Your first aid needs assessment is the legal starting point
General information for UK hospitality operators, not legal advice. If something here is wrong or out of date, the editorial policy explains how to report it.
GB law sets no ratio of first aiders to staff, so a first aid needs assessment is what decides the cover a hospitality venue must provide.
A first aid needs assessment is the exercise that decides how much first aid cover a venue has to provide, because the Health and Safety (First-Aid) Regulations 1981 set no ratio of first aiders to staff. HSE states plainly that there are no hard and fast rules on exact numbers, so the assessment is what turns a general duty into a specific answer about who is trained, on which shifts, and what kit sits within reach of the pass.
The Regulations require provision that is adequate and appropriate in the circumstances, meaning sufficient equipment, facilities and personnel at all times. They apply in Great Britain, so operators in Northern Ireland work to the equivalent provision enforced there; HSE recognises First Aid at Work and Emergency First Aid at Work certificates from HSE Northern Ireland approved providers as equivalent to the Great Britain qualifications of the same name. The assessment is also the first document an inspector asks for after an injury, since it shows whether the cover in place that night was a considered decision or a guess made after the event.
What a first aid needs assessment actually has to cover
HSE's guidance on what employers must do on first aid lists the factors to weigh: the nature of the work, workplace hazards and risks, the nature and size of the workforce, the work patterns of staff, holiday and other absences of those who will be first aiders or appointed persons, and the organisation's own history of accidents or incidents. A second group follows: travelling, remote and lone workers, how the workforce is distributed, how remote a site is from emergency medical services, whether staff work on shared or multi-occupancy sites, and provision for non-employees such as members of the public.
Read against a hospitality site, those factors stop being abstract. Workplace hazards means hot oil, open flame, steam, knives, glass and wet floors, alongside the cleaning chemicals already covered under COSHH. Work patterns means split shifts, late finishes and the hour at either end of the day when one person is alone in the building. Holiday and other absences is the factor most often skipped, because a rota with exactly one trained first aider has no cover at all for a fortnight in August. Remoteness from emergency medical services is not only a rural question, since a first-floor function room reached by a narrow stair slows an ambulance crew down.
Why a commercial kitchen is not a low-hazard workplace
HSE's position is that some small, low-risk workplaces need nothing more than a first aid kit and a person appointed to take charge of the arrangements, while a workplace with more significant health and safety risks, such as one using machinery or hazardous materials, is more likely to need a trained first aider. The table below sets out what the guidance says follows from each finding, rather than any fixed staffing ratio.
| What your assessment concludes | What HSE says the provision should be |
|---|---|
| No trained first aider is required | A suitably stocked first aid kit, an appointed person to take charge of the arrangements, and information for all employees about those arrangements |
| Workplace or workforce issues, or more significant health and safety risks | A sufficient number of appropriately trained first aiders, and possibly additional equipment and facilities |
| Larger premises, or higher hazards present | A first aid room, where the assessment identifies that one is needed |
| More than 10 employees | An accident book, required under social security law |
The case that trips people up is the small, higher-hazard site. Fewer than five employees in a higher-hazard workplace does not automatically mean at least one qualified first aider, because the minimum in HSE guidance is still an appointed person; it is the assessment that decides whether trained first aiders are needed on top of that. For most kitchens the honest conclusion will be that they are, since burns, scalds and deep lacerations are foreseeable and time critical, and a delay of minutes changes the outcome for the person hurt. That conclusion still has to be reached and recorded rather than assumed from a row in a table, and it has to hold for every shift the building is open.
Appointed person or first aider: the two are not interchangeable
An appointed person takes charge in an emergency, looks after the equipment and facilities and calls the emergency services when required, and is not required to have any formal training. They can also provide emergency cover, within their role and competence, where a first aider is absent for unforeseen reasons, and HSE is specific that annual leave does not count as unforeseen. Using the title loosely for somebody who has done neither role properly is the gap the assessment exists to close.
A first aider holds a valid certificate of competence in First Aid at Work or Emergency First Aid at Work. HSE's first aid questions and answers refer to the three-day FAW course and the one-day EFAW course. HSE's guidance on what a first-aider is states that certificates for the purposes of first aid at work last for three years, that a requalification course is needed before expiry, and that once a certificate has expired the holder is no longer considered competent to act as a workplace first aider. Annual refresher training is not mandatory but is strongly recommended. Since 1 October 2013 HSE no longer approves first aid training, qualifications or training organisations, so checking that a provider is competent is the employer's job rather than something a logo on the certificate settles.
Kit that matches the risk, not a generic box off a shelf
There is no legally fixed list of first aid box contents. HSE publishes a suggested minimum stock for low-hazard work and notes that employers may wish to refer to British Standard BS 8599-1, adding that whichever route you take the contents should reflect the outcome of the needs assessment. It also recommends that you do not keep tablets and medicines in the first aid box, which matters in a trade where somebody will always offer a painkiller for a burn.
