Does Cal/OSHA Require CPR Training? What California Employers Need to Know
By 212 Safety, LLC | September 28, 2026
Most California employers know they need a first aid kit at the worksite. Far fewer can answer a harder question: if a worker collapses on your job right now, is there someone on-site who is trained and currently certified to perform CPR?
If the answer is "I'm not sure" or "we had a guy, but he left," you have a gap that Cal/OSHA can cite — and that could cost a life.
First aid and CPR requirements in California are more layered than most employers realize. The rules differ by industry, and some of the most commonly cited guidance online actually applies only to shipbuilding — not to construction or general industry. This article covers what the regulations actually say, which employers are affected, and where real citations have been issued.
The Two Standards That Cover Most Employers
California's first aid requirements for most employers come from two sections of Title 8 of the California Code of Regulations:
Section 3400 — Medical Services and First Aid (General Industry Safety Orders)
This standard applies to general industry employers — manufacturing, warehousing, offices, retail, restaurants, and most other non-construction workplaces. It requires three things:
The employer must ensure the ready availability of medical personnel for advice and consultation on matters of occupational health or injury.
In the absence of an infirmary, clinic, or hospital in near proximity to the workplace, a person or persons must be adequately trained to render first aid. Training must be equal to that of the American Red Cross or the Mine Safety and Health Administration.
Adequate first aid materials, approved by the consulting physician, must be readily available for employees on every job.
Section 1512 — Emergency Medical Services (Construction Safety Orders)
This standard applies to construction employers and adds requirements beyond Section 3400:
Each employer on a construction project must ensure the availability of a suitable number of appropriately trained persons to render first aid.
Every employer must provide at least one first aid kit in a weatherproof container, with contents inspected regularly and expended items promptly replaced.
The employer must have a written plan to provide emergency medical services.
Effective provisions must be made in advance for prompt medical treatment in the event of serious injury or illness.
Each employer must inform all employees of the procedure to follow in case of injury or illness.
The key phrase both standards share: "in the absence of an infirmary, clinic, or hospital in near proximity." Most construction sites, agricultural operations, remote facilities, and many industrial workplaces don't have a hospital next door. For those employers, having trained first aid personnel on-site isn't optional — it's the law.
Where CPR Is Explicitly Required
Neither Section 3400 nor Section 1512 uses the word "CPR" in the regulatory text. But several industry-specific Cal/OSHA standards go further and explicitly mandate CPR training:
Electrical Workers — Section 2940.10
When employees perform work on or near exposed lines or equipment energized at 50 volts or more, persons trained in first aid including CPR must be available. For field work involving two or more employees, at least two CPR-trained persons must be present. New employees must be trained in first aid and CPR within three months of their hire date.
This standard applies to power generation, transmission, and distribution work — including utility crews, electrical contractors, and line-clearance tree trimmers.
High-Voltage Work — Section 2941
Workers performing rubber-glove work on primary conductors or equipment energized above 7,500 volts from an aerial lift must have a qualified person on the ground who is trained in first aid, CPR, radio procedures, and rescue techniques.
Logging and Sawmills — Section 6251
Employers at fixed sawmill facilities must maintain personnel certified to provide first aid and CPR so that these services are readily available. Certification must follow the standards of the American Heart Association, the American Red Cross, or another nationally recognized agency.
Residential Care Facilities — Section 3421(m)
Employers must provide training in first aid and CPR. For field work involving two or more employees, at least two trained persons must be available. All new employees must be trained in first aid and CPR within 90 days of their hire date. Training must be performed by a certified instructor and must be equal to that of the American Red Cross or MSHA.
The IIPP must identify the person or persons with authority and responsibility for implementing and maintaining the program. This cannot be vague. "Management is responsible for safety" doesn't satisfy the standard. The program must name a specific individual who has the authority to act — including the authority to stop work and commit resources to correct hazards.
