A first aid needs assessment isn't optional. Under the Health and Safety (First-Aid) Regulations 1981, every UK employer must assess their workplace to determine what first aid provision is adequate. Get it wrong, and you could face enforcement action, insurance issues, or worse — an emergency you're not prepared to handle.
Have you completed a first aid needs assessment?
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What is a first aid needs assessment?
A first aid needs assessment is a systematic evaluation of your workplace to determine what first aid provision you need. It considers your specific circumstances — the hazards present, the people who work there, and the nature of your operations — to answer critical questions:
- How many first aiders do you need?
- Should they be trained to FAW or EFAW level?
- Do you need appointed persons instead of (or as well as) first aiders?
- What first aid equipment and facilities do you need?
- Do you need a dedicated first aid room?
- Are there special circumstances requiring additional provision?
"Adequate" first aid provision looks different for every workplace. A 10-person office needs very different provision from a 10-person construction site. Your assessment determines what "adequate" means for you — and demonstrates to regulators that you've thought seriously about your obligations.
The legal requirement
The Health and Safety (First-Aid) Regulations 1981 (Regulation 3) explicitly requires employers to:
"Provide, or ensure that there are provided, such equipment and facilities as are adequate and appropriate in the circumstances for enabling first-aid to be rendered to his employees if they are injured or become ill at work."
Before you can meet this duty, you must assess what's "adequate and appropriate" for your circumstances. Regulation 3(2) makes this clear by requiring employers to consider:
- The nature of the workplace and its hazards
- The size of the workforce and distribution of employees
- The location of the workplace and access to emergency medical services
- The history of accidents and ill health at the workplace
Not doing an assessment isn't just poor practice — it's a breach of the law. HSE inspectors will ask to see your written assessment. Without one, you can't demonstrate that your first aid provision is adequate, and you're vulnerable to enforcement action.
The accompanying Approved Code of Practice (ACOP L74: First aid at work) provides detailed guidance on how to conduct your assessment. While the ACOP isn't law itself, courts will use it as evidence of good practice. If you don't follow it, you need a good reason why.
Who should conduct the assessment?
Your assessment should be carried out by someone competent — someone with the knowledge, experience, and authority to:
- Identify workplace hazards and their potential consequences
- Understand your workforce and working patterns
- Interpret HSE guidance and apply it to your circumstances
- Make informed recommendations about first aid provision
- Record and communicate their findings
This might be:
- The business owner or manager (in smaller, lower-risk workplaces)
- Your health and safety manager or advisor
- A competent external consultant (for complex or higher-risk workplaces)
Involve your first aiders (if you already have them) and other employees in the assessment. They understand the day-to-day realities of your workplace and may identify risks or issues you've overlooked.
Conducting the assessment
A thorough needs assessment examines five key areas. Let's work through each one.
1. Assess workplace hazards and risks
Start by identifying what could go wrong. What hazards are present, and what injuries or illnesses might they cause?
Ask yourself:
- What are the main hazards in your workplace? (machinery, chemicals, heights, vehicles, slips and trips, manual handling, heat, cold, etc.)
- What injuries might reasonably occur? (cuts, burns, fractures, head injuries, chemical exposure, eye injuries, cardiac events, etc.)
- How serious could these injuries be?
- Could injuries happen suddenly and be immediately serious?
- Are there special risks requiring specific first aid knowledge? (chemical burns, confined spaces, electrical hazards, drowning risk)
- What do your risk assessments tell you?
Risk Level Examples
Lower-hazard workplace
- •Most injuries would be minor (cuts, bruises, headaches)
- •Low likelihood of serious injuries
- •Main hazards: slips/trips, manual handling, DSE-related
- •Close to emergency medical services
- •EFAW training may be sufficient
Higher-hazard workplace
- •Potential for serious injuries (fractures, burns, head injuries)
- •Machinery, heights, hazardous substances present
- •Main hazards: machinery, falls, vehicles, chemicals, manual handling
- •May be remote from emergency medical services
- •FAW training typically required
Bottom line: The higher the risk of serious injury, the more first aid provision you need — both in terms of numbers and level of training.
Look at your accident history:
- What injuries have occurred in the past 3-5 years?
- What near misses have been recorded?
- Have employees required first aid treatment? For what?
- Are there patterns suggesting particular hazards?
- What about similar businesses in your industry?
2. Assess your workforce
The people who work in your organization affect what first aid provision you need.
