Do employers need to review first aid provision in light of the Covid-19 outbreak?

Written by Anna Bishop
Oct 23, 2020

Anna is a Training Product Manager at Red Cross Training responsible for the development and review of our training products.

COVID-19 has impacted most workplaces significantly - from an increase in people working from home to reduced staff and changes in building layouts. In the midst of the operational chaos of the UK’s initial lockdown phase, reviewing your first aid provision needs may have been lower down the agenda. 

Despite this, your legal obligations under The Health and Safety (First-Aid) Regulations 1981 to provide an “adequate and appropriate” level of first aid for employees has never changed. However, your circumstances and what is reasonably practicable to achieve are likely to have altered significantly.

The HSE recommended that businesses consider reviewing their first aid needs assessment when carrying out their COVID-secure risk assessment. So if you’ve not already done so, we look at why it’s so important and what you need to consider.


Why do employers need to review first aid provisions in light of Covid-19?

The pandemic has significantly altered the way businesses operate for many. Overnight, 45% of people worked exclusively from home in the first month of lockdown, compared with just 5.6% before. With restrictions once again tightening,  homeworking where possible looks set to continue for the foreseeable future. 

Office-based workplaces that have reopened may  now be operating with COVID-secure staggered shift patterns and one-way systems, while other industries have had to significantly alter how they carry out their work.. 

Meanwhile, sadly, 1.2 million staff have now been furloughed and others have been made redundant - meaning your workplace may have fewer staff resulting in, increased workload for those remaining. 

However, with all this change, it is important to remember that health and safety risks should still be reviewed regularly. The HSE’s L74 guidance on The Health and Safety (First Aid) Regulations 1981 (“the HSE’s Guidance”) states that you should periodically review your needs, particularly after any changes to operations (s.30). 

If ever there was a time when so many businesses were going through such significant operational change, it’s now. 


What changes may impact our first aid provision?

When conducting your first aid needs assessment, section 3.10 of the HSE’s Guidance has a useful checklist outlining the key things to consider when completing your first aid needs assessment.. The operational changes following the pandemic mean that you may have to pay particular attention to the following issues:


  • More remote and lone workers
    Generally, the HSE considers that those working deskbound remotely are a low-risk. However, they do recommend that you issue lone or remote workers with a personal first aid kit and a mobile (if required) so that they can contact someone in the event of an emergency. You also need to consider whether they require additional training (s.21 of the HSE’s Guidance).

It’s arguable that you may even have to consider additional equipment or cover if they are particularly vulnerable or now very remote from emergency services. 


  • Less staff and fewer people in the office 
    If you’ve made redundancies, had to furlough staff, or you have less people in the workplace due to homeworking, then the number of first aiders you require may have reduced. 


  • Workers spread out further in the office
    You’re required to consider how quickly first aiders can respond to a person in need. Social distancing is likely to mean that your employees are spread out more. Just because your workforce size may have reduced, it doesn’t mean the number of first aid personnel you need has.


  • Activities may be harder to complete

If you operate in a high-risk industry such as manufacturing, construction and engineering, any process adaptations made to reduce COVID-19 transmission may mean that there are new hazards or a greater risk from existing ones.

See: What is a high-hazard business in first aid at work legislation?


  • First aiders may not be available 

First aid cover should be available at all times and take account of alternative working arrangements (s.3.5 of the HSE’s Guidance). You may even have  first-aiders that are absent due to shielding, self-isolation or staggered shifts. 

You may also find that whilst available and competent, some first aiders may be reluctant or unwilling to act as a first aider as they are worried about the risks of contracting the virus. 

It’s best to talk to your staff to address any concerns they may have and direct them to resources that may help, such as: 6 ways to protect yourself when performing first aid during Covid-19.


  • Sharing first aiders with other organisations

You may now be sharing sites with other employers due to operational or budget constraints. Section 25 of the HSE’s Guidance requires that employers exchange information about hazards and risks with each other. One employer may be able to take full responsibility for first aid but it’s strongly recommended that any agreements are in writing to prevent misunderstandings. Sharing first aid cover with other organisations is one of the measures the HSE has recommended to meet your obligations (which we cover below). 

  • First aid training delays

First aid training providers had to close during the UK-wide lockdown. Even though many have now reopened, the backlog of courses and social distancing measures could mean that first aiders’ certifications have/will lapse.

All of these issues may impact the outcome of your first aid needs assessment, such as the number of first aiders and training required, how many first aid kits you need and if you need specialist equipment. 


How can employers ensure adequate first aid provisions during Covid-19?

COVID-19  means that what level of first aid provision is “so far as reasonably practicable to achieve” has changed for many employers. There are still ways to ensure you comply with your legal duties, though, such as:

  • Reducing first aider cover if your current circumstances mean that there are fewer people coming to the workplace
  • Stopping higher-risk activities 
  • Sharing first aid cover with another business
  • If first aid certificates have expired, ensuring you have taken/take every effort to arrange requalification training as soon as possible.  If you have relied on an extension, ensure you can explain in detail why it was not possible previously.

For more advice on this, see: How can you help ensure first aid cover when your colleagues return to work?


As the lockdown continues and the government has recommended that employees work from home where possible again, it’s essential that you review the level of first aid cover you have and whether it’s adequate for your circumstances. With those circumstances constantly changing, remember to revisit your needs again regularly.

If you need to refresh your knowledge of your first aid legal obligations, then why not download our eBook: The Complete Guide to First Aid at Work:

guide to first aid at work

Topics: First Aid

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