BC First Aid Records: Retention and Confidentiality

September 29, 2026·16 min read

A first aid event can end in minutes. The record must remain useful much longer. In British Columbia, an employer needs to know which reported injuries and contaminant exposures enter the workplace first aid record, how long to keep that record, and who may see information that can reveal a worker's health. These are separate questions. A complete entry can still be mishandled if it is placed in a shared incident folder, circulated in a committee pack or lost when a contractor leaves the site.

The starting point is section 3.19 of the British Columbia Occupational Health and Safety Regulation. It addresses the record, minimum retention, confidentiality, inspection by a WorkSafeBC officer and the worker's own access. WorkSafeBC Guideline G3.19 gives practical detail about acceptable fields, corrections, access and multiple-employer workplaces. The regulation sets the legal requirements. The guideline explains WorkSafeBC's approach to applying them. An employer's internal filing method is a further operational decision.

This article covers the section 3.19 record after an injury or exposure is reported or treated. It does not decide whether an incident requires a separate investigation, a compensation claim, or another notification. It also does not replace the workplace's first aid assessment under section 3.16 or written procedures and drills under section 3.17. Those tasks need their own evidence.

Which events belong in the first aid record?

Section 3.19 subsection 1 requires the employer to maintain at the workplace, in a form acceptable to WorkSafeBC, a record of all injuries and exposures to contaminants covered by the Regulation that are reported or treated. The word *reported* matters. A worker's account of a covered exposure can require a record even when the worker receives no first aid treatment at that moment. A system that only opens a record when supplies are used can miss the other side of the rule.

The record should describe what was reported or observed. It should not turn an attendant into a medical diagnostician or ask an administrator to decide that a reported exposure is harmless. Section 3.21 subsection 1 requires a first aid attendant to objectively record observed or reported signs and symptoms of covered injuries and exposures. That is a useful discipline for anyone building the form: separate the worker's report, direct observations, treatment and later administrative steps. If a fact is unknown, say so rather than filling the gap with a confident guess.

An employer also needs a way to receive reports when the designated first aid attendant is unavailable or the worker is away from the main site. Guideline G3.19 says that in a small workplace without a required attendant, or when a worker is injured away from the workplace and receives no attendant treatment, another person who administers care or a supervisor may complete the first aid record. This is the regulator's guidance on how the record can be made in those circumstances. It does not change the employer's duty to maintain the record.

Consider a worker who reports a splash of a contaminant but has no immediate symptoms. A record can capture the report, location, time and steps taken without inventing a diagnosis. Consider a worker who tells a supervisor about a minor cut after declining treatment. The reported injury should not vanish from the process merely because no bandage was issued. The exact facts of an event may trigger other duties, but the first aid record should not depend on a later claim decision.

What information should the record contain?

WorkSafeBC's G3.19 list of acceptable record information gives a practical design test. It includes the worker's full name and occupation; the date and time of injury or reported exposure or illness; the date and time the matter was reported to the employer; witness names; how the event occurred; the nature of the injury, exposure, disease or illness; treatment and arrangements made for the worker; subsequent treatment for the same event; and the signature or equivalent of the person giving first aid, with the worker's signature if possible.

The two dates and times serve different purposes. The event may have happened earlier than the report. Keeping both helps a later reader reconstruct what was known and when. Witness names should identify actual witnesses, not people copied from a shift roster. A treatment entry should say what was done, by whom and whether the worker was referred or transported. If no treatment was given, that can be stated plainly. Avoid a prefilled phrase such as “no further action required” when the record does not support it.

WorkSafeBC provides a first aid record form, but the guideline says employers need not use that exact form if their own records capture the required information. That permits a paper or electronic design that works for the workplace. It does not remove the need to make the information available, keep it confidential and preserve it. Before replacing an old paper form with a digital form, compare every field with G3.19. Check that the date of report, subsequent treatment and the identity of the person recording care are not lost in the conversion.

A well-designed record also makes it clear which statements are a worker's own account and which are the attendant's observations. A short narrative box can be more useful than a series of vague tick boxes if it identifies the location, activity and immediate action. The aim is a contemporaneous account. The form should not invite speculative fault findings or broad circulation of medical details to people who only need a safety summary.

How soon should an entry be made, and who may change it?

Guideline G3.19 says first aid records must be completed as thoroughly as possible by a first aid attendant as soon as practicable after treatment. The person making the entry should use the facts then available. Waiting until a weekly administration session makes exact times and observations harder to recover. Where the guideline allows another person to create the record, the employer should make that route obvious so a reported injury is not left in an informal message thread.