Numbers and distribution:
- How many employees work at the site?
- Are they concentrated in one area or spread out?
- Do you have multiple floors, buildings, or sites?
- Are some areas more hazardous than others?
- Could a first aider reach any employee within 2-3 minutes?
Working patterns:
- Do you operate shifts? (You need first aid cover during ALL working hours)
- Is there out-of-hours or weekend working?
- Do employees work alone or in isolated locations?
- Are there times when many staff are off-site?
- Do you have seasonal variations in staff numbers?
Workforce characteristics:
- Are there inexperienced workers, trainees, or apprentices?
- Do you employ young workers (under 18)?
- Are there new or expectant mothers?
- Does anyone have a disability or health condition requiring special consideration?
- Are there workers whose first language isn't English? (May affect their ability to explain symptoms or understand instructions)
- Do you have high staff turnover?
Working away from base:
- Do employees travel as part of their work?
- Are there remote or off-site working locations?
- Do employees work at client premises?
- Are there lone workers?
Care home revised first aid provision after workforce assessment
A residential care home with 40 staff assumed they needed only basic first aid provision. Their assessment revealed they needed significantly more.
- ✗24-hour operation across three shifts — initial provision only covered day shift
- ✗High proportion of agency and temporary staff (less familiar with facilities)
- ✗Staff working alone during night shifts
- ✗Some staff didn't speak English as first language
- ✗Previous year saw four staff injuries requiring hospital treatment (manual handling)
The home trained six FAW first aiders to ensure coverage across all shifts, created visual first aid guidance for staff with limited English, improved their first aid room, and implemented better manual handling training to address the injury trend.
Don't just count employees. Consider shift patterns, staff characteristics, turnover, and working arrangements. Your assessment should identify vulnerabilities in your current provision.
3. Assess workplace characteristics
Your physical workplace affects how quickly first aid can be provided.
Location and access:
- How far are you from emergency medical services?
- Would an ambulance reach you within 10 minutes? 30 minutes? Longer?
- Are there access difficulties? (Rural location, traffic congestion, security barriers)
- Is the workplace easy to find for emergency services?
- Do you have mobile phone coverage?
Layout and facilities:
- Is the workplace on multiple floors?
- Are there separate buildings or annexes?
- Are some areas remote from others? (Could take several minutes to reach)
- Is there a suitable location for treating casualties? (Privacy, comfortable, accessible)
- Do you need a dedicated first aid room?
Public access:
- Do members of the public visit your premises? (offices, shops, leisure facilities, schools)
- Are there visitors, contractors, or delivery drivers?
- Do you have a duty of care to non-employees?
While the law only requires you to provide first aid for your employees, HSE strongly recommends extending provision to non-employees. Most employers do this as good practice — and to reduce legal risks.
Environmental factors:
- Are there areas exposed to extreme temperatures?
- Is there potential for contamination? (Food environments, clinical settings, chemical work)
- Are there hygiene considerations?
4. Consider special circumstances
Some circumstances require additional or different first aid provision.
Remote and lone workers:
- Do employees work alone for extended periods?
- Could a lone worker summon help if they became incapacitated?
- Do you have check-in procedures?
- Should lone workers carry personal first aid kits?
- Do they need enhanced first aid training?
High-risk activities:
- Do any activities require specialist first aid knowledge?
- Chemical handling (specific treatment protocols, eye wash, safety showers)
- Confined spaces (rescue procedures, breathing apparatus knowledge)
- Work at height (casualty evacuation, spinal injury management)
- Hot works (burns treatment)
- Electrical work (electrical shock treatment)
- Diving or water work (drowning, hyperbaric injuries)
Temporary changes:
- Are there periods of change that affect first aid needs?
- Refurbishment or construction work
- Seasonal peaks in staff numbers or activity
- Known absences of first aiders (holidays, training, maternity leave)
- Special events or activities
- School holidays (if many working parents)
Travel and mobile workers:
- Do employees work from vehicles?
- Do they attend client sites or work locations?
- Are traveling first aid kits needed?
- What provision exists at locations they visit?
5. Review existing provision
If you already have some first aid provision, evaluate whether it's adequate.
Current first aiders:
- How many first aiders do you currently have?
- Are they FAW or EFAW qualified?
- When do their qualifications expire?
- Are they available during all working hours?
- What happens when they're on holiday or off sick?
