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The First Aid Code of Practice: What Australian Businesses Must Follow
Safe Work Australia's model Code of Practice runs to roughly 50 pages, and most of it is written for a lawyer, not a busy WHS manager. The part you actually need fits on one page. The first aid Code of Practice tells you what equipment, facilities and trained people your workplace has to provide, and it does it in plain terms once you know where to look.
The catch is that the model code is exactly that, a model. It only has legal force in a state or territory once that jurisdiction adopts it, and not every one adopts it the same way. So before you act on a single ratio or kit requirement, you need to know which version applies to you.
What the first aid Code of Practice actually is
The model Code of Practice for first aid in the workplace is an approved code under section 274 of the Safe Work Australia model Code of Practice, made under the Work Health and Safety Act. Safe Work Australia writes it, but Safe Work Australia does not regulate anyone. Each state and territory chooses whether to adopt the model WHS laws and the codes that sit under them.
Most jurisdictions have. New South Wales, Queensland, South Australia, Tasmania, the ACT and the Northern Territory all run the harmonised WHS framework and an approved first aid code that mirrors the model. Western Australia joined the harmonised system later than the rest, its Work Health and Safety Act 2020 commencing on 31 March 2022, and applies it through its own Work Health and Safety (General) Regulations 2022 and a WA-adapted first aid code of practice. Victoria is the only state outside the harmonised scheme. It operates under the Occupational Health and Safety Act 2004 and WorkSafe Victoria's own Compliance Code for first aid in the workplace.
The practical upshot is the one mistake we see most from businesses with sites in more than one state. They build a kit and a roster to the document they found first, usually the Safe Work Australia model or their head-office state, then assume it travels. A setup that is fine in Sydney can be measured against a different code in Melbourne or Perth.
The substance is broadly consistent, but the document name, the regulator and some of the detail change with the border. Check the regulator for each state you operate in before you rely on a single figure.
Is the Code of Practice legally binding?
An approved code of practice is not law in the way the WHS Act is, but it is admissible in court. A court may treat the code as evidence of what is reasonably known about a hazard and what is reasonably practicable to do about it. In short, if something goes wrong and you ignored the code, you will be explaining why.
You can meet your duty a different way if your method gives an equal or higher standard of safety. But the code is the benchmark a regulator and a court will measure you against, so departing from it without a clear reason is rarely worth the risk.
The four things every workplace must provide
The model code groups the requirement into four parts: first aid kits, first aid procedures, first aid facilities, and trained first aiders. Under the code, equipment, facilities and first aiders must be accessible to workers whenever they are working, including night shifts and overtime.
First aid procedures are the written piece people forget. A procedure records who your first aiders are, where the kits and any equipment live, how an incident gets reported and recorded, and how an emergency response is triggered on your site. It does not need to be long, but it needs to exist and be known to workers.
First aid facilities are about space rather than supplies. A small low risk office does not need a dedicated room, but the code points larger or higher risk workplaces toward a designated first aid room once the size, hazard level and distance from medical help cross a threshold you assess yourself.
Every worker must be able to reach a first aid kit, which means at least one kit per workplace and more across larger or spread-out sites. What goes inside it depends on your risk assessment, and we cover that in detail in our guide to what a compliant workplace first aid kit needs to contain. The code also asks you to nominate someone, usually a first aider, to check each kit after every use or at least once every 12 months, with a signed and dated inventory list inside.
That 12-month check is the one most businesses miss, and the failure pattern is consistent. When a workplace kit comes back to us for servicing after a year or more without a look, it is rarely the dramatic items that have gone. It is the everyday consumables: adhesive plasters, antiseptic wipes and eye wash get raided between incidents and quietly disappear, while the trauma items sit untouched and expire in place.
A sterile dressing is only sterile while its packaging is sealed and intact: once a packet is torn, punctured, water-damaged or has come open, treat it as no longer sterile even if the printed expiry date is fine. The cheap fix is a standing reorder of restocking supplies on the same cycle as the check, so the kit is full when someone actually needs it.
How many trained first aiders do you need?
The model Code of Practice sets three starting ratios by workplace type.
| Workplace type | Recommended first aiders |
|---|---|
| Low risk | 1 for every 50 workers |
| High risk | 1 for every 25 workers |
| Remote high risk | 1 for every 10 workers |
Read those as a floor, not a target you tick off once. The trap is treating one trained name on the roster as coverage for the whole operation. A single first aider rostered across three shifts is not the same as a first aider available at all times, and the moment that person takes leave or calls in sick, a site that looked compliant on paper has nobody trained on the floor.
The code asks you to refine the headcount by weighing the nature of the work and its hazards, the size and location of the workplace, and the number and composition of your workers, including how shifts are covered and how quickly emergency services can reach you. Count per shift, not per payroll, and carry enough trained people that one absence does not leave a gap. First aiders should hold a current nationally recognised statement of attainment and refresh their training regularly.
What to do next
Start by confirming which regulator and which code apply in your state, because that decides every requirement below it. Then run a genuine risk assessment, count your workers per shift against the right ratio, and check your kits against the 12-month rule.
If you would rather not work through a 50-page document, our workplace first aid compliance guide breaks the whole framework down by business type. You can browse our workplace first aid kits by risk level, or talk to our team on 03 5443 2239 about getting your sites assessed and stocked. Email info@firstaiddistributions.com.au if that is easier. We manufacture and check our own kits, so the one we recommend is one we have built and inspected ourselves.