Health and Safety (First-Aid) Regulations 1981, UK wide
First Aid Needs Assessments
The law does not tell you how many first aiders to have. It tells you to work it out and to be able to explain your answer if someone is hurt. AL23 Safety carries out that assessment and documents the reasoning behind it, for employers UK wide.
What is a first aid needs assessment?
The document that turns a legal test into a number you can defend
Regulation 3(1) of the Health and Safety (First-Aid) Regulations 1981 requires equipment and facilities that are adequate and appropriate in the circumstances. Regulation 3(2) requires such number of suitable persons as is adequate and appropriate. Everything hinges on those two words. The needs assessment establishes what they mean for your workplace, then evidences it.
This is an advisory service, not a course. We assess what you need, size the provision and write the justification. The EFAW and FAW courses themselves and mental health awareness training, sit with our health and safety training team.
Who needs one
Every employer, at any size, including the ones who think the answer is obvious
- Any employer, since regulation 3 has no lower threshold. A business with one employee still has to reach a conclusion.
- Organisations that have grown, moved, restructured shifts or opened a second site since the last assessment.
- Multi-occupancy buildings where cover is quietly assumed to come from another tenant.
- Employers with travelling, remote or lone workers, whose provision cannot simply be a kit on a wall.
- Higher hazard operations with machinery, hazardous substances, work at height or confined spaces.
- Schools, care settings, leisure and retail, where the population on the premises far exceeds the payroll.
- Anyone whose first aiders have let certificates lapse or whose rota leaves shifts uncovered.
- Employers asked by a client or insurer to produce the assessment rather than the certificates.
The regulations that apply
Your legal framework, in plain terms
The Health and Safety (First-Aid) Regulations 1981, SI 1981/917, are the whole of the specific duty. They were amended in 2002 and again by SI 2013/1512, which removed the requirement for HSE to approve first aid training providers with effect from 1 October 2013. The supporting publication is L74, "First aid at work. The Health and Safety (First-Aid) Regulations 1981", third edition published in 2013 with amendments in 2018 and 2024. The 2018 amendment added guidance on automated external defibrillators. The 2024 amendment added employers' responsibilities to take account of employees' mental health in the needs assessment. One honest note on status. The document is published as "Guidance on Regulations", which indicates the Approved Code of Practice element was removed at the third edition, though many secondary sources still call L74 an ACOP. We check the current HSE product page before describing its status in your documents.
Regulation 3(1)
Adequate and appropriate equipment and facilities for first aid to be rendered to your employees.
Regulation 3(2) and 3(4)
Such number of suitable persons as is adequate and appropriate. An appointed person may be enough where the nature of the undertaking, the number of employees and the location of the establishment make that adequate instead.
Regulation 3(3)
Cover for the temporary and exceptional absence of a suitable person.
Regulation 4
A duty on the self-employed to provide adequate and appropriate equipment for rendering first aid to themselves at work.
Regulation 5
Inform employees of the arrangements, including where the equipment, facilities and people are.
One important limit
The Regulations do not require you to provide first aid for anyone other than your own employees. HSE strongly recommends including members of the public, pupils, patients, residents and customers in the assessment. That recommendation is guidance rather than law. Section 3 of the Health and Safety at Work etc. Act 1974 and sector-specific duties will often bring non-employees back into scope by another route. A visitor attraction that plans only for its staff has misread the position.
There are no fixed numbers in law
The ratio table you are looking for does not exist any more
HSE states that there are no hard and fast rules on exact numbers and that what is adequate and appropriate depends on the circumstances. The prescriptive ratio tables in earlier editions of the guidance have gone. The indicative table in the companion leaflet INDG214 is a starting point, not a legal minimum.
The consequence is worth stating plainly. An employer with ten first aiders and no assessment is in a weaker position than one with two first aiders and a documented, reasoned assessment. There is no express duty to record it, unlike regulation 3(6) of the Management of Health and Safety at Work Regulations 1999. HSE recommends recording it. In practice an unrecorded assessment cannot be defended after an incident.
What we assess
Every factor HSE expects you to weigh
- The nature of the work and the specific hazards present, from machinery and hazardous substances through to work at height and vehicle movements.
- The size, distribution and mix of the workforce, including how far apart people actually are during the day.
- Work patterns, shift working and out of hours activity, where the daytime cover disappears.
- Your accident and ill health history, including near misses and injuries that were treated informally.
- Travelling, remote and lone workers, including whether they need a personal kit and a reliable means of summoning help, which links to our lone worker risk assessments.
- Employees at sites occupied by other employers, including whether shared arrangements are agreed in writing rather than assumed.
- Annual leave, sickness, turnover and training absence, plus how cover holds when two first aiders are away together.
- Provision for non-employees, including visitors, contractors, pupils, patients and members of the public.
- Distance from emergency medical services, ambulance access and whether a stretcher can reach the casualty.
- Employees with disabilities or particular health conditions, handled confidentially.
- Multi-occupancy buildings, including who holds the kit and who responds in common parts.
- Mental health of employees, brought expressly into the assessment by the 2024 amendment to L74.
- Whether a first aid room is warranted, which HSE indicates for larger premises and higher hazard environments, plus any specialist provision your hazards demand such as eyewash for chemical splash, burns dressings or cyanide antidote kits.
Appointed person or first aider
Two different roles and the assessment decides which you need
An appointed person takes charge when someone is injured or ill, looks after the equipment and calls the emergency services. No formal first aid training is required, though emergency first aid training is good practice. An appointed person must not attempt treatment they have not been trained to give.
A first aider has been trained by a competent provider and holds a valid certificate. Where the assessment identifies significant risks, such as machinery, hazardous substances, work at height or a large dispersed workforce, trained first aiders are the answer instead.
