Health and Safety
Executive / Commission
Regulatory Impact Assessments: Offshore
Under the Health and Safety (First-Aid) Regulations 1981, employers are required to carry out an assessment of their first aid needs. Where they provide first aiders, those first aiders require a valid certificate in first aid at work (FAW) issued by an HSE approved training organisation. The FAW training course is run over four days. Every three years, first aiders need to undertake a two day FAW requalification course to obtain a new certificate.
HSE commissioned research has highlighted the following:
The research concluded that given the trend in UK industry towards an expanding service sector with a lower risk base, the proportionality of first aid resource in workplaces is an issue. The current FAW training regime is not considered as offering first aid solutions which are necessarily proportional to risks.
The intervention will simplify the first aid training regime and introduce a greater level of proportionality in enabling employers to comply with the FAW Regulations. They will be able to send first aiders on either a three day FAW or one day emergency first aid at work (EFAW) course, depending on the requirements of the workplace.
Reduction of the FAW course from four to three days will be facilitated, in part, by a shorter syllabus. In addition, training providers should minimise teaching of theory and place greater emphasis on practical aspects of the course. This will result in a simplified, more focused course which should help first aiders with learning. This is consistent with the latest guidelines on basic life support issued by the Resuscitation Council (UK) which are simplified to aid teaching and learning. A three day course in occupational first aid is already established in Ireland. The three day FAW course will be taught by approved training providers. Overall, HSE anticipates that the standard of training will remain at an appropriate level.
While some employers use appointed persons trained in a one day basic first aid course as first aiders, such courses can be run by any training provider and HSE approval is not required. Therefore, the quality of training could be variable and use of appointed persons as first aiders in this way does not allow the employer to comply with the FAW Regulations. The new one day course in EFAW will only be run by approved training providers to ensure that the standard of training will be at an appropriate level.
Introducing a one day EFAW course along with a three day FAW course will enable employers to provide a more proportionate response to their first aid needs. This should be especially beneficial to smaller businesses. Employers will be expected to conduct a first aid needs assessment, taking into account all relevant circumstances of their workplace. The findings of this assessment will help the employer decide whether their first aiders should be trained in EFAW or FAW. EFAW enables the first aider to provide basic first aid to someone who is injured or taken ill while at work. FAW includes EFAW, and in addition equips the first aider to apply first aid to a range of specific injuries and illness. The employer should ensure that the type of injuries and illness that might occur in the workplace can be dealt with by the first aid personnel they provide. In general terms, low hazards and a small number of employees will tend towards EFAW while higher hazards and larger numbers of employees will tend towards FAW. Based on HSE commissioned research on the number of first aiders in industry, a survey of employers' approaches to first aid training and the move away from higher hazard, large scale industry, it is estimated that 25% of first aiders undertaking FAW training will switch to the EFAW course when implemented.
By conducting a needs assessment, the employer can ensure they have appropriate first aid provision and in doing so it is not anticipated that providing EFAW (as opposed to FAW) trained first aiders will have an adverse impact on health. The quality of EFAW and FAW training should be the same - it is the number of topics covered that differs between the two and which the employer should match to their needs. Equally, it will be legitimate for a visiting HSE/Local Authority inspector to challenge an employer where they have reason to believe that their first aiders should be trained in FAW but are actually trained in EFAW.
The objectives of the intervention are to help employer duty holders access competent first aid, provide a more proportionate response to their first aid needs and to minimise burdens on business. HSE will also encourage employers to send first aiders on half day annual refresher training within any three year FAW/ EFAW certification period. This should help first aiders maintain their basic skills and keep up to date, but it will not be mandatory.
The unit costs of the current courses are:
The unit costs for the current first aid training courses are adapted from the findings of research commissioned by HSE. They include both a cost for the course itself plus the loss of an employee to undertake the training (£300 a day, based on HSE report).
First aid provision is relevant to all industry sectors. Previous data have estimated that 100,000 new first aiders are trained every year by approved training providers.
4 day FAW course for new first aiders
£1500 x 100,000 = £150m (1)
The number of new ‘appointed’ persons being trained in a one day first aid course each year is not known with certainty, but can be estimated at approximately 100,000.
1 day first aid course for appointed persons
£400 x 100,000 = £40m (2)
Research suggests there are at least 750,000 existing FAW qualified first aiders in the workplace and 650,000 employees that have completed first aid training for appointed persons (probably with a three year certification period). The number of certificates expiring in each year is one third of the total population. This means that around 250,000 first aiders and 220,000 appointed persons require requalification every year.
2 day FAW requalification course for existing first aiders
£800 x 250,000 = £200m (3)
1 day requalification course for appointed persons
£400 x 220,000 = £88m (4)
500,000 first aiders and 430,000 appointed persons annually are not subject to requalification. Research indicates that nearly 20% of organisations currently put these first aiders through ad hoc annual refresher training. Uptake is thus estimated at around 100,000 per year for first aiders and 90,000 for appointed persons.
Half day refresher course for existing first aiders
£200 x 100,000 = £20m (5)
Half day refresher course for appointed persons
£200 x 90,000 = £18m (6)
Total costs per year = (1)+(2)+(3)+(4)+(5)+(6)
= £150m + £40m + £200m + £88m + £20m +£18m
= £516m (TC1)
It is estimated that 25% of first aiders undertaking FAW training will switch to the EFAW course when implemented. In addition 80% of ‘appointed’ persons will switch to the EFAW course. There should also be increased uptake of training as a result of the increased flexibility afforded to employers under the new system - given that training of appointed persons in emergency first aid is already widespread, the increased uptake of EFAW training is considered to be <5% of the population of 'appointed persons'
Of the current 100,000 newly trained first aiders undertaking initial FAW training, it is assumed approximately 25% will switch to the one day EFAW course when implemented (ie 75,000 people on the new three day FAW, 25,000 on one day EFAW per year).
