First aid needs assessment: what it decides and how many first aiders you need

A first aid needs assessment decides what "adequate and appropriate" first aid means for your workplace, which is the test in regulation 3 of the Health and Safety (First-Aid) Regulations 1981. It settles whether an appointed person and a stocked kit are enough, or whether you need trained first aiders, how many, and at which level. HSE publishes suggested numbers, and there is no fixed legal ratio.

The Regulations apply in England, Wales and Scotland, including to workplaces with fewer than five employees. Northern Ireland has a separate set of first aid regulations.

What do the first aid regulations require?

The Health and Safety (First-Aid) Regulations 1981 put the employer's duties in regulations 3 and 4:

Provision	What it requires
Regulation 3(1) of the First-Aid Regulations 1981	Equipment and facilities that are adequate and appropriate in the circumstances for giving first aid to your employees if they are injured or become ill at work
Regulation 3(2) of the First-Aid Regulations 1981	Suitable people to give first aid, in a number that is "adequate and appropriate in the circumstances", each with "such training and ... such qualifications as may be appropriate in the circumstances"
Regulation 3(3) of the First-Aid Regulations 1981	When a first aider is absent "in temporary and exceptional circumstances", appointing a person to take charge is enough for the period of the absence
Regulation 3(4) of the First-Aid Regulations 1981	Where the nature of the undertaking, the number of employees at work and the location of the establishment make it "adequate and appropriate", an appointed person in place of a first aider
Regulation 4 of the First-Aid Regulations 1981	Telling employees the arrangements, including where the equipment, facilities and people are

The duty covers illness as well as injury, and HSE's guidance applies it whatever the cause, so a heart attack at a desk is within scope. To meet regulation 4 of the First-Aid Regulations 1981, the same guidance suggests a notice in a prominent position at each site and first aid information at induction.

Regulation 3(2) of the First-Aid Regulations 1981 used to require training and qualifications approved by HSE. An amendment in force from 1 October 2013 replaced that with the "appropriate in the circumstances" test. Since then HSE no longer approves workplace first aid training, qualifications or training organisations, so checking that a provider is competent is your job.

The Regulations cover your employees only. HSE strongly recommends including customers, visitors and pupils in your assessment as well, and a builders merchant's trade counter or a garden centre brings the public onto your site.

Regulation 5 of the First-Aid Regulations 1981 gives self-employed people within its scope, broadly those whose work could put others at risk, a duty to provide such first aid equipment, if any, as is adequate and appropriate in the circumstances for their own use at work.

How do you carry out a first aid needs assessment?

Start from your risk assessment. Regulation 3 of the Management of Health and Safety at Work Regulations 1999 already requires a suitable and sufficient assessment of the risks. HSE's guidance on the First-Aid Regulations, L74, says to use those findings to identify the likely injuries, which then decide the type, quantity and location of the equipment, facilities and people you provide.

HSE's list of what to consider:

• the nature of the work and its hazards, including any that need special arrangements
• the size of the workforce and who is in it, such as young workers or people with known health conditions
• shift patterns and out-of-hours work
• holidays and other absences of your first aiders and appointed persons
• your history of accidents and ill health
• travelling, remote and lone workers, and how far your sites are from emergency medical services
• shared or multi-occupied sites, and members of the public

Where one site mixes different work, L74 gives the example of production and office areas: assess each separately and carry the results into the first aid assessment. Several buildings or floors may each need their own provision. On a shared site, one employer can take responsibility for first aid for everyone, and HSE strongly recommends a written agreement.

You do not have to write the assessment down. L74 points out that a written record lets you show a safety representative or an HSE or local authority inspector how you decided on your provision, which is reason enough to keep one. Review it periodically, and after any change in how you operate.

What should be in a first aid kit at work?

There is no mandatory list. The contents follow your assessment, and for low-hazard work L74 suggests a minimum of:

• a leaflet with general first aid guidance
• 20 individually wrapped sterile plasters of assorted sizes
• two sterile eye pads
• two individually wrapped triangular bandages, preferably sterile
• six safety pins
• two large and six medium sterile, individually wrapped, unmedicated wound dressings
• at least three pairs of disposable gloves

British Standard BS 8599-1 sets out kit contents in more detail. HSE's guidance says buying a kit that meets it is not a requirement of the Regulations, and whichever kit you buy, its contents should match the findings of your assessment. Provide at least one kit for each work site, mark it with a white cross on a green background, keep tablets and medicines out of it, and restock it soon after use. Staff who travel for work may need a personal kit.

How many first aiders do you need?

