How do you complete a BC workplace first aid assessment?
A British Columbia employer must provide at least the first-aid equipment, supplies, facilities, attendants and services required by WorkSafeBC Schedule 3-A, then assess whether more is needed so injured workers can receive prompt first aid and prompt transport to medical treatment. Section 3.16 of the BC OHS Regulation requires a written assessment for that additional-needs decision. It must cover worker numbers and locations, workplace risks, likely injuries, barriers to reaching injured workers, transport time and available methods. It must be reviewed and updated within 12 months of the previous assessment or review and whenever a significant operational change affects it.
The assessment is not a certificate that a first aid kit exists. It connects real work, geography and transport conditions to the resources needed to get help to an injured worker. The employer must prepare, review and update it in consultation with the joint committee or worker health and safety representative where applicable. At a workplace where workers of two or more employers are present at the same time, section 3.20 gives the prime contractor a whole-workplace assessment and coordination duty. These are material reasons to write a site-specific document rather than print a provincial table and file it unchanged.
Start with the statutory minimum, then test the real workplace
Schedule 3-A sets minimum first-aid levels by workplace class, worker count and hazard rating. The current WorkSafeBC Part 3 regulation contains the tables and definitions. Class 1 is the ordinary category; classes 2, 3 and 4 reflect remote or less-accessible conditions as defined in the Schedule. Do not guess a class from the site's postal address. Travel to medical treatment, access difficulty and the actual work location matter. Nor should an employer copy a training certificate title from an old pre-2024 table without checking the present basic, intermediate and advanced classifications.
Identify the maximum number of workers who may be present during the relevant operating period, the hazard rating and the workplace class. Record the table row chosen, the attendant level, kits, facilities and any transport requirement. Schedule 3-A is the baseline under section 3.16(1)(a). Section 3.16(1)(b) then asks whether additional provision is needed to ensure prompt first aid and prompt medical transport. A minimum row can be inadequate for a site with widely dispersed crews, difficult rescue access or a changing high-risk activity.
For example, a company with twenty workers in one easily accessible workshop may choose a different Schedule 3-A row from a company with twenty workers dispersed across forest access roads. Even if the same number appears in the workforce column, the class, hazard rating, travel and rescue barriers can change the equipment and attendant decision. The written assessment should explain the facts used, not merely output a shopping list.
Record the six matters section 3.16(2) names
First, record how many workers are present and where they work. Include shifts, seasonal peaks, lone or mobile workers, contractors and the part of the site furthest from help. A head count averaged over the year can hide a busy weekend or shutdown crew. Second, map worker locations against the first aid attendant, equipment, communications and transport pickup point. If a worker is behind a locked process boundary, a nearby attendant may still be unable to reach them quickly.
Third, describe the nature and extent of risks and hazards. Think about machinery, heights, vehicle movement, chemicals, confined access, hot work and environmental conditions where relevant. Fourth, consider the types of injuries likely to occur. This is not a prediction that a particular accident will happen; it tests whether the available response can deal with credible exposures. A facility where a chemical splash is plausible may need a different immediate response from an office with mainly minor cuts and strains. The first-aid assessment does not replace hazard control or safe work procedures.
Fifth, identify barriers to first aid reaching the worker. Distance, terrain, locked gates, radio dead zones, night access, elevated work, restricted spaces and weather can matter. Sixth, evaluate time and methods of transport to medical treatment. Use realistic conditions, not a map application at midday if the site operates at night or in winter. Identify who calls transport, where an ambulance or other vehicle can collect the injured person, and what happens if the normal route is closed.
WorkSafeBC's G3.16 guideline explains how to consider factors beyond the table minimum. Use the current guideline alongside the current regulation; the legal obligation remains in section 3.16 and Schedule 3-A. Avoid declaring that a numerical drive time alone makes a workplace remote or less accessible without applying the Schedule definitions and the actual travel conditions.
Turn the assessment into a service that works on every shift
Once the assessment identifies a required attendant, confirm the person holds the current certificate level and can actually respond while on duty. Section 3.15 sets attendant qualification requirements; section 3.18 requires an effective communication means between the attendant and workers, and bars duties that interfere with responding to first-aid requests. A name on the rota is weak evidence if that person is often offsite, handling a task that prevents them hearing a call, or working only one of three shifts.
Check where kits and any dressing station or first aid room are kept, whether they are suitable, clean, dry and ready for use, and whether workers can reach them. Section 3.16(4) addresses these conditions. Test access through locked doors, site gates and changing work zones. If emergency transport is required under Schedule 3-A, check the equipment and arrangement against the relevant schedule provisions rather than assuming that any pickup truck satisfies the rule. For air transport as the primary or only method, section 3.17.1 has specific pre-operation and daily availability arrangements.