The statutory floor in any workplace is a suitably stocked first aid kit, an appointed person to take charge of the arrangements and information for all employees about those arrangements. Everything above that floor comes from your assessment.
Training, certificates and refreshers
Course length, validity and staying current
Emergency First Aid at Work runs to at least six hours over a minimum of one day. First Aid at Work runs to at least 18 hours over a minimum of three days. Both certificates are valid for three years. Requalification must be completed before or on expiry, since an expired certificate means the person is no longer a qualified first aider.
HSE strongly recommends annual refresher training of about half a day during the three-year period. It is a recommendation rather than a legal requirement and HSE says so directly. We still advise it, since skills fade and the refresher is where a rusty first aider finds out.
Since 1 October 2013 HSE no longer approves training providers. The due diligence sits with you. Acceptable routes include a provider working to a qualification regulated by Ofqual, SQA Accreditation or Qualifications Wales. A provider accredited by a voluntary aid society or a recognised trade body also qualifies, as does an independent provider you have assessed yourself. Defibrillator use is now an integral part of both syllabuses.
Mental health and defibrillators
Two areas where the marketing runs well ahead of the law
There is no legal requirement to have a mental health first aider. What the law now requires, following the 2024 amendment to L74, is that you take account of employees' mental health in the first aid needs assessment. HSE says mental health first aid may be beneficial depending on workplace needs. It endorses no particular course, syllabus or provider. HSE's stated priority is prevention at source, which means the duty that matters most is the risk assessment covered by our stress risk assessments service. Appointing mental health first aiders does not discharge it. They are a support measure rather than a control measure.
Health and safety law does not require a defibrillator either. Where you choose to provide one, HSE expects the manufacturer's written instructions to be available, training to be considered and siting that allows the unit to be reached and returned within the survival window. It should be signed to the standard symbol and maintained, with pad expiry and battery checks. Registering it on The Circuit, the national defibrillator network, is free and lets ambulance services direct callers to it. Some sport and leisure governing bodies require AEDs as a condition of affiliation. Those requirements are contractual rather than statutory.
Our process
Gather, walk the site, then size it
- 01
Gather
We collect headcount by location and shift, the accident record, the current provision and your certificates.
- 02
Walk the site
We look at distances, ambulance access, hazard concentrations and where the kits and any AED actually are.
- 03
Assess
We work through HSE's factors in turn and record the reasoning for each, including those that did not apply.
- 04
Size the provision
We set the number of first aiders and appointed persons by location and shift, the kit contents and the cover arrangements for absence.
- 05
Document and review
We issue the written assessment with the review triggers, then support the training plan and the annual re-check.
What you get
A reasoned assessment and a provision schedule
- A written needs assessment recording every HSE factor considered and the conclusion reached on each.
- A provision schedule by site and shift, naming the number of first aiders, appointed persons and their required certificate level.
- A kit specification covering location, contents, restocking owner and any specialist items.
- An arrangements notice for display under regulation 5, naming the first aiders and the equipment locations.
- A training plan with certificate expiry dates and a requalification calendar so nobody lapses unnoticed.
- A review schedule with named triggers, including any change of process, premises or workforce and any reportable accident.
What we need from you
Headcount, accident records and current cover
- Headcount by site, shift and department, including contractors and agency staff.
- Your accident book and any RIDDOR reports for the last three years.
- The current list of first aiders and appointed persons with certificate dates.
- Kit locations, first aid room, AED and any shared arrangements with other tenants, plus details of ambulance access on large or restricted sites.
Why AL23 Safety
The number, with the reasoning behind it
Accountable
If your provision is thinner than your risk, we say the number rather than recommend a review. If it is generous, we say that too.
Reasoned, not templated
The value is in the justification. A page carrying a headcount and a number is not an assessment.
Clear about what is law
Mental health first aiders and defibrillators are not legal requirements. We separate the duty from the good idea so you can budget honestly.
UK wide
We assess first aid provision across the UK, in offices, factories, care settings, schools and field-based operations. We hand the training over cleanly to the right course.
Not sure whether your numbers would stand up
The question is never the number. It is the reasoning behind it
Tell us your headcount, your shifts and your hazards. We will tell you whether your current provision looks defensible and what an assessment would involve.
Common questions
Answers, up front
Cannot see your question? Get in touch and we will answer it directly.
Contact usThere is no legal number. HSE states there are no hard and fast rules on exact numbers, since what is adequate and appropriate depends on the circumstances. The tables circulating online, including the indicative one in INDG214, are starting points rather than minimums. The legal test is whether you carried out an assessment and reached a reasonable conclusion.
There is no express duty to record it, unlike the risk assessment duty under regulation 3(6) of the Management of Health and Safety at Work Regulations 1999. HSE recommends recording it. Our view is blunter. An unrecorded assessment is indistinguishable from no assessment once an inspector or a claimant solicitor asks.
Not as a matter of the 1981 Regulations, which cover your employees only. HSE strongly recommends including non-employees in the assessment. Section 3 of the Health and Safety at Work etc. Act 1974 will often require it in practice. If members of the public are on your premises in numbers, planning only for staff is a decision you would struggle to defend.
No. HSE strongly recommends annual refresher training of around half a day during the three-year certificate period. Its own guidance answers the question of whether it is required with a plain "no". We recommend it anyway. Certificate validity is three years for both EFAW and FAW. Requalification must happen before expiry or the person stops being a qualified first aider.
The drivers are the number of sites, the number of shifts and the hazard profile. A single office is a short piece of work. A manufacturing group with four plants and a night shift is a larger exercise. Most single-site assessments are issued within a week of the visit. Where first aid sits inside a wider retainer, it is normally covered by the retained hours.
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