TO:                       Environmental Health and Safety (EHS) Coordinator    

FROM:                Sam Celly BChE MChE JD CSP

DATE:                  October 20, 2026

SUBJECT:            First-Aid Kits: 2026 ANSI Update, New Cal/OSHA Rules & Good Practice

Background. On September 17, 2026, International Safety Equipment Association (ISEA) published ANSI/ISEA Z308.1-2026, the updated American National Standards Institute (ANSI) standard for workplace first-aid kits, which takes effect in 2027.  At about the same time, the Cal/OSHA Standards Board approved the first major overhaul of California’s first-aid regulation in decades, expected to take effect as early as January 1, 2027.  In this memo, we discuss the changes to the regulatory requirements for first-aid kits, guidelines, and training.  California regulations mandate that employers ensure ready availability of medical personnel for advice on matters of industrial health or injury. 

CALIFORNIA REGULATIONSCurrently in California: Regulations mandate that first-aid materials approved by a consulting physician be readily available on the premises.  A consulting physician is a medical doctor who should be familiar with dealership operations and typical hazards. (Ref: 8 CCR §3400(a)–(c)).Proposed Regulations in California: On September 17, 2026, the California Occupational Safety and Health Standards Board unanimously approved revisions to 8 CCR §3400 (Medical Services and First Aid for General Industry) and 8 CCR §1512 (Emergency Medical Services for Construction).  The revised rules are expected to take effect as early as January 1, 2027, pending final approval by the Office of Administrative Law (OAL). Key changes under proposed regulations for general industry employers such as dealerships, service shops, and collision centers are:First-Aid Kit Contents: Employers can stock kits that meet the ANSI/ISEA Z308.1-2021 Class A standard OR have a licensed healthcare professional customize the contents. If hazard assessment identifies unique and potentially serious hazards, employers must provide specialized first-aid items, and a Class B kit may meet those requirements. See the detailed discussion below.Readily available. Kits must be in a location with no obstacles to immediate acquisition for use.  (An earlier proposal to require access within 3–4 minutes was dropped.)Locations communicated. Kit locations must be communicated to employees and, to the extent practicable, clearly indicated with signage, labeling, or other means.Hazard evaluation.  Employers must evaluate the number and placement of kits based on workplace size, employee locations, and the types and severity of hazards, and add supplies for hazards unique to the workplace.  A first-aid guide must accompany each kit.

Hazard Assessment: Hazard assessment involves reviewing workplace hazards, typical injuries that have happened (see Log 300) or could occur at the workplace, and the availability of the supplies necessary to respond to those injuries.  Risk assessment includes looking at Bureau of Labor Statistics (BLS) or OSHA injury data.  The M.D. at the local clinic responding to occupational injuries can be a source of guidance as well.  It is a good practice to inspect and refill first-aid kits at least monthly and after any incident in which supplies were used. Keep a written log. Discard expired items promptly.  Disinfect cabinet surfaces frequently.  Ensure labeling and markings are legible and permanent.  Check that each kit and its location is visibly marked.  Place signs at a conspicuous location that indicate the locations of first-aid kits on site.  Employers must provide a sufficient number of kits based upon facility layout, number of employees and access to the kits during the work turn.  The distance from the clinic must also be part of the decision-making process.

Commentary. Dealership management should make prudent decisions on the number and location of the first-aid kits.  As a rule of thumb, we recommend at least one kit per 40 employees, adjusted for layout and shifts.  First, keep in mind that all areas of employment should have access to kits.  For example, if only the sales department is open on a Saturday, then a kit must be made available to employees in that area.  Secondly, these kits are subject to pilferage and abuse.  To avoid pilferage, the first-aid kit may be placed in the office or open view of the manager.  If an employee is observed using multiple bandages more often than others, the employee can be counseled on safety and proper work procedure to avoid slicing his/her hand multiple times a day!  Make sure that access is not compromised, i.e., kits must remain completely accessible when employees are present.  Under the new Cal/OSHA rule, post signs or labels showing where kits are kept to the extent practicable.

Class A vs. Class B

What the standard says. ANSI/ISEA Z308.1-2021 divides workplace first-aid kits into Class A for basic minor injuries and Class B for high-risk, complex, or densely populated environments.  Class A kits generally are suitable for common workplace injuries such as minor cuts, abrasions, minor burns and eye injuries. Class B kits are intended to treat injuries more often found in densely populated workplaces with complex and/or high-risk environments, such as warehouses, factories and outdoor areas. The standard doesn’t assign the class by industry. ISEA’s position is that employers should conduct a workplace hazard assessment to first decide if a Class A or Class B minimum fill best fits the type of hazards at the facility.

ANSI Standard Class A Kit

Required Min. Fill (Z308.1-2021/2026)

16 Adhesive Bandage 1×3 in.

1 Adhesive Tape 2.5 yd. (Total)

10 Antibiotic Application 1/57 oz.

10 Antiseptic 1/57 oz.

1 Breathing Barrier

1 Burn Dressing (Gel Soaked) 4×4 in.

10 Burn Treatment 1/32 oz.

1 Cold Pack 4×5 in.

2 Eye Covering w/Means of Attachment 2.9 sq. in.

1 Eye/Skin Wash 1 fl. oz. (Total) Eye wash stations are needed in shop area per ANSI Z358.1-2014

1 First-Aid Guide (English and Spanish, new in 2026)

10 Hand Sanitizer 1/32 oz.

2 pairs Medical Exam Gloves

1 Roller Bandage 2 in. x 4 yd.

1 Scissors

2 Sterile Pads 3×3 in.

2 Trauma Pads 5×9 in.

1 Triangular Bandage 40x40x56 in.

1 Foil Blanket 52×84 in.

ANSI Standard Class B Kit (Class B kit has everything in a Class A kit and more)
The Class B kit adds a 4 in. x 4 yd. roller bandage, a splint, and a tourniquet to the list above, with larger quantities of most items (for example, 50 adhesive bandages, 4 pairs of exam gloves, and 4 fl. oz. of eye/skin wash).

