Workplace First Aid Compliance in Australia: The Complete Guide for Businesses

Open the first aid kit in your office right now. If it has been sitting on the wall for more than 12 months without being checked, you already have a compliance problem, and most Australian workplaces do. The kit was bought with good intentions, ticked a box on the safety checklist, and then quietly became somebody else's problem. Expired eye wash. Missing triangular bandages. A contents list that no longer matches what's actually inside.

Workplace first aid requirements in Australia are not optional. They are set out in Safe Work Australia's First Aid in the Workplace Code of Practice and enforced through state and territory WHS legislation. The requirements cover more than the kit itself. They include risk assessment, trained first aiders, documentation, and an ongoing maintenance schedule that most businesses either do not know about or do not follow.

This guide covers the full scope of workplace first aid compliance: what the Code of Practice actually requires, how to determine what your specific workplace needs, what goes in the kit, how many trained first aiders you need, and how to maintain the whole system over time without it falling through the cracks.

What the Code of Practice actually requires

Australian workplace first aid requirements are governed by Safe Work Australia's First Aid in the Workplace Code of Practice. Every business must conduct a first aid risk assessment, provide appropriate first aid kits and equipment, ensure access to trained first aiders, and maintain a system for regular kit inspection and restocking. State and territory WHS regulators enforce these requirements.

The Code of Practice is an approved code under the model Work Health and Safety (WHS) Act. While it is not legislation in itself, a business that follows the Code is considered to have met its duty of care for first aid provision. A business that does not follow it needs to demonstrate that its alternative approach provides an equivalent or higher standard of protection, which is a difficult argument to make if something goes wrong.

The obligations fall on the person conducting a business or undertaking (PCBU). In practical terms, that means the business owner, the employer, or the entity responsible for the workplace. The obligations cannot be delegated away entirely. You can assign someone to manage the first aid program, but the legal responsibility stays with the PCBU.

The Code covers five core areas: risk assessment, first aid kits and equipment, first aiders, first aid facilities, and documentation. Each of these is addressed in its own section below.

Risk assessment: determining your workplace first aid needs

Before you buy a single bandage, the Code of Practice requires a first aid needs assessment. This is not a bureaucratic exercise. It determines everything that follows: the type and number of kits, the number of trained first aiders, whether you need a first aid room, and the kind of equipment that should be available.

The assessment looks at the nature of the work being performed, the types of hazards present, the size and layout of the workplace, the number of workers, and the distance to the nearest medical facility. A small office in suburban Melbourne with 15 workers has very different needs from a construction site 40 kilometres from the nearest hospital.

High-risk workplaces, those involving machinery, chemicals, heights, extreme temperatures, or remote locations, need more extensive first aid provisions than low-risk office environments. The Code does not prescribe a one-size-fits-all kit because no single kit suits every workplace.

The assessment should also consider shift patterns and working arrangements. If your business runs multiple shifts, first aid provisions need to be available for each shift, not just during standard hours. Workers who operate alone or in isolated parts of a building present a different risk profile from workers in a shared office space. The Code expects that you have thought about how first aid reaches the worker, not just whether it exists somewhere on the premises.

Document the assessment. Keep a written record of what you assessed, what you decided, and why. If a regulator asks how you determined your first aid provisions, the documented risk assessment is your answer. Without it, you are relying on a verbal explanation after the fact, and that is not where you want to be. Review the assessment whenever the workplace changes: a new process, a new location, a significant change in workforce size, or after an incident that reveals a gap.

What a compliant workplace first aid kit must contain

The Code of Practice sets out minimum contents for first aid kits based on the risk level of the workplace. For a low-risk workplace such as an office or retail store, the minimum kit contents include adhesive strips, sterile gauze, triangular bandages, wound closure strips, disposable gloves, a resuscitation mask, scissors, tweezers, saline solution for eye irrigation, and a range of other specified items. High-risk workplaces require additional items, and workplaces with specific hazards like chemical exposure or burn risk may need specialised additions.

The critical point many businesses miss is that these are minimums. If your risk assessment identifies specific hazards, your kit must include items that address those hazards even if they are not listed in the generic minimum contents table. A commercial kitchen, for example, should include burn dressings beyond the minimum specification.

