The short answer

Under General Safety Regulation 3:

• where more than five employees are employed at a workplace, the employer must provide an accessible first-aid box or boxes;
• where more than 10 employees are employed, at least one person with a valid certificate of competency in first aid must be readily available during normal working hours for every group of up to 50 employees at a general workplace, or for every group of up to 100 employees in a shop or office.

The certificate must be issued by an organisation approved by the Chief Inspector. Regulation 3(4) was amended on 5 December 2025 to remove the previous list of named organisations and replace it with that approval requirement.

Examples:

• 1–5 employees: no automatic Regulation 3(2) box threshold, although the general duty to ensure prompt first aid still applies;
• 6–10 employees: first-aid box required, but the numerical Regulation 3(4) trained-first-aider threshold has not yet been crossed;
• 11–50 employees in a general workplace: at least one qualifying first aider readily available;
• 51–100 employees in a general workplace: at least two;
• 11–100 employees in a qualifying shop or office: at least one;
• 101–200 employees in a shop or office: at least two.

These are minimum statutory ratios, not a complete emergency-response design.

Shift patterns, site layout, travel time, leave, remote work areas, chemical risks and operational hazards may mean that more trained people are necessary to achieve the underlying requirement of prompt first aid treatment.

First-aid boxes: what the regulation actually requires

A first-aid box must be available and accessible where more than five employees are employed.

The employer must take account of:

• the types of injury likely to occur;
• the nature of workplace activities;
• the number of employees.

The box must contain suitable equipment and at least the minimum items listed in the General Safety Regulations Annexure.

The Annexure currently lists:

1. wound cleaner/antiseptic, 100 ml;
2. swabs for cleaning wounds;
3. cotton wool for padding, 100 g;
4. sterile gauze, minimum quantity 10;
5. one pair of forceps for splinters;
6. one pair of scissors, minimum size 100 mm;
7. one set of safety pins;
8. four triangular bandages;
9. four 75 mm × 5 m roller bandages;
10. four 100 mm × 5 m roller bandages;
11. one 25 mm × 3 m roll of elastic adhesive;
12. one 25 mm × 3 m non-allergenic adhesive strip;
13. one packet of adhesive dressing strips, minimum 10 assorted sizes;
14. four 75 mm × 100 mm first-aid dressings;
15. four 150 mm × 200 mm first-aid dressings;
16. two straight splints;
17. two pairs large and two pairs medium disposable gloves;
18. two CPR mouthpieces or similar devices.

For shops and offices, the Annexure allows the specified quantities of certain listed items to be reduced by half.

The statutory list is a minimum, not a risk assessment.

A workplace handling corrosives, hazardous chemicals or other special hazards may require additional emergency facilities. Regulation 3 specifically addresses, among other things, eyewash facilities where there is an eye-injury risk from biological or chemical substances and fast-reacting deluge showers where sudden skin exposure to large quantities of toxic, corrosive, high-risk or similar hazardous substances is possible.

First aider training and appointment

Regulation 3(4) requires the person to hold a valid certificate of competency in first aid issued by an organisation approved by the Chief Inspector.

Do not rely only on a training company’s marketing statement that it is “accredited”. Confirm that the certification route meets the current occupational-health-and-safety requirement.

Also note an important legal distinction: Regulation 3(4) does not itself say that every certificate is automatically valid for exactly three years.

The legal requirement is that the person holds a valid certificate. Employers should therefore verify the expiry or currency requirements applicable to the certificate and training route actually used rather than placing a blanket “three years” statement into every legal register.

Similarly, Regulation 3 does not expressly prescribe a particular statutory appointment-letter format for first aiders.

A written appointment remains sensible governance because it records:

• the person’s role;
• area or shift of responsibility;
• certificate details;
• responsibility for the first-aid station;
• replacement arrangements.

But the employer should not confuse the appointment letter with the competence requirement.

Where high-risk, toxic, corrosive or similar hazardous substances are handled, Regulation 3(5) goes further: the relevant first aider must be trained in first-aid and emergency procedures appropriate to injuries and acute effects that may arise from those substances.

Means of escape and evacuation

General Safety Regulation 13J, inserted in March 2025, deals directly with fire evacuation.

Among other things, employers must ensure suitable exit arrangements and keep escape doors, passages and stairs capable of allowing quick evacuation.

Having regard to the workplace’s size, construction, location, occupancy and activities, the workplace must be provided with at least two means of egress situated as far apart as practicable.

This matters because fire compliance is not a paperwork exercise.

A workplace with locked exits, obstructed escape routes or no workable evacuation arrangements has a serious emergency-control failure, whatever else is in the safety file.

How many fire fighters or fire marshals are legally required?

Unlike Regulation 3’s first-aider formula, the General Safety Regulations do not contain a universal national “one fire fighter per X employees” ratio for ordinary workplaces.

The number of trained emergency personnel should be determined from the workplace emergency and fire-risk arrangements, including:

• size and layout;
• number and distribution of occupants;
• shift pattern;
• fire loading;
• higher-risk processes;
• evacuation complexity;
• disabled or vulnerable occupants;
• assembly and accountability arrangements;
• coverage during leave and absence;
• local-authority requirements;
• client or site-specific requirements.

Where the applicable municipal fire-safety regime, approved emergency plan or client specification requires particular trained fire-safety roles, those requirements must also be followed.

A written appointment and defined emergency role are good control measures, but they should reflect the real emergency structure rather than create a title with no operational function.

Worked example: small warehouse

Assume a warehouse has 35 employees working on the same shift.

For first aid:

• the workplace exceeds five employees, so suitable first-aid boxes must be accessible;
• it exceeds 10 employees;
• it is not relying on the shop/office ratio;
• at least one qualifying first aider must therefore be readily available during normal working hours.

However, if the first aider works only in an upstairs office while employees work across a large yard and warehouse, or if the person is frequently away from site, the employer should reassess whether that provides prompt first aid in practice.

If corrosive chemicals are handled, the emergency-facility and first-aider-training requirements may also change.

For fire protection, “35 employees” does not tell us how many trained fire personnel are required.

We would need to consider the building, storage arrangement, fire load, ignition sources, occupancy and fire design.

Worked example: small office

Assume an office has 18 employees.

The workplace requires a first-aid box because it exceeds five employees.

It also exceeds 10 employees and falls within the shop/office category, so at least one person with the required valid first-aid certificate must be readily available during normal working hours.

That person must actually be available. If the designated person works remotely three days a week, the certificate in the file does not provide the required coverage.

Emergency staffing must again be assessed from the premises and applicable fire requirements — not from the employee count alone.

Frequently asked questions

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AuthorJean DuvenageManaging Director Reviewed byArthur PaddockSenior Safety Consultant