A kitchen assessment usually adds blue detectable plasters, burn dressings and an eyewash provision wherever chemicals are in use. Where mains tap water is not readily available for eye irrigation, HSE advises providing at least one litre of sterile water or sterile normal saline in sealed, disposable containers, which are not kept for reuse once the seal is broken. There is no set review timetable for restocking, but sterile items carry expiry dates and should be replaced by them, and kits should be restocked soon after any use. That is where most venues fail, because a box is raided in an emergency and never refilled by accident, so the gap in the burn dressings stays invisible until it matters.
Records that outlast the incident itself
Recording matters as much as the treatment. If you have more than 10 employees you must keep an accident book under social security law, though the entries may equally sit in your own record system, and personal details must be stored confidentially in a secure place. HSE separately suggests giving first aiders and appointed persons a book in which to record the incidents they attend, and is clear that this record book is not the same thing as the statutory accident book; its value is that patterns in minor injuries feed straight back into the next assessment.
Anything meeting the criteria under RIDDOR carries its own reporting duty, and regulation 12 of RIDDOR 2013 requires the responsible person to keep a record of reportable injuries and occurrences, with each entry kept for at least three years from the date it was made. Checking reportability at the point of injury with a RIDDOR reportability checker settles the question while the detail is fresh, and the thresholds are set out in our guide to RIDDOR accident reporting in hospitality. A personal injury claim can land long after the shift everyone has forgotten, and by then the record is the only surviving account of what happened.
Extending provision to customers and lone workers
The Health and Safety (First-Aid) Regulations 1981 do not require an employer to provide first aid for members of the public, but HSE strongly recommends including them in the needs assessment and making provision for them. For a venue that seats a hundred strangers and serves alcohol, a choking incident or a collapse at a table is not a risk that can reasonably be excluded from planning. The same logic covers travelling and lone workers, where the assessment should decide whether personal first aid kits and a means of raising the alarm are needed for anyone working away from the main site or cashing up alone at midnight.
Provision sized only for the busiest hour of service, with nothing behind it for the quiet hours at either end of the day, is not a complete assessment whatever the Regulations technically demand. Holding first aid alongside the COSHH and risk assessment records you already keep puts the chemical hazards, the venue risk assessments and the first aid arrangements in one place instead of three folders nobody cross-checks, and the practical detail on the COSHH side is set out in our guide to COSHH and risk assessments in hospitality.
Doing this without the paperwork
Zynthio's COSHH and risk assessment module holds every substance on site with its hazards, PPE, storage, disposal and first aid procedures, and attaches the safety data sheet with an expiry date so an expired sheet counts alongside a missing one. Venue risk assessments are scored on a 5 by 5 matrix, signed off, and dated for review, from templates by category including kitchen and fire that carry suggested hazards, controls and the legal basis. Accident and near-miss entries sit in a separate accident book module that records the injured person, witnesses, first aid and hospital treatment, days absent and the RIDDOR reportable flag, and keeps entries for three years. One honest limit: due and overdue states are shown on the dashboard rather than pushed at you, so opening it has to be part of the weekly routine.
Frequently asked questions
How many first aiders does a small pub actually need?
There is no fixed number in law. The Health and Safety (First-Aid) Regulations 1981 require provision that is adequate and appropriate in the circumstances, and HSE says there are no hard and fast rules on exact numbers. Your own first aid needs assessment decides it, weighing the hazards on site, the size and work patterns of the workforce, the layout of the building and how far you sit from emergency medical services.
How long does a first aid certificate last?
HSE guidance states that certificates for the purposes of first aid at work last for three years, and that a requalification course is needed before expiry. Once a certificate has expired the holder is no longer considered competent to act as a workplace first aider. Annual refresher training is not mandatory, but HSE strongly recommends it so that skills stay current between renewals.
Can a first aid box contain paracetamol or other medication?
HSE recommends that you do not keep tablets and medicines in the first aid box. There is no legally fixed contents list. HSE publishes a suggested minimum stock for low-hazard work and notes that employers may wish to refer to BS 8599-1, with the contents reflecting the outcome of the needs assessment either way.
Does the needs assessment have to be written down?
HSE says you do not need to record the findings, but that you may find it useful to do so because it demonstrates how you decided on the provision you make. In practice an inspector looking into an injury will ask how the decision was reached, and a written assessment is the fastest way to answer that without relying on memory.
Should first aid provision cover customers as well as staff?
The Regulations do not require employers to provide first aid for members of the public. HSE strongly recommends that employers include the public in the first aid needs assessment and make provision for them, which for a venue serving food and alcohol to a room full of strangers is the sensible reading of the duty.