Corrections deserve their own rule. G3.19 says a record should not be revised by someone other than its creator, apart from adding administrative information that was unavailable at the time. Revisions should be clear and traceable. For a paper record, the guideline gives an initialled single cross-out as an example. In an electronic workflow, retaining the original entry, identity of the editor, timestamp and reason for change serves the same traceability objective. That electronic method is a practical implementation choice, not a claim that WorkSafeBC mandates a particular software feature.

For example, if a worker later remembers that a witness was present, the person who created the record can make a traceable addition. If a compensation administrator later receives a claim number, that administrative information can be appended without silently changing the medical account. A manager should not rewrite the attendant's observation to make a later incident summary look tidier. If an entry is disputed, preserve the original and record the correction and its source, rather than hiding the disagreement.

How long must BC first aid records be kept?

Section 3.19 subsection 2 says first aid records must be kept for at least three years. This is a minimum, not an instruction to destroy every record as soon as three years have elapsed. Other legal duties, an active claim, a preservation obligation or an employer's justified records policy may affect a particular file. This article does not set a universal destruction date for every record category.

The wording of section 3.19 subsection 2 gives the minimum period but does not itself state a detailed disposal-clock formula. Do not replace it with a precise “three years from the incident date” instruction unless a current authoritative rule applicable to the record supports that calculation. An employer can log the event date, report date, record creation date and any later additions so the retained material is intelligible. Before disposal, confirm the relevant retention rules and whether a claim or other lawful preservation reason still applies.

Retention must survive changes in people and contractors. If the only copy is in an attendant's notebook taken home after a project closes, the employer may be unable to produce it. Set a named record custodian, a documented transfer on role change and a retrieval method that still works after the original attendant leaves. A three-year rule is only meaningful if the employer can actually find the record throughout that period.

Keep the record legible and complete. A scanned form with a cut-off signature or an exported database containing only the first treatment entry may not preserve the information that G3.19 expects. When changing storage systems, test retrieval with a sample historic record, including its amendments and attachments. That is an operational control, not a separate statutory retention period.

Who may see a first aid record?

Section 3.19 subsection 3 requires first aid records to be kept confidential. It prohibits disclosure except as permitted by the Regulation or otherwise by law. Subsection 4 requires availability for inspection by a WorkSafeBC officer. Subsection 5 says workers may request or authorize access to their own first aid records concerning treatment or a report about themselves. These are specific access rules. They do not make the whole first aid log a general staff document.

The access part of Guideline G3.19 says only people with a legitimate business need may access records and that access is limited to the information necessary for the purpose. Its examples include a direct supervisor, the worker or an authorized representative for that worker's own record, designated health and safety or compensation staff, attendants, a prime contractor where coordination requires it, and a WorkSafeBC prevention officer. Inclusion on that example list is not a blanket right to read every record. The purpose and extent of access still matter.

Suppose a supervisor needs to know that a worker has been taken for medical care and that a job must be covered. The supervisor may need the relevant record or a limited part of it to perform that task. A manager assembling a safety trend report generally does not need to email the full medical narrative to a broad distribution list. The guideline says a summary is generally enough for a joint health and safety committee or worker representative, and may be enough for a prime contractor. A summary can describe the event pattern and corrective action without naming every injured worker or reproducing treatment details.

This distinction matters when a single spreadsheet serves several audiences. A shared dashboard that displays names, symptoms and treatment to all committee members conflicts with the guideline's limited-access approach. Separate the confidential source record from a de-identified or otherwise appropriately limited safety summary. If identification is needed for a legitimate purpose, assess that purpose and the permitted extent of disclosure before sending the material.

The guideline says first aid records should be treated as personal medical information and kept confidential in line with applicable privacy legislation. This article does not determine which privacy statute applies to every employer or authorize a particular disclosure under it. For an unusual request from an insurer, outside lawyer, client or another employer, verify the legal basis and necessary scope rather than treating a general safety interest as automatic permission.

How should a worker's own-record request be handled?

The worker-access rule in section 3.19 subsection 5 is direct: workers may request or authorize access to first aid records for treatment or a report about themselves. A request should therefore be routed to someone who can locate the relevant record, verify the requester or authorization and provide access to that worker's material without exposing another person's record. Do not assume a worker must explain why they want their own first aid entry.

At a minimum, an employer process should identify a contact, the records held, how an authorization is checked, and how a copy or inspection is provided. A request covering several treatment entries may require a search across different dates or sites. If one incident involved several workers, separate their information before sending a copy. If another law affects the form or timing of a response, use that law rather than inventing a deadline under section 3.19. The section establishes the access entitlement but does not in the cited wording prescribe a universal response-day count.