- Do they actually work in the locations where they're needed?
Equipment and facilities:
- How many first aid kits do you have?
- Are they appropriately stocked and in date?
- Are they in the right locations?
- Is there a suitable place to treat casualties?
- Do you need a first aid room?
- Is equipment appropriate for your identified risks?
Information and records:
- Do all employees know who the first aiders are?
- Are first aiders clearly identified? (Notice boards, posters, badges)
- Do employees know where first aid kits are kept?
- Are first aid incidents being recorded?
- What do the records tell you?
Factors to Evaluate in Existing Provision
Are first aiders present during all working hours, across all locations, with cover for absences?
Is the level of training appropriate for your workplace risks?
Are first aid kits sufficient in number, appropriately located, and properly stocked?
Do employees know who first aiders are, where kits are, and what to do in an emergency?
Are you recording first aid incidents and learning from them?
Determining first aid provision needed
Based on your assessment, you can now determine what first aid provision you need.
Number of first aiders
HSE provides starting point guidance based on workplace risk and employee numbers:
Lower-hazard workplaces (offices, shops, libraries, light assembly):
- Fewer than 25 employees: At least one appointed person
- 25-50 employees: At least one first aider (EFAW may be sufficient)
- 50+ employees: Additional first aider for every 50 employees
Higher-hazard workplaces (construction, manufacturing, warehousing, chemical work):
- Fewer than 5 employees: At least one appointed person
- 5-50 employees: At least one FAW-trained first aider
- 50+ employees: Additional FAW first aider for every 50 employees
These are starting points only, not fixed rules. Your assessment might require more first aiders because of shift work, site layout, remoteness, specific hazards, or other factors. You can never have too many first aiders, but you can definitely have too few.
Adjust for your circumstances:
Add more first aiders if:
- You operate multiple shifts (need coverage 24/7)
- The workplace is spread over large area or multiple buildings
- There are employees in remote or isolated locations
- You're far from emergency medical services
- You have high-risk activities
- You have high staff turnover (harder to maintain coverage)
- First aiders are often away from their normal location
- You want to ensure cover during holidays and sickness
Training level: FAW or EFAW?
Choose First Aid at Work (FAW) if:
- Your workplace is higher-hazard
- Serious injuries could occur
- You're remote from emergency medical services
- Your workforce is large (50+ employees)
- You want more comprehensive first aid capability
Emergency First Aid at Work (EFAW) may be sufficient if:
- Your workplace is genuinely low-hazard
- Serious injuries are very unlikely
- You're close to emergency medical services
- Your workforce is small
- Your needs assessment supports this level
When in doubt, choose FAW. It provides more comprehensive training and gives first aiders greater confidence and capability. Many low-risk employers choose FAW even though EFAW might technically be sufficient.
Appointed persons vs first aiders
Very small, low-risk workplaces may only need appointed persons rather than trained first aiders.
An appointed person:
- Takes charge when someone is injured or becomes ill
- Calls an ambulance if needed
- Looks after first aid equipment and keeps it stocked
- Maintains accident records
- Is NOT a first aider and should not attempt treatment beyond what any reasonable person would do
When is an appointed person sufficient?
- Very low-risk workplace (office, shop, consulting firm)
- Very small number of employees (fewer than 25 in low-risk, fewer than 5 in higher-risk)
- Close proximity to emergency medical services
- Employees work near each other
Most employers find that having at least one qualified first aider provides greater confidence and capability, even in low-risk settings.
First aid equipment
Minimum requirement: At least one suitably stocked first aid kit per location, containing:
- Guidance leaflet
- Sterile adhesive dressings (assorted sizes)
- Sterile eye pads
- Individually wrapped triangular bandages
- Safety pins
- Sterile wound dressings (medium, large, extra-large)
- Disposable gloves
First aid kits must NOT contain medication — not even basic painkillers like paracetamol or aspirin. First aiders aren't qualified to administer medication, and you have no way to know about allergies or drug interactions.
Additional equipment to consider:
- Multiple kits for large workplaces or multiple floors
- Traveling first aid kits for mobile workers
- Specialized equipment for identified hazards:
- Eye wash stations (chemical work)
- Burns dressings (hot work)
- Thermal blankets (outdoor work)
- Resuscitation equipment
- Automated External Defibrillator (AED)
First aid room
Most workplaces don't need a dedicated first aid room, but you must provide one if your assessment identifies it as necessary.