FAD's workplace first aid kits are designed around Safe Work Australia's requirements for both low-risk and high-risk environments. For a detailed walkthrough of what belongs in each kit type and how contents vary by risk category, read our article on what a compliant workplace first aid kit actually needs to contain.

Location matters as much as contents. Kits should be clearly signed, easily accessible, and positioned so that any worker can reach one within a reasonable time. In larger workplaces, this means multiple kits distributed across the site. In multi-level buildings, each floor should have its own kit. The kit should not be locked in a cupboard or stored in an office that is only open during certain hours. If workers cannot get to it quickly when something happens, the contents are irrelevant.

How many first aiders does your workplace need?

Having a kit on the wall is only part of the obligation. Someone in the workplace needs to know how to use it. The Code of Practice requires that trained first aiders be available during all working hours, including shift work and after-hours operations.

The number of first aiders depends on the size of the workforce, the risk level, and the layout of the workplace. For a low-risk workplace with fewer than 25 workers, one trained first aider may be sufficient. For workplaces with 25 to 50 workers, at least two first aiders should be available. High-risk and larger workplaces need more, and the calculation should account for absences, leave, and shift patterns so that there is always a first aider on site when people are working.

First aid qualifications in Australia must be nationally recognised, meaning the training is delivered by a registered training organisation (RTO) and the certificate is a nationally accredited unit of competency. The most common qualification is HLTAID011 (Provide First Aid), which includes CPR. Qualifications need to be renewed: CPR annually, and the full first aid certificate every three years.

Keep a register of first aiders that includes names, qualification details, expiry dates, and shift rosters. This is part of the documentation trail the Code expects. If a first aider's certificate lapses without being renewed, you have a gap in your first aid coverage, and that gap is a compliance issue.

It is also worth noting that a first aider who completed their training five years ago but has not practised since may technically hold a current certificate while lacking the confidence to act under pressure. Some businesses address this by running annual refresher sessions or tabletop scenarios alongside the formal requalification cycle. The Code does not mandate this, but it is good practice, and it demonstrates a genuine commitment to first aid readiness rather than a paper-only approach.

First aid facilities: when a kit is not enough

For some workplaces, a wall-mounted kit and a trained first aider are not sufficient. The Code of Practice requires that higher-risk workplaces and those with larger workforces consider whether a dedicated first aid room is necessary. The assessment turns on the same factors as the broader risk assessment: the nature of the hazards, the number of workers, and how far the workplace is from emergency medical services.

A first aid room should be large enough for a person to lie down, have good lighting and ventilation, be clearly signed and accessible, and include a sink with running water. It does not need to be a full medical clinic, but it does need to be a functional space where a first aider can assess and treat an injury in reasonable conditions.

Most low-risk offices with small teams will not need a dedicated room. But if your risk assessment identifies a need, the Code expects you to provide one. Skipping this step because it seems excessive is exactly the kind of gap that shows up during a regulator visit or, worse, after an incident where the absence of a suitable treatment space contributed to a poor outcome.

Audit and maintenance: keeping the kit compliant over time

This is where most workplace first aid programs break down. The kit gets purchased, the first aiders get trained, and then nobody checks the kit again until someone opens it in an emergency and discovers that half the contents are expired.

The Code of Practice requires regular inspection and restocking of first aid kits. Items that are used, damaged, or past their expiry date must be replaced promptly. The kit itself should be checked at a regular interval, and many WHS professionals recommend quarterly as a practical minimum.

A good audit process is straightforward. Open the kit. Check every item against the contents list. Remove anything expired or damaged. Replace what is missing. Record the inspection, including the date, the person who conducted it, and any items replaced. That record is your evidence of ongoing compliance.

If the idea of managing this manually across multiple kits, multiple locations, or multiple facilities sounds like a headache, that is because it is. The larger the business, the more likely it is that kit inspections will be missed, records will be incomplete, and expiry dates will be overlooked. 

Documentation and compliance records

Workplace first aid compliance is not just about what you provide. It is about what you can prove you provided. Documentation is the difference between a business that is genuinely compliant and one that only thinks it is.