HSE says there are no hard and fast rules, and publishes suggested numbers in Appendix 3 of L74 for the first aid personnel to have available at all times people are at work. They are suggestions, and the legal test stays "adequate and appropriate":

Hazard level, with HSE's examples	Employees	HSE's suggested minimum
Low hazard, such as offices, shops and libraries	Fewer than 25	At least one appointed person
Low hazard	25 to 50	At least one first aider trained in emergency first aid at work (EFAW)
Low hazard	More than 50	At least one first aider trained in first aid at work (FAW) for every 100 employed, or part of 100
Higher hazard, such as light engineering and assembly, food processing, warehousing, extensive work with dangerous machinery or sharp instruments, construction and chemical manufacture	Fewer than 5	At least one appointed person
Higher hazard	5 to 50	At least one EFAW or FAW first aider, depending on the type of injuries that may occur
Higher hazard	More than 50	At least one FAW first aider for every 50 employed, or part of 50

Two things push the number up from there. The table counts who is available whenever people are working, so a site running an early and a late shift needs cover on each. And an appointed person can stand in for an absent first aider only in the temporary and exceptional circumstances that regulation 3(3) of the First-Aid Regulations 1981 describes. HSE's guidance says annual leave does not count, so holidays need trained cover.

Take a 40-person warehousing business working two shifts. HSE lists warehousing as higher hazard, so the suggestion is at least one EFAW or FAW first aider on each shift, plus enough trained people to cover holidays and other planned absences, and a plan for sickness absence. The likely injuries decide the level, and fractures and chest injuries are FAW syllabus topics.

At the other end, a 12-person office can reasonably finish its assessment at an appointed person and a stocked kit. HSE suggests considering a trained first aider even there, because an accident or sudden illness remains possible.

Which first aid training does your needs assessment point to?

Role	Minimum course length in HSE's guidance	What they can deal with	Our course
Appointed person	No formal training required	Takes charge: looks after the kit and facilities and calls the emergency services. HSE says they should not attempt first aid they are not trained for	An EFAW course makes them a first aider
EFAW first aider	Six hours over one day	An unconscious casualty, seizures, CPR and use of a defibrillator, choking, wounds and bleeding, shock and minor injuries	Emergency First Aid at Work, one day, for lower-risk workplaces
FAW first aider	18 hours over at least three days	Everything in EFAW, plus injuries to bones, muscles and joints, chest injuries, burns and scalds, eye injuries, poisoning, anaphylaxis, and recognising major illness such as heart attack, stroke, epilepsy, asthma and diabetes	First Aid at Work, three days, for higher-risk workplaces

EFAW and FAW certificates are valid for three years. L74 says a first aider whose certificate has expired is no longer considered competent to act as one, so book the requalification before the expiry date. HSE strongly recommends an annual refresher in between, though it is optional.

Some hazards need more than the standard course. L74 lists examples, including the management of life-threatening bleeding for agriculture, forestry, construction and remote sites, and paediatric first aid for schools and nurseries. Tell your training provider about your particular hazards so the course can be tailored to them.

HSE updated L74 in 2024 to stress that your assessment should take account of employees' mental health. An EFAW or FAW first aider may already be able to give initial support during an acute mental health episode, and HSE says you should consider whether further training is needed. Our one-day First Aid for Mental Health course trains nominated staff to spot problems early and signpost colleagues to help.

When you choose a provider, HSE's guidance asks you to check that the syllabus matches your assessment, the course runs for the contact hours above, the trainers are competent, there is quality assurance, and the certificate records its three-year validity.

Frequently asked questions

Is a first aid needs assessment a legal requirement? Yes, in HSE's reading: its guidance says employers are required to carry one out, and the assessment is how you decide what is "adequate and appropriate" under regulation 3 of the Health and Safety (First-Aid) Regulations 1981. The Regulations apply in England, Wales and Scotland.

Do I have to write down my first aid needs assessment? No, though HSE calls a written record useful, because it shows how you decided on your first aid provision.

Does a small business need a trained first aider? It depends on the assessment. HSE suggests an appointed person and a stocked kit as the minimum for a low-hazard workplace with fewer than 25 employees, and for a higher-hazard one with fewer than five.

How long does a first aid certificate last? Three years, for both EFAW and FAW. Requalify before the expiry date, and consider the annual refresher HSE strongly recommends.

Do I have to provide first aid for customers and visitors? Not under regulation 3 of the First-Aid Regulations 1981, whose duties cover only your employees, though HSE strongly recommends including members of the public in your assessment and making provision for them.

Do I need a defibrillator at work? Health and safety law does not require one. If your assessment leads you to provide one, the Provision and Use of Work Equipment Regulations 1998 apply, so you give users written instructions, and HSE says fuller training is likely to make them more confident. AED use is part of the EFAW and FAW syllabus, and defibrillator training covers it on its own.

Can a first aider give painkillers? No. In HSE's guidance, first aid at work excludes giving tablets or medicines to treat illness, with one exception: aspirin for a suspected heart attack, in line with accepted first aid practice.

Where to start

Put three things side by side: your risk assessment, a headcount for each site and shift, and your accident records. Read them against HSE's suggested numbers, then list the expiry date of every first aid certificate you hold.

If you would like help, we can work through the needs assessment with you. Before a First Aid at Work course, we also confirm your sector, incident arrangements and first aid needs with your site lead.