OHS Act guide
First aiders and first aid boxes: the two thresholds people confuse
General Safety Regulation 3 sets one trigger for the box and a different, higher one for trained first aiders. This guide sets out both, the ratios, the box contents, and what changed on 5 December 2025. Position as at August 2026.
One regulation, four separate duties
General Safety Regulation 3 is short, and it is doing more work than most people realise. It contains a general duty, a box duty, a trained person duty and a signage duty, each with its own trigger.
Regulation 3(1) is the general one and it has no threshold at all: the employer must take all reasonable steps necessary in the circumstances to ensure that persons at work receive prompt first aid treatment in the event of injury or emergency. Everything below sits on top of that.
The thresholds
These count employees at the workplace.
| Trigger | What is required | Provision |
|---|---|---|
| Any workplace | All reasonable steps to ensure prompt first aid treatment | GSR 3(1) |
| More than 5 employees | A first aid box or boxes at or near the workplace, accessible to employees | GSR 3(2) |
| More than 10 employees | At least one person with a valid first aid certificate of competency readily available during normal working hours, for every group of up to 50 employees, or every group of up to 100 in a shop or office | GSR 3(4) |
| Hazardous substances handled | First aid persons trained specifically in the treatment and emergency procedures for those substances, plus eyewash and emergency deluge shower provisions | GSR 3(5) |
| Wherever a box exists | A prominent notice in a conspicuous place showing where the box is kept and the name of the person responsible for it | GSR 3(6) |
Readily available during normal working hours is the phrase that turns this into a rostering problem rather than a headcount problem. A single certificated person covering a day shift does not satisfy regulation 3(4) for a workplace that also runs an evening shift. Cover has to hold across the hours the workplace actually operates.
The commonly repeated summary, one first aider per 50 employees, drops both the more than 10 employees trigger and the separate group size of up to 100 for shops and offices. It also drops the availability requirement, which is the part inspectors test.
What has to be in the box
Regulation 3(3) requires the box to contain suitable first aid equipment, including at least the equipment listed in the Annexure to the regulations, selected with reference to the type of injuries likely to occur, the nature of the activities and the number of employees. Only the listed articles, equipment or similar medicine may be kept in the box.
The Annexure minimum includes wound cleaner or antiseptic, swabs, cotton wool, sterile gauze, forceps for splinters, scissors, safety pins, triangular and roller bandages in specified sizes, elastic and non allergenic adhesive, assorted adhesive dressing strips, first aid dressings in two sizes, straight splints, disposable gloves in two sizes, and CPR mouth pieces or similar devices. For shops and offices the quantities of several listed items may be reduced by half.
The Annexure is a floor, not a ceiling. Regulation 3(3) requires selection with reference to the injuries likely to occur, so a workplace with a chemical, mechanical or heat hazard profile is expected to hold more than the Annexure list. The regulation sets no inspection interval for the box, so the interval comes from the employer risk assessment under section 8(2)(d). Items expire and get used, which is a practical argument for a short cycle.
General Safety Regulation 3(3) and the AnnexureCertificate validity, and what actually changed in December 2025
Regulation 3(4) requires a valid certificate of competency in first aid issued by an organisation approved by the chief inspector for that purpose. It does not state a validity period. That is worth saying plainly, because the widely quoted three year validity is not in the regulation.
The three year currency comes from the qualification and the accredited training provider, under the framework in Department of Labour notice R.1463 of 2017, which requires a training organisation to hold accreditation from the Quality Assurance Body to which the Quality Council for Trades and Occupations has delegated quality assurance for first aid, before it can be considered for approval. So three years is an industry and qualification norm rather than an OHS Act requirement.
On 5 December 2025, General Safety Regulation 3(4) was amended so that the certificate must come from an organisation approved by the chief inspector, with the previously named issuing bodies removed from the wording. The practical consequence for an employer is to confirm that a training provider is currently approved, rather than relying on its historical standing.
GSR 3(4) as amended 5 December 2025, notice R.1463 of 2017Questions about workplace first aid
How many first aiders does my workplace need?
General Safety Regulation 3(4) applies where more than 10 employees are employed, and then requires at least one person with a valid first aid certificate of competency readily available during normal working hours for every group of up to 50 employees, or every group of up to 100 employees in the case of a shop or office. Because the requirement is availability during working hours, cover has to hold across shifts rather than just on paper.
Do we need a first aid box if we only have four employees?
Regulation 3(2) is triggered by more than 5 employees, so with four employees that specific duty is not triggered. Regulation 3(1) still applies: the employer must take all reasonable steps necessary in the circumstances to ensure persons at work receive prompt first aid treatment. For most workplaces the reasonable step that satisfies regulation 3(1) is a stocked first aid box, so small employers commonly provide one regardless.
How long is a first aid certificate valid for?
General Safety Regulation 3(4) requires a valid certificate of competency issued by an organisation approved by the chief inspector, and it does not state a validity period. The three year currency that is widely quoted comes from the qualification and the accredited provider under the QCTO framework referenced in notice R.1463 of 2017, not from the regulation itself. It should be described as a qualification norm rather than a statutory rule.
Who is allowed to issue a first aid certificate?
Regulation 3(4) requires the certificate to come from an organisation approved by the chief inspector for that purpose. Notice R.1463 of 2017 requires an applicant organisation to hold valid accreditation from the Quality Assurance Body to which the QCTO has delegated quality assurance for first aid before it can be considered for approval. The regulation was amended on 5 December 2025 to remove the historically named bodies from the wording, so confirm that your provider is currently approved.
Can the first aider also be the health and safety representative?
Nothing in the Act or the regulations prevents the same person holding more than one role, and in a small workplace that is common. The practical caution is capacity and conflict: the health and safety representative function under section 18 includes examining the causes of incidents, and there is an obvious awkwardness where the same person also provided the first aid treatment being examined. Each role also carries its own competence and record requirements, which still have to be met separately.
Certificates that expire quietly, caught early
The GRC Shop OHS app links each first aid appointment to the certificate that supports it, drops the seat when the certificate lapses, and shows the shortfall per site rather than per company.
This guide is general information about published law, stated as at August 2026. It is not legal advice and GRC Shop is not a law firm. Confirm any provision against the current Act or gazetted regulation before acting.