The assessment should feed the separate written procedures under section 3.17: how to call for help, how the attendant responds, access and movement where barriers exist, who calls transport, and routes to medical treatment. The existing Complys BC drill article owns the procedure-testing task under section 3.17. A failed drill may be evidence that the section 3.16 assessment underestimated a barrier or transport problem. Update the assessment when the finding materially affects its assumptions, then update procedures and services to match.
Example: remote maintenance crew
A maintenance team moves between a depot and a temporary site where a normal ambulance cannot reach every work area directly. The employer's assessment should record the worker numbers, route, vehicle access, communications coverage, likely injuries and transport times at the times the crew operates. It should apply the current Schedule 3-A class and hazard-rating tests and then ask whether the minimum provision is enough. A depot assessment made for a paved urban yard should not be copied to the remote site simply because the same employer and kit are involved. If the site relies on air transport, section 3.17.1 may become relevant.
Multi-employer sites: the prime contractor's assessment
Section 3.20 states that when workers of two or more employers are working at the workplace at the same time, the prime contractor must assess the workplace circumstances under section 3.16(2) for all workers and do everything reasonably practicable to establish and maintain the necessary first-aid provision. This is narrower and more precise than saying every shared property always triggers a prime-contractor first-aid assessment. Determine whether the statutory multiple-employer condition applies to the actual workplace and time.
The prime contractor needs each employer's staffing, locations, hazards, shifts and first-aid resources. Agree who provides attendants, equipment, communication and transport, and how an injured worker from one company can access them. A subcontractor's isolated first-aid kit may not solve a common access or emergency transport problem. Equally, the prime contractor's whole-site assessment should not be used to erase the individual employer's own section 3.16 duties. Put the arrangements in the induction and test the call path across employers.
If a new employer arrives mid-project, or two work areas overlap where the original plan assumed one crew, revisit the assessment. Record the change and communicate the revised arrangement. A prime contractor should not have to discover during an emergency that one employer's attendant was the only person with the gate code or that another employer's workers do not know how to call for help.
Review within 12 months and when operations change
Section 3.16(3) requires review and update within 12 months after the previous assessment or review, and whenever a significant change affecting the assessment occurs. The anniversary is a backstop, not permission to wait after moving operations, changing shifts, introducing a new high-hazard process or losing the only transport route. Document what changed, whether the table minimum changed, what additional services are now needed, consultation with the committee or representative, and who approved the revised plan.
If an incident or drill shows that the attendant could not reach a worker promptly, treat that as evidence to review the assessment. A new low-hazard office worker does not automatically require a full rewrite, but a large change in worker numbers may move the site to a different Schedule row. Keep dated versions and the factual reasons for changes. The record should show that the written assessment and the service on site match each other.
The existing Complys BC first-aid record article owns what to record after injury or exposure under section 3.19. The section 3.16 assessment is a different, forward-looking decision about resources and access. An incident record can reveal a gap in the assessment, but it is not itself the required written assessment.
Common failures to catch before an emergency
- Using the Schedule table alone. Section 3.16 requires a written assessment of additional needs for prompt first aid and transport.
- Using an average head count. The worker number present at the relevant time and location may be higher.
- Assuming โurbanโ means easy access. A high-rise, locked plant or traffic-controlled site can create barriers even near a hospital.
- Keeping the attendant on paper only. Check certification, shift coverage and ability to respond.
- Ignoring a changed transport route. Update the assessment, procedures, training and drills as needed.
- Treating a multi-employer site as separate silos. Section 3.20 requires the prime contractor's all-worker assessment when its condition applies.
- Waiting a year after a significant change. Review when the change affects the assumptions, not merely on the calendar date.
Where Complys can help
The verified Complys Canada site describes worker, training, hazard and document records. A buyer reviewing Canadian OHS software can ask whether the deployed product can store the written assessment, alert owners to review dates, map attendant qualifications to shifts and keep procedure versions. This article does not claim Complys calculates Schedule 3-A requirements, determines workplace class or hazard rating, provides first aid, arranges medical transport or certifies compliance. The employer and any prime contractor must make and implement the actual first-aid decisions.
Use current WorkSafeBC section 3.16 and Schedule 3-A to set the baseline, then walk the site and test the response pathway with the workers and committee or representative who know its barriers. Sign and date the assessment, provide the resulting services on every relevant shift, and review it within 12 months and after significant change. A written assessment is valuable only if an injured worker can actually get help and reach medical treatment promptly.
For the related Complys product, see Ohs Compliance Software. This guide is general information, not legal advice; verify current requirements against the official sources linked above.