3 day FAW course for new first aiders
£1150 x 75,000 = £86m (1)
1 day EFAW course for new first aiders
£400 x 25,000 = £10m (2)
Of the current 100,000 new ‘appointed persons’ per year, it is assumed 80% will become EFAW qualified first aiders instead while the rest will undertake first aid training for appointed persons.
1 day EFAW for new first aiders coming in to FAW rather than ‘Appointed Persons’
£400 x 80,000 = £32m (3)
1 day first aid for new ‘appointed persons’
£400 x 20,000 = £8m (4)
All certificates expire after three years. FAW certificates can be renewed by attending the two day requalification course. EFAW certificates are renewed by attending the EFAW course again.
The number of FAW qualified first aiders in the workplace is relatively static over time at 750,000.
250,000 first aiders will require requalification per year (since the number of certificates expiring in each year is one third of the 750,000). Of these, 25% (62,500) will requalify by taking EFAW and 75% (187,500) will undertake the 2 day requalification course for existing first aiders.
2 day FAW requalification course for existing first aiders
£800 x 187,500 = £150m (5)
1 day EFAW course (requalification) for existing first aiders
£400 x 62,500 = £25m (6)
The population of existing first aiders is 750,000. The two thirds of existing first aiders (500,000) not subject to requalification are considered eligible for the proposed half day refresher course. Uptake is currently estimated at 20% (100,000). HSE will proactively encourage higher attendance on this course with the expectation that 50% (250,000) of eligible first aiders will attend after 3 years.
Half day refresher course for existing first aiders
£200 x 100,000 = £20m (7)
Rising to (after 3 years)
£200 x 250,000 = £50m (8)
Of the current 650,000 population of appointed persons, one third (approx 220,000) will require requalification per year. Of these, 80% (approx 175,000) will requalify by EFAW, the rest (44,000) will continue to requalify as appointed persons
1 day EFAW requalification for existing ‘appointed persons’ entering the training regime
£400 x 175,000 = £70m (9)
1 day requalification for existing ‘appointed persons’
£400 x 44,000 = £18m (10)
Of the 650,000 current appointed persons, two thirds (433,000) are eligible for the half day refresher course. Uptake is currently estimated at 20% (approx 87,000), rising to 50% (approx 220,000) after 3 years. These costs are the same whether or not the appointed person switches to EFAW.
Half day refresher course for ‘appointed persons’ entering the training regime
£200 x 87,000 = £17m (11)
Rising to (after 3 years)
£200 x 220,000 = £44m (12)
Increased uptake of first aid training is expected under the new system as a result of the increased flexibility afforded to employers. The potential increase in numbers is expected to result in an additional 25,000 employees (<5% of 650,000 appointed person population) undertaking EFAW training in each of the 3 years following implementation. After 3 years, they will all require requalification
1 day EFAW course for additional, new EFAW first aiders
£400 x 25,000 = £10m (13)
1 day EFAW requalification course for additional, new EFAW first aiders (after 3 years)
£400 x 25,000 = £10m (14)
Increased uptake of first aid training will increase the number of new EFAW first aiders by 75,000 over 3 years (25,000 per year). One third undertake the EFAW requalification course (see above) whilst the remaining two thirds (50,000) are eligible for annual refresher training, of which 50% (25,000) are estimated to participate after 3 years.
Half Day Refresher course for additional, new EFAW first aiders (after 3 years)
£200 x 25,000 = £5m (15)
There are around 3.5m businesses in Great Britain and on average, an employer will take approximately 15 minutes to consider the guidance which will be introduced to support the new training regime. The hourly rate for a health and safety professional, taken from ASHE, is approximately £21/hour (including non-wage costs) and reading the guidance is a one off cost.
Reading guidance
£5.25 x 3.5m = £18m (16)
Total Costs Per Year (year 1)
= (1) + (2) + (3) + (4) + (5) + (6) + (7) + (9) + (10) + (11) + (13) + (16)
= £86m + £10m + £32m + £8m + £150m + £25m + £20m + £70m + £18m + £17m + £10m + £18m
= £464m (TC2)
Total Costs per Year (after 3 years):
= (1) + (2) + (3) + (4) + (5) + (6) + (8) + (9) + (10) + (12) + (14) + (15)
= £86m + £10m + £32m + £8m + £150m + £25m + £50m + £70m + £18m + £44m + £10m + £5m
= £508m (TC3)
The intervention will yield significant savings to industry. It will be of particular benefit to small organisations, allowing a more proportionate approach to be used by employers in defining their first aid needs.
Savings in Year 1 = TC1-TC2 = £516m – £464m = £52m,
Saving after 3 years = TC1-TC3 = £516m – £508m = £8m
In the first year of implementation, it is estimated that there will be a net saving of around £52m, largely due to a reduction in the cost of training new first aiders. It is estimated that this will fall to a saving of £8m after three years, due to greater assumed participation in short training courses.1 'Where an employee does not need a qualified first aider, the minimum requirement is to appoint a person to take charge of the first aid arrangements. This appointed person does not need to undertake first aid training to fulfil their role but many have been trained in emergency first aid'