You may need a first aid room if:
- You have 150+ employees
- You're remote from emergency medical services
- You have special hazards
- Serious injuries could occur
- Your industry guidance recommends it
At minimum, you need a suitable location where someone who is ill or injured can rest in privacy until they recover or help arrives.
Recording your assessment
Your assessment must be recorded in writing. This isn't just bureaucracy — it's essential evidence that you've met your legal duty to assess.
What to document
Your written assessment should include:
-
Date of assessment and who conducted it
- When was it done?
- Who carried it out?
- What's their competence?
-
Description of your workplace
- Nature of business and activities
- Location and access to emergency services
- Layout (floors, buildings, site area)
- Number of employees and working patterns
-
Hazards identified
- List of workplace hazards
- Potential injuries or illnesses
- Risk level assessment
- Reference to existing risk assessments
-
Workforce considerations
- Employee numbers and distribution
- Shift patterns and working hours
- Special characteristics (lone workers, inexperienced staff, etc.)
- Employees working away from base
-
Special circumstances
- Any factors requiring additional provision
- Remote locations, high-risk activities, etc.
-
Existing provision reviewed
- Current first aiders (names, qualification levels, expiry dates)
- Current equipment and facilities
- Gaps or inadequacies identified
-
Conclusions and recommendations
- Number of first aiders needed
- Training level required (FAW/EFAW)
- First aid equipment needed
- Facilities required
- Any special provisions
- Action plan with timescales
-
Review date
- When will the assessment be reviewed?
- What triggers would require earlier review?
Keep your assessment accessible. HSE inspectors will ask to see it. Make sure key managers know where it is and that it's referenced in your health and safety documentation.
When to review your assessment
Your assessment isn't a one-time exercise. You must keep it under review and update it when circumstances change.
Annual review
At minimum, review your assessment every year. Even if nothing obvious has changed, the review process often identifies subtle shifts that affect your needs.
Annual review checklist:
- Have employee numbers changed?
- Have working patterns changed (new shifts, more remote working)?
- Have any new hazards been introduced?
- Has the workplace layout changed?
- Are first aider qualifications up to date?
- What does accident data tell you?
- Is current provision still adequate?
Review triggers — when to review immediately
Don't wait for your annual review if circumstances change significantly. Review your assessment when:
Changes to your workplace:
- Introduction of new hazards or processes
- Change in workplace layout (refurbishment, new building, relocation)
- New machinery or equipment
- Change in distance to emergency services
Changes to your workforce:
- Significant increase or decrease in employee numbers (20%+ change)
- Introduction of shift working or change to shift patterns
- New vulnerable workers (young workers, disabled employees, expectant mothers)
- Increase in remote or lone working
- High turnover affecting first aider availability
Changes to first aid provision:
- First aider leaves or qualification expires
- Loss of multiple first aiders
- Feedback from first aiders about adequacy of equipment or training
- Changes to HSE guidance or legal requirements
After incidents:
- Serious injury or ill health at work
- Multiple similar incidents suggesting a pattern
- Incident where first aid provision proved inadequate
- Near miss revealing a gap in provision
Set calendar reminders for your annual review date AND for first aider qualification expiry dates. Build triggers into your change management process so that significant workplace changes automatically prompt an assessment review.
HSE guidance and resources
The Health and Safety Executive provides detailed guidance on first aid needs assessments.
Key HSE publications:
L74: First aid at work (Approved Code of Practice)
- The definitive guidance on the First-Aid Regulations
- Provides detailed advice on conducting assessments
- Includes examples and case studies
- Available free from HSE website
INDG214: First aid at work: Your questions answered
- Shorter guide answering common questions
- Useful quick reference
- Free from HSE website
First aid needs assessment form
- HSE provides a template assessment form
- Helps structure your assessment
- Ensures you've considered all factors
- Available for download from HSE
HSE guidance is regularly updated. Check the HSE website for the latest versions and any changes to requirements or best practice.
Industry-specific guidance
Some industries have specific guidance:
- Construction industry first aid guidance (Construction Industry Advisory Committee)
- Offshore installations (separate regulations apply)
- Agriculture guidance
- Care sector guidance
Check whether industry-specific guidance exists for your sector and follow it alongside general HSE guidance.
