Written and maintained by CASRAI Editorial Board
Last updated
General product and regulatory information only, not medical advice. It does not replace your own safety officer, occupational-health provider or the current text of the rules cited below.
Purpose and who this is for
This guide is for a workplace buyer, safety coordinator or facilities manager who has to pick a first aid kit supplier and wants to know which rule creates the duty, what a supplier should be able to document, and what the supplier’s regulatory status does and does not tell you. It does not rank suppliers or quote prices. For the contents of a kit, see what is inside a first aid kit.
Which rule applies to your workplace
Start with the rule, because it decides what a supplier’s kit must let you do. In general industry, 29 CFR 1910.151(b) says that where no infirmary, clinic or hospital is in near proximity for treating all injured employees, a person or persons must be adequately trained to render first aid, and that “Adequate first aid supplies shall be readily available.” The regulation page lists no contents and no quantities (OSHA, checked 2026-11-01).
On construction sites, 29 CFR 1926.50(d) is more specific: supplies must be easily accessible, the kit contents placed in a weatherproof container with individual sealed packages for each type of item, and checked before each job and at least weekly thereafter (OSHA, checked 2026-11-01). See construction site first aid station requirements for the full set of subsections.
Supplier checklist: what to ask, tied to the text
The table turns the rule wording into questions to put to any supplier. The questions are editorial interpretation of the cited text, not requirements written into the regulations.
| Question for the supplier | Why it matters | Rule text it follows |
|---|---|---|
| Which rule or standard was the kit assembled for (general industry, construction, or a voluntary standard)? | 1910.151(b) sets no contents list, so a claim that a kit is “OSHA compliant” needs a stated basis. | 1910.151(b): “Adequate first aid supplies shall be readily available.” |
| Is the container weatherproof and are the items individually sealed? | This is the wording for construction work. | 1926.50(d) |
| Can individual items be re-ordered after each weekly check? | Pre-job and weekly checks mean you will need to replace items between full-kit orders. | 1926.50(d): checked before each job and at least weekly |
| Is an itemised contents list supplied with the kit? | It lets the person doing the check compare the kit against a list. Read the list against the contents checklist and your own site needs. | Editorial interpretation of 1926.50(d) |
| If the kit cites a voluntary standard such as ANSI/ISEA Z308.1, which edition is printed on the label? | Editions change; the label and the standard’s publisher (ISEA/ANSI) are the places to confirm current text. OSHA’s 1910.151 page does not itself list a contents standard. | Editorial interpretation |
Manufacturer, distributor or retailer
The FDA states that owners and operators of establishments that produce or distribute devices for use in the United States must register annually and generally list their devices (FDA device registration and listing page, checked 2026-11-01). That does not mean every seller appears in the registration database. 21 CFR 807.65 exempts several kinds of business from establishment registration, including retail establishments making final delivery or sale to the ultimate user (paragraph e), carriers (paragraph h), makers of raw materials or components (paragraph a) and general-purpose items not labeled or promoted for medical use (paragraph c). Paragraphs (d), (e), (f) and (i) apply only to entities located in a US State (Cornell LII, checked 2026-11-01).
How do I confirm a supplier is legitimate?
Ask for the documents in the table above and check that what is delivered matches them. A distributor or retailer that is absent from FDA’s registration database is not, on that fact alone, evidence of non-compliance, because 21 CFR 807.65 exempts some of them. For a wider vendor file, see vendor onboarding documentation.
What is the difference between a manufacturer and a distributor?
For this purpose, a manufacturer produces the devices and is the party the FDA registration and listing requirement is aimed at; a distributor or retailer resells them and may fall under a 21 CFR 807.65 exemption depending on what it does. Which category a supplier falls into is a question to put to the supplier in writing.
Which certificates and registrations can I check independently?
The OSHA and CFR texts above are public and can be read directly. Whether a given business has registered with FDA is a question about that business; the exemptions in 21 CFR 807.65 mean a missing entry needs an explanation, not an automatic rejection.
What varies by facility type
Construction work carries the explicit weatherproofing, sealed-package and weekly-check wording; general industry under 1910.151(b) carries the broader “readily available” standard together with the near-proximity clinic test. Organisations buying across many sites may also route first aid kits through supply-chain and procurement channels; for label checks on larger orders see bulk medical supplies.
Storage, expiry and restocking
1926.50(d) sets the checking cadence for construction: before each job and at least weekly. Neither rule page sets an expiry schedule, so use the dates printed on the individual items and the supplier’s replacement documentation. Cabinet, bag and box options are covered in first aid kit wall mounts and cabinets.
FAQ
What should be in a first aid kit?
1910.151(b) requires “adequate first aid supplies” to be readily available but the regulation page lists no contents. A practical list by category is in what is inside a first aid kit; the same answer covers “what should be inside the first aid kit”, “what should a first aid kit contain” and “what should you have in a first aid kit”.
Is a first aid kit supplier regulated?
Producers and distributors of devices for US use are covered by FDA registration and listing, subject to the exemptions in 21 CFR 807.65. Retail establishments making final sale to the ultimate user are one exempt group.
Sources
- OSHA, 29 CFR 1910.151, Medical services and first aid: osha.gov (checked 2026-11-01).
- OSHA, 29 CFR 1926.50, Medical services and first aid: osha.gov (checked 2026-11-01).
- 21 CFR 807.65, Exemptions for device establishments: Cornell LII (checked 2026-11-01).
- FDA, Device Registration and Listing: fda.gov (checked 2026-11-01).
