First aid provision is a fundamental WHS obligation for every PCBU in Australia. The Code of Practice for First Aid in the Workplace establishes the requirements for first aid equipment, trained personnel, and facilities that must be provided at every workplace. From 1 July 2026, Section 26A of the WHS Act makes compliance with this code legally binding. The code's requirements scale with the size of the workforce, the nature of the work hazards, and the remoteness of the workplace from emergency medical services. While first aid obligations may seem straightforward compared to other WHS requirements, non-compliance is one of the most common findings in workplace inspections and exposes the PCBU to enforcement action for a readily preventable deficiency.
The full title is the Code of Practice: First Aid in the Workplace, published by Safe Work Australia. The code becomes legally binding from 1 July 2026 under Section 26A of the WHS Act. The code applies to all workplaces and all PCBUs regardless of industry, size, or risk level. It covers the assessment of first aid requirements based on workplace hazards, the number and distribution of first aid kits and their minimum contents, the number and qualifications of first aid trained personnel, the provision of first aid facilities including first aid rooms for larger workplaces, communication and signage requirements for first aid, and the documentation and review of first aid arrangements. The code references the guidelines of the Australian Resuscitation Council and the relevant Australian Standards for first aid kits.
The code applies to every PCBU in every industry. Construction sites, manufacturing facilities, offices, retail premises, educational institutions, healthcare facilities, agricultural properties, and mining operations all have first aid obligations. The code's requirements scale with the risk profile — a construction site with high-risk activities and multiple hazard types requires more extensive first aid provision than a small office. Remote workplaces far from emergency medical services require enhanced first aid capability because response times for ambulance services may be significantly longer. The code also applies to PCBUs who manage shared workplaces such as shopping centres and office buildings, who must coordinate first aid provision among multiple occupant PCBUs. Mobile workers and workers who travel between workplaces must have access to first aid appropriate to their work activities.
The code requires PCBUs to conduct a first aid needs assessment considering the nature of the work and the workplace hazards, the size and layout of the workplace, the number and distribution of workers, the nature of the injuries and illnesses likely to occur, and the distance of the workplace from emergency medical services. First aid kits must be provided in sufficient numbers and locations to ensure that all workers have reasonable access. Kit contents must be appropriate for the workplace hazards — a basic office kit has different requirements from a construction site kit or a chemical manufacturing kit. The code specifies minimum contents for general purpose first aid kits. First aiders must hold current nationally recognised first aid qualifications and must be available during all work periods. The number of first aiders must be proportionate to the workforce size and the risk level. Workplaces with more than 200 workers or with high-risk activities should consider providing a dedicated first aid room. First aid facilities must be clearly signed and accessible.
First, conduct a first aid needs assessment for each workplace considering the hazard profile, workforce size, workplace layout, and distance from emergency medical services, and document the assessment outcomes including the number and type of first aid kits required, the number of trained first aiders needed, and whether a first aid room is required. Second, audit all first aid kits for contents, condition, and accessibility, replacing expired or damaged items and ensuring kit contents match the hazard profile identified in the needs assessment. Third, verify that sufficient workers hold current first aid qualifications and that qualifications are renewed before expiry, maintaining a register of qualified first aiders with their qualification dates and expiry dates. Fourth, review first aid signage and communication, ensuring that first aid kit locations, first aid room location, and first aider names are clearly displayed and that emergency procedures include first aid response steps. Fifth, establish a documented first aid kit inspection schedule with defined frequencies for checking contents, replacing expired items, and restocking after use.
Failure to provide adequate first aid can worsen the outcome of workplace injuries and illnesses, converting treatable conditions into serious or fatal outcomes. After 1 July 2026, failure to follow the code constitutes a standalone offence. Improvement notices are commonly issued for inadequate first aid provision during routine inspections, including expired first aid kit contents, insufficient numbers of trained first aiders, and missing first aid signage. Category 3 penalties of up to $346,300 for a body corporate apply for duty failures even where no person was actually harmed. Where inadequate first aid provision contributes to the severity of a worker's injury, the failure becomes an aggravating factor in any prosecution for the underlying incident. The cost of compliant first aid provision is modest compared to the potential penalties and the moral obligation to provide immediate treatment to injured workers.
EHS Atlas manages first aid kit inspection schedules, first aider qualification registers, and needs assessment documentation in a single audit-ready platform.
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