Cal/OSHA First Aid Updates: ANSI Class A Kits Before 2027

California employers who keep first-aid kits for construction or general industry should plan a kit and program refresh. The Occupational Safety and Health Standards Board (OSHSB) listed revisions to Title 8 § 1512 (Construction Safety Orders) and § 3400 (General Industry Safety Orders) for adoption consideration on its September 17, 2026 agenda. Secondary reporting (CalChamber HRWatchdog, Sep 24, 2026) says the Board approved the package that day, with an expected effective date of January 1, 2027 pending Office of Administrative Law (OAL) review. As of Sep 29, 2026, the official OSHSB First Aid rulemaking status table still leaves "Filed with Secretary of State" and "Effective date" blank. Treat January 1, 2027 as a reported target, not as filed final law, until OAL and the Secretary of State filing are reflected on the Board page.

This post summarizes what the Board's 15-day Modified Text would change, who should care, and what to do now. It is not legal advice. Read the modified text, your sector's orders, and any final filed rule before you change practice.

What changed

Substance below comes from the official 15-day Modified Text for First Aid 2025 (Construction § 1512 and General Industry § 3400), retrieved Sep 29, 2026.

1. Kit contents: ANSI Class A Table 1 or a PLHCP

Employers may stock first-aid kits that meet Table 1, which conforms to ANSI/ISEA Z308.1-2021 Class A minimums, or have contents determined by an employer-authorized physician or other licensed health care professional (PLHCP, as defined in § 5144). The old employee-count table of kit lists is removed and replaced with that ANSI Class A Table 1 path.

Table 1 minimums include (among others): adhesive bandages (16), adhesive tape, antibiotic application, antiseptic, breathing barrier, burn dressing and burn treatment, cold pack, eye covering, eye/skin wash, first-aid guide, foil blanket, hand sanitizer, medical exam gloves (2 pair), roller bandage, scissors, sterile pads, trauma pads, and a triangular bandage. Footnotes in the Modified Text spell out ANSI quality details for breathing barriers, cold packs, scissors, and the first-aid guide.

2. General industry: consulting-physician kit approval is no longer the default path

Under the Modified Text for § 3400, the prior model that centered consulting-physician approval of kit materials as the default is replaced by the same dual path: ANSI Class A Table 1 or PLHCP-determined contents. Ready access, kit count, location communication, and hazard-driven extras still apply.

3. Enough kits, based on people, places, and hazards

For both construction and general industry, the employer must evaluate the need for a sufficient number of kits based on size, employee location(s), and the types and severity of occupational hazards. Kits must be readily available for employee use. Construction still requires at least one kit in a weatherproof container for covered project, line-crew, and short-duration or transient work.

4. Tell people where the kits are

The location of each first-aid kit must be communicated to employees and, to the extent practicable, clearly indicated with signage, labeling, or other means so it is reasonably visible on the jobsite or in the workplace.

5. Specialized supplies when hazards call for them

Where a hazard assessment or the employer-authorized PLHCP identifies unique, reasonably anticipated, and potentially serious workplace hazards, the employer must provide additional specialized first-aid items suitable for those hazards.

6. Chemical-injury materials trigger HazCom training

If first-aid materials for treating chemical injuries are included in kits, the Modified Text points to § 5194(h)(2)(E) training on emergency procedures.

7. Construction operations that stay in the picture

Multi-employer site rules for emergency medical services and appropriately trained persons remain. Kit inspection language is updated (check contents when a kit is put into service and inspect regularly so expended items are replaced). Construction written EMS plan duties and related structure remain part of § 1512.

8. First-aid guide vs. first-aid person training

Kits under Table 1 include a first-aid guide whose topics follow Appendix A (aligned with ANSI/ISEA Z308.1-2021 Appendix A), or topics determined by the PLHCP. Employers are not required to train employees on the contents of that guide. Separate first-aid person / trained-person requirements in § 1512(b) and § 3400(b) still govern training of people who render first aid.

Who cares

Direct

California employers covered by Construction Safety Orders § 1512 and General Industry Safety Orders § 3400. That is a wide set: GCs and trades on CA jobsites, manufacturers, warehouses, shops, and most SMB employers who maintain workplace first-aid kits under Title 8.

Practical audience

• EHS and safety leads who own kits, EMS plans, and IIPP references.
• Site supers and facility managers who place, mark, and restock kits.
• HR and operations leads updating emergency procedures and HazCom emergency training when chemical first-aid items are stocked.
• Multi-employer construction hosts who coordinate EMS / trained-person pools.

Indirect

Out-of-state employers with California sites or CA subcontractors. Federal OSHA first-aid rules are not rewritten by this package. Watch your own state only if you track California as a model.