Keep a brief access log: request date, record found, person deciding, basis for access, material supplied and delivery method. This is a suggested control to demonstrate that the confidentiality rule was respected. It is not presented as a separate field mandated by G3.19. Avoid attaching the complete record to an unverified email address or a general team channel merely because the requester says they are a colleague of the injured worker.

What changes on a multiple-employer worksite?

The legal obligation in section 3.19 subsection 1 is framed around the employer maintaining the record at the workplace. G3.19 explains how that obligation can work when another employer provides the first aid service. It says first aid records are owned by the injured worker's employer. A service provider may maintain them during the project, but the records must be provided to the injured worker's employer once that employer's work on the project is complete. The injured worker's employer must retain them for at least three years.

That means a prime contractor's central first aid room should not become an unexamined permanent archive for every subcontractor's workers. At mobilisation, agree who creates a record, who can retrieve it while the project is active, how a worker requests access, and how the record will be transferred securely when an employer leaves. The project arrangement must protect confidentiality throughout the handoff. The guideline also says each participating employer must separately comply with the section 3.19 record duty at its own workplace, even if a central service keeps records.

A practical handover list can identify the employer, event identifier, record creator, transfer date and receiving custodian without putting a full treatment narrative into a general project register. Confirm receipt and preserve a retrieval path. If a worker requests their own record after the project ends, the employer should be able to locate the holder rather than asking the worker to find an individual former attendant.

Paper, electronic storage and location

The regulation specifies a record in a form acceptable to WorkSafeBC. It does not require the employer to buy a particular system. A locked paper file can work if records remain legible, retrievable and available for lawful inspection. An electronic system can work if access is restricted, changes are traceable, retrieval survives staff changes and the record remains available at the workplace for the regulatory purpose. These are implementation considerations drawn from the record and confidentiality duties, not a product endorsement.

G3.19 also says that electronically kept and stored records should be stored within Canada. The word *should* is guidance, so do not describe Canadian hosting as an absolute requirement of section 3.19 itself. A business considering a cloud repository should check where records and backups are held and assess the applicable privacy and contract requirements. The guide does not resolve every cross-border data issue. The safe immediate action is to avoid uploading medical detail into a general project folder without checking access, storage and retention first.

Paper has its own failure modes. A form left on a first aid room counter may be visible to visitors. A site binder handed to a new shift may mix confidential records with public procedures. Give the person maintaining the log a secure location and a method to provide an officer or the worker with the relevant record when access is permitted. Confidentiality and availability must both be maintained.

An operational records check after a first aid event

Use a short review once immediate care and reporting are underway. Ask whether the covered injury or exposure was recorded, even if there was no treatment. Confirm the event and report times are separated, the entry attributes observations accurately, and the treatment or referral field says what happened. Check whether the creator signed or authenticated the entry and whether any later administrative addition is marked as such. The review can be performed without circulating the full record to everyone involved in the safety response.

Then confirm custody. Is the record at the workplace in an acceptable, retrievable form? Who may access it, and are committee or management summaries limited to their actual purpose? Can the worker request their own entry? If another employer delivered the first aid, is there a documented handover to the injured worker's employer? Finally, set a retention control that respects the three-year minimum and pauses disposal when another valid preservation reason exists.

These questions are not a scoring algorithm. A checked box cannot establish that every disclosure was lawful or that every event was classified correctly. They are prompts for a person to compare the actual record and workflow with section 3.19 and G3.19. If the facts involve a disputed disclosure or an unusual privacy obligation, get case-specific advice before using this general article as a decision rule.

Keep the record task separate from wider incident management

A first aid record answers what was reported or treated and what care or arrangements followed. An incident investigation examines causes and corrective action. Compensation reporting and notifications have their own triggers and forms. The same event may involve several of these processes, but one document does not automatically fulfil them all. Do not delete an entry because another system holds a claim number, or copy the full medical entry into a widely circulated investigation report merely to avoid typing a summary.

For broader program ownership, use the Canadian health and safety program guide. That hub explains the wider management context. This page is the narrower BC recordkeeping task. It should link from the hub only after the canonical route and live status are confirmed during integration.

If your organisation is reviewing how it coordinates safety work across sites, explore Complys in Canada and discuss the workflow you need. Confirm any proposed handling of medical records, access permissions or retention with the actual product implementation and your own privacy requirements before relying on it. This article does not claim that Complys stores, validates or controls first aid records.

Primary sources checked: WorkSafeBC Occupational Health and Safety Regulation, sections 3.19 and 3.21; WorkSafeBC OHS Guideline G3.19. Recheck section 3.19 and G3.19 before publication and on a change to the Regulation or guideline.