Recommended Supplemental Supplies (Z308.1-2026): These are not part of the required minimum fill. Select based on your hazard assessment with your medical provider: 

• 2 naloxone nasal sprays in a separate, clearly labeled kit stored in plain view
• Bleeding-control supplies (chest seals, hemostatic and compression bandages)
• Anti-choking device

Types of First-Aid Kit Containers

• Type I containers are used in stationary indoor settings.  No rough handling. (Example: Auto dealership)
• Type II containers are used in portable indoor settings. No rough handling.
• Type III containers are used for mobile, indoor/outdoor settings.
• Type IV containers are used for portable use in outdoor settings where rough handling is a factor.

Class B: Class B kits may be needed for your facility if you encounter injuries beyond “common workplace injuries” such as:

• Deep lacerations from sheet metal, glass, and cutting tools
• Crush or pinch injuries from lifts, jacks, and falling components
• Thermal burns from exhaust, engines, and welding/cutting

Action Items Before 2027

• Replace or supplement first-aid guides with English/Spanish versions as kits are restocked.  Not mandated in California but good practice.
• Decide whether you will rely on the ANSI Class A list (a Class B kit also qualifies, since it contains everything in Class A) OR a physician/licensed health care professional selected list, and document the choice.
• Walk the facility (service, body shop, parts, detail, sales, offices) and confirm each kit is readily available, with no locked doors or obstacles during any shift, and that its location is posted.
• Inventory kits in service vans and parts trucks and set a restocking routine for mobile workers.
• Consider stocking naloxone now with your occupational clinic’s input.  You will need employee training on naloxone usage.
• If there is no infirmary, clinic, or hospital in near proximity, someone on site must be adequately trained to render first aid (e.g., an American Red Cross or equivalent course).

Employers who choose not to have first-aid kits violate the law and risk loss of productive time when employees must rush to the local drug store for a bandage every time they incur an injury.

Proposed Regulations on Naloxone in California. Assembly Bill 1976 (signed September 2024) directs Cal/OSHA to submit a rulemaking proposal to the Standards Board, on or before December 1, 2027, to revise 8 CCR §3400 to require naloxone hydrochloride or another FDA-approved opioid antagonist in workplace first-aid materials. The Board must consider the proposal for adoption on or before December 1, 2028. That rulemaking is still to come. The Board did not address naloxone in the §3400 overhaul it approved on September 17, 2026, and left it to the AB 1976 rulemaking. Until then, Cal/OSHA does not require naloxone in first-aid kits, although ANSI/ISEA Z308.1-2026 now recommends it as a supplemental item.

Automated External Defibrillator (AED) Standards: Under California H&S Code §19300, a dealership building must have an AED if it is a Group B (offices, F&I, service writing) or Group M (showroom, sales) building with an occupant load of 200 or more, and the building was either constructed on or after January 1, 2017, or, if older, underwent tenant improvements or renovations of $100,000 or more in one calendar year on or after January 1, 2020.  Occupant load is calculated per CBC §1004; verify it against the permit set. Some cities, such as San Diego have their own AED regulations; consult local requirements. 

Buildings that need an AED under §19300 and were built on or after January 1, 2024, or older buildings with $100,000 or more of tenant improvements or renovations in one calendar year after that date, must place at least six trauma kits in an easily accessible container next to the AED (H&S §19310). Inspect each trauma kit at least every three years and restock a kit after each use.

If you have an AED, California H&S Code §1797.196 requires you to:

• maintain and test it per the manufacturer’s guidelines, at least biannually and after each use;
• notify the local EMS agency of its location and type;
• offer an annual demonstration;
• post instructions in at least 14-point type next to the unit;
• Inspect the AED at least every 90 days for operability, such as a blinking light or signs of tampering;
• Keep records of maintenance and testing.

Ref: Information from www.osha.gov and www.dir.ca.gov, ISEA (www.safetyequipment.org), and industry summaries of ANSI/ISEA Z308.1-2026 were used to prepare this newsletter.  Readers should consult the published standard and the final OAL-approved text of 8 CCR §3400 for exact requirements. 

DISCLAIMER: The contents of this newsletter are for informational purposes only and are not to be considered legal advice. Employers must consult their lawyer for legal matters and EPA/OSHA consultants for matters related to Environmental, Health & Safety. The article was authored by Sam Celly of Celly Services, Inc. who has been helping automobile dealers comply with EPA and OSHA regulations for over 35 years. Sam is a Certified Safety Professional (No. 16515) certified by the Board of Certified Safety Professionals. Sam received his BE (1984) and MS (1986) in Chemical Engineering, followed by a J.D. from Southwestern University School of Law (1997). Sam is a member of the American Chemical Society (No. 31176063), American Industrial Hygiene Association (No. 124715), and National Association of Dealer Counsel (NADC). Sam also serves on the Board of Orange County American Industrial Hygiene Association and on CA Industrial Hygiene Council (CIHC). Our newsletters can be accessed at www.epaoshablog.com. We welcome your comments/questions. Please send them to sam@cellyservices.com.