What to do (now through OAL / expected early 2027)

1. Watch the official OSHSB First Aid page for "Filed with Secretary of State" and "Effective date." Do not treat January 1, 2027 as locked until those fields (or equivalent OAL/SOS notice) fill in.
2. Inventory kits against Table 1 / ANSI Class A, or document a PLHCP determination if you will use that path instead.
3. Walk kit count and placement. Map employee locations and hazard types. Add kits where ready access is weak (large floors, remote yards, multi-building campuses, mobile crews).
4. Communicate and mark locations. Update orientation, site maps, and toolbox talks. Add signage or labels where practicable.
5. Run a simple hazard check for specialized supplies (chemical exposure, trauma, heat-related illness, or other reasonably anticipated serious hazards). Stock extras only where the assessment or PLHCP supports them.
6. If you stock chemical-injury treatments in kits, align SDS, emergency procedures, and § 5194(h)(2)(E) training with what is actually in the box.
7. Construction: keep weatherproof containers, confirm put-into-service and regular inspections, and refresh multi-employer EMS / trained-person arrangements and the written plan as needed.
8. Update IIPP / emergency action references once the filed effective date is confirmed, so program documents match the kit standard you chose.

Also watch

Federal OSHA HazCom 2024 employer compliance for substances remains due November 20, 2026 (91 FR 1695). Separate from this Cal/OSHA first-aid package. Use it as a calendar reminder for workplace labels, program, and training updates where substances still need work.

Closing

These revisions move California first-aid kits from older employee-count lists and a physician-approval-first general-industry habit toward a clearer ANSI Class A or PLHCP contents rule, plus real duties on how many kits, where they sit, and what extras your hazards need. Board adoption was listed for September 17, 2026. Secondary sources report approval and an expected January 1, 2027 effective date pending OAL. Official SOS filing and effective-date fields were still blank on Sep 29, 2026. Prep the kits and placement work now. Treat "adopted" and the January 1, 2027 date as locked only after official Board minutes and OAL/SOS filing catch up.

Safety-Chat / Provisio EHS will update when the Board page shows filing and an effective date. Until then, work from the Modified Text and verify against the live OSHSB hub.

Sources

All claims above were checked against these sources on Sep 29, 2026 (America/Denver):

1. OSHSB First Aid 2025 rulemaking hub: status table (public hearing Jan 15, 2026; 45-day and 15-day periods listed; "Filed with Secretary of State" and "Effective date" blank as of retrieval); links to Modified Text and related documents.
   https://www.dir.ca.gov/oshsb/First-Aid-2025.html
   Retrieved: Sep 29, 2026 ~8:37 AM MDT (America/Denver)

2. OSHSB 15-day Modified Text PDF: proposed amendments to Title 8 § 1512 and § 3400: Table 1 / ANSI/ISEA Z308.1-2021 Class A or PLHCP contents; drop of old employee-count kit table; kit-count and ready-availability evaluation; location communication and practicable signage/labeling; specialized items via hazard assessment or PLHCP; chemical-injury materials → § 5194(h)(2)(E); construction weatherproof container and inspection updates; multi-employer EMS / trained-person framework; Appendix A first-aid guide topics; employers not required to train on guide contents.
   https://www.dir.ca.gov/oshsb/documents/First-Aid-2025-15-Day-Modified-Text.pdf
   Retrieved: Sep 29, 2026 ~8:38 AM MDT (America/Denver)

3. OSHSB September 17, 2026 meeting agenda: Proposed Safety Orders for Adoption item: Construction Safety Orders § 1512 and General Industry Safety Orders § 3400 First Aid (briefing, public comment, Board discussion). Agenda lists adoption consideration; it is not itself a vote record.
   https://www.dir.ca.gov/oshsb/documents/agendaSep2026.pdf
   Retrieved: Sep 29, 2026 ~8:38 AM MDT (America/Denver)

4. CalChamber HRWatchdog (secondary): reports Board approval of first-aid updates and expected effective date January 1, 2027 pending OAL. Used only for vote-outcome reporting and expected-effective phrasing; substance of rule changes rests on source 2.
   https://hrwatchdog.calchamber.com/2026/09/cal-osha-approves-significant-changes-to-employers-first-aid-requirements/
   Retrieved: Sep 29, 2026 ~8:37 AM MDT (America/Denver)

5. Also-watch only: Federal Register, Jan 15, 2026, 91 FR 1695: HazCom employer substances compliance date November 20, 2026.
   https://www.federalregister.gov/documents/2026/01/15/2026-00653/hazard-communication-standard
   Retrieved: Sep 29, 2026 ~8:33 AM MDT (America/Denver) (scout re-check)