory language,” “train” and “instruct” mean presenting information “in a manner that employees receiving it are capable of understanding.” It directs compliance officers to determine whether training meets “the requirements and intent of the specific standard,” considering the standard’s language and the facts and circumstances of the particular workplace. [2]

OSHA states that its requirements are “set by statute, standards, and regulations.” [6] Its Best Practices Guide recommends “[h]aving trainees develop ‘hands-on’ skills through the use of mannequins and partner practice” as one of the “program elements to be considered,” not as a requirement applicable to every workplace. [7] Its current First Aid Programs webpage states: “OSHA recommends that CPR training include having trainees develop ‘hands-on’ skills through the use of mannequins and partner practice.” [8] Accordingly, each applicable standard must be followed as written.

This page addresses only what the cited federal OSHA provisions themselves require. OSHA has stated that it is “the responsibility of the employer to make an assessment of the workplace and determine all first aid needs” and that an employer using a first-aid or CPR course “must satisfy him/herself that the course adequately covers” the types of injuries and illnesses likely to be encountered. [24] Depending on the particular job, worksite, license, or intended use, an employer or worksite policy, a licensing or credentialing body, or another responsible organization may require something further, such as additional instruction, a hands-on or practical skills-check, or a particular certification. Any such “different or additional requirements” must be evaluated separately and does not alter what the cited federal OSHA provisions themselves expressly require. [6]

Among the mandatory federal OSHA CPR and first-aid provisions surveyed, “Logging operations” [21] Appendix B is the only provision that expressly requires “practical exercise and examination (both written and practical).” [22]

Sources

[1] Occupational Safety and Health Administration, Medical and First Aid—Standards. (https://www.osha.gov/medical-first-aid/standards)

[2] Occupational Safety and Health Administration, OSHA Training Standards Policy Statement, memorandum from David Michaels, Ph.D., M.P.H., Assistant Secretary, to Regional Administrators (Apr. 28, 2010). (https://www.osha.gov/laws-regs/standardinterpretations/2010-04-28)

[3] Occupational Safety and Health Administration, Confined Spaces in Construction; Final Rule, 80 Fed. Reg. 25366, 25437 (May 4, 2015). (https://www.osha.gov/laws-regs/federalregister/2015-05-04)

[4] Occupational Safety and Health Administration, Walking-Working Surfaces and Personal Protective Equipment (Fall Protection Systems); Final Rule, 81 Fed. Reg. 82494, 82638-43 (Nov. 18, 2016). (https://www.osha.gov/laws-regs/federalregister/2016-11-18)

[5] Occupational Safety and Health Administration, Inspection Guidance for Animal Slaughtering and Processing Establishments (Oct. 15, 2024). (https://www.osha.gov/laws-regs/standardinterpretations/2024-10-15)

[6] Occupational Safety and Health Administration, Letters of Interpretation. (https://www.osha.gov/laws-regs/interpretations)

[7] Occupational Safety and Health Administration, Best Practices Guide: Fundamentals of a Workplace First-Aid Program, OSHA 3317-06N (2006), especially pp. 1 and 11. (https://www.osha.gov/sites/default/files/publications/OSHA3317FIRST-AID.pdf)

[8] Occupational Safety and Health Administration, Medical and First Aid—First Aid Programs. (https://www.osha.gov/medical-first-aid/programs)

[9] Occupational Safety and Health Administration, 29 C.F.R. § 1910.151—Medical services and first aid, paragraph (b). (https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.151)

[10] Occupational Safety and Health Administration, 29 C.F.R. § 1926.50—Medical services and first aid, paragraph (c). (https://www.osha.gov/laws-regs/regulations/standardnumber/1926/1926.50)

[11] Occupational Safety and Health Administration, 29 C.F.R. § 1910.268—Telecommunications, paragraph (c). (https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.268)

[12] Occupational Safety and Health Administration, 29 C.F.R. § 1910.146—Permit-required confined spaces, paragraphs (k)(2)(iii)-(iv). (https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.146)

[13] Occupational Safety and Health Administration, 29 C.F.R. § 1910.269—Electric power generation, transmission, and distribution, paragraph (b)(1). (https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.269)

[14] Occupational Safety and Health Administration, 29 C.F.R. § 1910.269—Electric power generation, transmission, and distribution, paragraph (x), definition of “first-aid training.”(https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.269_2)

[15] Occupational Safety and Health Administration, 29 C.F.R. § 1910.410—Qualifications of dive team, paragraph (a)(3). (https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.410)

[16] Occupational Safety and Health Administration, 29 C.F.R. § 1915.12—Precautions and the order of testing before entering confined and enclosed spaces and other dangerous atmospheres, paragraph (e)(1). (https://www.osha.gov/laws-regs/regulations/standardnumber/1915/1915.12)

[17] Occupational Safety and Health Administration, 29 C.F.R. § 1915.87—Medical services and first aid, paragraphs (c)(4)-(5). (https://www.osha.gov/laws-regs/regulations/standardnumber/1915/1915.87)

[18] Occupational Safety and Health Administration, 29 C.F.R. § 1926.951—Medical services and first aid, paragraph (b). (https://www.osha.gov/laws-regs/regulations/standardnumber/1926/1926.951)

[19] Occupational Safety and Health Administration, 29 C.F.R. § 1926.968—Definitions, definition of “first-aid training.”(https://www.osha.gov/laws-regs/regulations/standardnumber/1926/1926.968)

[20] Occupational Safety and Health Administration, 29 C.F.R. § 1926.1211—Rescue and emergency services, paragraphs (b)(3)-(4). (https://www.osha.gov/laws-regs/regulations/standardnumber/1926/1926.1211)

[21] Occupational Safety and Health Administration, 29 C.F.R. § 1910.266—Logging operations, paragraph (i)(7). (https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.266)

[22] Occupational Safety and Health Administration, Mandatory Appendix B to 29 C.F.R. § 1910.266—First-aid and CPR Training. (https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.266AppB)

[23] Occupational Safety and Health Administration, The Review of First Aid Training Programs (Jan. 6, 1995). (https://www.osha.gov/laws-regs/standardinterpretations/1995-01-06)

[24] Occupational Safety and Health Administration, Training Material for First Aid and CPR Training (Aug. 4, 1994). (https://www.osha.gov/laws-regs/standardinterpretations/1994-08-04-0)

[25] Mine Safety and Health Administration, First Aid—30 C.F.R. §§ 56.18010 and 57.18010. (https://arlweb.msha.gov/stats/top20viols/tips/18010.htm)

[26] Occupational Safety and Health Administration, OSHA Letters of Interpretation and Directives System and Functions (Feb. 20, 2002). (https://www.osha.gov/laws-regs/standardinterpretations/2002-02-20)

Last reviewed: September 3, 2026