The records you should be keeping include the first aid needs assessment (and any updates to it), a kit location register, contents lists for each kit, inspection records with dates and outcomes, a first aider register with qualification expiry dates, and records of any first aid incidents and the treatment provided.

These records serve two purposes. First, they satisfy a WHS regulator that your first aid program is active and maintained. Second, they protect the business in the event of an incident. If an employee is injured and a question arises about whether adequate first aid was available, your documentation is the evidence. Without it, you are making a case from memory, and that is never as convincing.

Storing these records does not need to be complex. A shared folder, a spreadsheet, or a dedicated compliance platform all work. What matters is that the records are accessible, up to date, and maintained consistently.

Incident records deserve particular attention. When first aid is administered, the first aider should record the date, the time, the person treated, the nature of the injury or illness, the treatment provided, and any referral to medical services. These records feed back into the risk assessment process. If your workplace is seeing repeated soft tissue injuries in the warehouse, that tells you something about both the hazards and whether your first aid provisions match the actual risks being presented.

One common oversight: businesses that have the records but cannot find them. If the WHS manager leaves and nobody knows where the inspection spreadsheet lives, the records effectively do not exist. Assign a clear owner, use a system everyone can access, and include the compliance records in your business continuity planning. It sounds excessive until the day a regulator asks for your audit trail.

How KitCheck removes the manual burden

Everything described above, the kit inspections, the expiry tracking, the documentation, the audit trail, is manageable when a business has one kit in one location. It becomes significantly harder when there are five kits across three floors, or 20 kits across six sites, or 50 kits across a network of aged care facilities.

KitCheck is FAD's online kit management platform, built specifically for businesses that need to track first aid kit compliance across one or more locations. It records kit locations, tracks expiry dates, generates inspection reminders, and produces audit reports that give WHS managers a single view of their compliance status.

The practical benefit is straightforward: instead of relying on a calendar reminder and a clipboard, KitCheck creates a documented compliance trail that runs in the background. When a regulator asks for evidence of your first aid maintenance program, you have a system that produces the answer, not a person trying to remember when the last check was done.

For businesses that prefer to hand off kit management entirely, FAD also offers onsite kit servicing across Central Victoria. The FAD team comes to your workplace, inspects the kits, replaces what needs replacing, and updates the records. It is the fully managed version of what KitCheck does digitally. For a closer look at how KitCheck works in practice, read our article Inside KitCheck: managing first aid compliance without the headache.

A note on schools and education settings

Schools have their own set of first aid compliance obligations that overlap with, but are not identical to, standard workplace requirements. Victorian schools must comply with both WHS legislation and Department of Education guidelines, which set additional expectations around student safety, excursion first aid, and sports events.

If you manage first aid compliance for a school or education setting, our guide to first aid for Australian schools and community organisations covers the specific requirements that apply to your context, including classroom kits, excursion provisions, and sporting event obligations.

Getting started with workplace first aid compliance

If you are reading this because your workplace needs to get its first aid program in order, the sequence is clear. Start with the risk assessment. Determine what your workplace actually needs based on the hazards, the workforce size, and the distance to medical care. Then acquire kits that meet those needs, train enough first aiders to cover all working hours, set up an inspection schedule, and document everything.

If you are reading this because you already have a program in place and you are not sure it is up to standard, the simplest first step is an audit. Open the kit. Check the contents against the Code of Practice requirements. Check your first aider register. Check when the last documented inspection was done. The gaps will be obvious.

FAD supplies workplace first aid kits designed around Safe Work Australia's requirements for low-risk and high-risk environments, along with first aid supplies for restocking. For businesses that need a system to stay on top of ongoing compliance, KitCheck is available at kitcheck.com.au.

Contact the FAD team on 03 5443 2239 or email info@firstaiddistributions.com.au to discuss your workplace first aid requirements. Whether you need one kit for a small office or a managed compliance program for a multi-site operation, the team can help you get it right.

Related articles

• How to identify workplace hazards: a practical walkthrough of the hazard categories Safe Work Australia recognises, how to spot hazards across different workplace environments, and why hazard identification is the starting point for any first aid risk assessment.
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