Common mistakes to avoid
1. Just counting heads
The biggest mistake is simply looking at employee numbers and assuming that determines your needs. A 30-person construction company needs very different provision from a 30-person consultancy firm. Your assessment must consider actual risks, not just headcount.
2. Forgetting shift workers
Many assessments only consider day shift staffing. If you operate evenings, nights, or weekends, you need first aid cover during those hours too. Don't leave night shift workers without provision.
3. Ignoring workplace layout
Having three first aiders sounds adequate for 120 employees — until you realize they all work in the same office building, and 40 employees work in a warehouse 500 meters away. Distribution matters as much as numbers.
4. Assuming EFAW is always sufficient for low-risk workplaces
Even in offices, serious medical events can occur (cardiac arrest, stroke, serious allergic reactions). Many employers choose FAW even for low-risk workplaces because it provides better capability to respond effectively.
5. Forgetting about holidays and absences
Your assessment might show you need two first aiders. But what happens when one is on holiday? Or off sick? Build in resilience.
6. Not recording the assessment
An unrecorded assessment is essentially worthless. If HSE inspect and you can't produce written evidence of your assessment, you're in breach regardless of how adequate your actual provision is.
7. Never reviewing it
Circumstances change. An assessment from five years ago doesn't reflect your current workplace. Review regularly and update when things change.
8. Not involving first aiders or employees
The person doing the assessment might not understand day-to-day realities. First aiders and employees often identify risks or practical issues that management overlook.
Frequently asked questions
The regulations only require you to assess first aid provision for employees. However, HSE strongly recommends including non-employees in your assessment and provision. Most employers extend first aid provision to anyone on their premises — it's good practice and reduces legal risk. If you have significant public access, this should definitely be reflected in your assessment.
Detailed enough to demonstrate you've considered all relevant factors and reached informed conclusions. It should be clear how you got from 'assessment of hazards and circumstances' to 'conclusions about provision needed'. A few paragraphs won't suffice for a complex workplace. Use the HSE template as a starting point — it ensures you cover everything required.
You can use a template to structure your assessment, but the content must be specific to your workplace. Generic tick-box assessments that could apply to any workplace won't satisfy the legal requirement. HSE provides a template form that you should complete with your specific information.
You have a legal duty to provide adequate provision, so 'I couldn't find volunteers' isn't an acceptable excuse. Options include: offering incentives for first aider training, making it part of job descriptions for new hires (as long as they can decline), approaching recruitment with a positive campaign, or considering how you can reduce risks to reduce the level of provision needed. As a last resort, you may need to reduce operations until adequate provision is in place.
The First-Aid Regulations only apply to employers in relation to their employees. If you're genuinely self-employed with no employees, you're not required to do an assessment or provide first aid provision. However, it's sensible to have a first aid kit and basic knowledge, particularly if you work in higher-risk environments or have visitors/clients attending your premises.
Your assessment should consider home workers, but the duty to provide first aid provision is limited when employees work from home. You can't reasonably provide first aiders at their homes. However, you should: provide guidance on maintaining a basic first aid kit at home, ensure they know how to summon emergency help, consider provision for when they attend the office or other locations, and include them in your overall assessment.
No. First aid provision is about immediate response before emergency services arrive. Even in urban areas with quick ambulance response, first aid may be needed immediately — for cardiac arrest, severe bleeding, choking, or other time-critical situations. Your assessment must provide for first aid response on-site, not rely solely on external emergency services.
The assessment should be carried out by someone competent and should be approved by someone with authority to implement its recommendations — typically a director, manager, or business owner. There's no requirement for external sign-off, but the person conducting the assessment must be competent to do so. For complex or higher-risk workplaces, consider having it reviewed by a health and safety professional.
Next steps
Ready to conduct your first aid needs assessment?
Download the assessment template: First Aid Needs Assessment Template →
Need to train first aiders based on your assessment? Choosing first aid training for your workplace →
Want to understand the full picture of first aid requirements? Complete guide to workplace first aid →
Not confident conducting your first aid needs assessment? A health and safety consultant can assess your workplace, provide expert recommendations, and document everything to HSE standards. Get in touch for a consultation.
Related articles:
- Workplace first aid requirements complete guide
- FAW vs EFAW training: which do you need?
- First aid room requirements
- Accident reporting and RIDDOR
Useful tools:
HSE resources:
- L74: First aid at work (ACOP)
- INDG214: First aid at work - Your questions answered
- HSE first aid needs assessment template