Real Citations: What Happens When Employers Fall Short
Pollock Pines, California — Inspection No. 1633708 (Decision September 1, 2026)
In a case decided by the Cal/OSHA Appeals Board in September 2026, an employer in Pollock Pines was cited under Section 3421(m) for failing to ensure that employees were trained in first aid and CPR within 90 days of their hire dates. The ALJ affirmed the citation.
First Aid Kit Physician Approval — Statewide Enforcement Trend
Cal/OSHA has increased citations under Section 3400(c) for employers whose first aid kits lack approval by a consulting physician. While many employers purchase kits that comply with federal OSHA requirements, California's standard is more specific — the contents must be approved by a physician. Cal/OSHA has argued that the hazard includes the risk of unauthorized drugs or personal medications being placed in kits without physician oversight.
This is a citation that catches even well-intentioned employers off guard. Having a well-stocked first aid kit is not enough if there is no documented physician approval on file.
What "Adequately Trained" Means in Practice
Sections 3400 and 1512 don't spell out "CPR" by name for most employers. But Cal/OSHA enforcement and standard industry practice both treat CPR-trained first aid responders as the practical way to meet the "adequately trained" standard — particularly in workplaces where:
The nearest clinic or hospital isn't genuinely close by
Work involves machinery, heights, electrical hazards, confined spaces, or chemical exposure
Employees work outdoors in California heat
The site runs multiple shifts, including nights and weekends, when medical facility access may be limited
In practice, an employer who provides only bandage-level first aid training — without CPR — and then has an employee experience cardiac arrest on the job is going to have a very difficult time arguing they met the "adequately trained" standard. CPR training through the American Red Cross or American Heart Association is the documented, defensible way to demonstrate compliance.
Proposed Changes: Sections 1512 and 3400 Are Being Updated
On January 15, 2026, the Cal/OSHA Standards Board held a public hearing on proposed revisions to both Section 1512 and Section 3400. The most significant changes would align first aid kit content requirements with the ANSI/ISEA Z308.1-2021 standard, modernizing the required supplies and simplifying compliance for employers.
The proposed revisions to Section 1512 also reference CPR in the mandatory first aid guide (Appendix A), which would include performing CPR and using an AED as required knowledge for appropriately trained persons. While this is part of the first aid guide content — not a standalone CPR mandate for every workplace — it signals the direction Cal/OSHA is moving: toward an expectation that first aid readiness includes CPR and AED competency.
The Compliance Checklist
Trained Personnel
At least one person adequately trained in first aid available during all work hours
Training equal to American Red Cross, American Heart Association, or MSHA standards
CPR training included (mandatory for electrical workers, logging, residential care; strongly recommended for all)
Certifications current — Red Cross and AHA cards are valid for two years with no grace period after expiration
Coverage planned for all shifts, including nights and weekends
First Aid Supplies
First aid kit readily available at every worksite
Kit contents approved by a consulting physician (California-specific requirement under Section 3400(c))
Kit inspected regularly and expended items promptly replaced
Construction sites: weatherproof container (Section 1512)
Documentation
Training records maintained — employee names, training dates, type of training, certifying organization
Physician approval of first aid kit contents on file
Written emergency medical services plan in place (Section 1512 for construction)
First aid procedures integrated into your IIPP
Communication
All employees informed of the procedure to follow in case of injury or illness
Employees know who the trained first aid responders are on each shift
Emergency phone numbers and facility locations posted at the worksite
212 Safety Delivers CPR and First Aid Training
212 Safety is a Licensed Training Provider for the American Red Cross and a Health & Safety Institute (HSI) Training Center. We provide on-site group training for construction and industrial employers throughout the Central Valley and across California — in both English and Spanish. Whether you need to certify your entire crew or bring a few employees current, we bring the training to your worksite.
Call or text (661) 865-8804 to schedule a consultation, or book a call online.
212 Safety, LLC is a veteran-owned, California Certified DVBE and Small Business (Micro) occupational safety training and consulting company based in Bakersfield, CA. We serve construction and industrial employers throughout California with Cal/OSHA compliance support, safety program development, respirator fit testing, forklift certification, and CPR/First Aid training.
