Workplace First Aid Requirements NSW | Employer's Guide
Every NSW business has a legal duty to provide first aid — but the legislation doesn't hand you a simple number. It requires each workplace to assess its own risks and provide what's adequate for them. This reference guide summarises where the duty comes from, the ratios SafeWork NSW recommends, the qualifications commonly used, and the refresher timing guidance — with links to the official sources throughout.
Key sources: Work Health and Safety Act 2011 (NSW) · Work Health and Safety Regulation 2025 (NSW) · SafeWork NSW Code of Practice: First Aid in the Workplace · SafeWork NSW – Legislation
Disclaimer: This page is a general reference guide only, provided to help you locate the relevant legislation and guidance. It is not legal, compliance or professional advice, may not reflect the most recent changes to legislation or codes of practice, and should not be relied upon to determine your obligations. Always confirm your requirements against the current Work Health and Safety legislation, the SafeWork NSW Code of Practice: First Aid in the Workplace, and where needed, your own professional advisers. Vitalmed First Aid Pty Ltd accepts no liability for reliance on the information on this page.
Your legal duty: the WHS Act and Regulation
Under the Work Health and Safety Act 2011 (NSW), a person conducting a business or undertaking (PCBU) must ensure, so far as is reasonably practicable, the health and safety of workers. The first aid duty is set out in the Work Health and Safety Regulation 2025 (NSW), which commenced on 22 August 2025 and replaced the Work Health and Safety Regulation 2017 (verify the current section number — formerly clause 42 of the 2017 Regulation — against the Regulation as made on legislation.nsw.gov.au). A PCBU must provide:
- First aid equipment, and ensure every worker has access to it
- Access to facilities for administering first aid
- An adequate number of trained first aiders, or arrangements for workers to access trained first aiders
What counts as "adequate" is determined by a first aid risk assessment considering the nature of the work, the hazards present, the size and location of the workplace, and the number and composition of workers.
The practical detail sits in the SafeWork NSW Code of Practice: First Aid in the Workplace — and its legal status changed on 1 July 2026. With the commencement of section 26A of the WHS Act 2011 (NSW), approved codes of practice are no longer guidance that courts may merely consider: PCBUs now have a duty to comply with an applicable approved code, or to manage the hazard or risk in a different way that provides an equivalent or higher standard of health and safety. If an approved code covers a risk present in a workplace, following it — or documenting an equal-or-better alternative — is now the legal expectation, not best practice.
How many first aiders does your workplace need?
The Code of Practice recommends these minimum ratios:
- Low risk (offices, retail, libraries, professional services) = 1 first aider per 50 workers
- High risk (construction, manufacturing, warehousing, work with machinery or chemicals) = 1 first aider per 25 workers
- High risk AND remote from timely medical/ambulance access = 1 first aider per 10 workers
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Four factors that catch employers out
- Count per shift, not per payroll. If you run multiple shifts, each shift needs coverage — a trained first aider must be accessible whenever work is being done, including nights, weekends and overtime.
- Count everyone on site at peak. The assessment is based on the maximum number of people at the workplace at any one time — including contractors, volunteers and, in settings like gyms, schools and aquatic facilities, members of the public.
- Each site counts separately. A business operating across multiple locations needs first aid provision at each one, not just head office.
- Risk category isn't self-nominated. If workers are exposed to hazards that could cause serious injury requiring immediate treatment, you're high risk — regardless of industry label.
What qualifications do workplace first aiders need?
First aiders should hold a nationally recognised unit of competency issued through a Registered Training Organisation. The standard units are:
- HLTAID009 Provide cardiopulmonary resuscitation — CPR only; suits workplaces where a full first aider is nearby
- HLTAID011 Provide first aid — the standard workplace first aid qualification, and the baseline most NSW risk assessments arrive at
- HLTAID015 Provide advanced resuscitation and oxygen therapy — for workplaces whose risk assessment identifies oxygen equipment or advanced resuscitation response: aquatic facilities, dive operations, dental and medical practices, remote sites and high-risk industrial settings
The Code is explicit that first aiders should be trained for the level of risk identified at the workplace — a pool with an oxygen kit on the wall needs staff trained to use it, not just staff with basic first aid.
Beyond training: kits, procedures and equipment
Trained first aiders are only one part of the duty. Under the Code, a first aid risk assessment should also cover:
- First aid kits — at least one, accessible to all workers at all times, contents matched to your hazards, checked and restocked regularly
- First aid procedures — workers must know how to get first aid help, who the first aiders are, and where equipment is located; build this into inductions
- Additional equipment where risk indicates — SafeWork NSW notes AEDs where there is electrocution risk, delayed ambulance access or large numbers of public; oxygen equipment in aquatic and clinical settings; asthma and anaphylaxis medication management
- First aid rooms — recommended for larger workplaces (the Code suggests considering one at around 200 workers) or where the risk profile warrants it
- Review triggers — reassess after any incident, workforce change, new equipment or hazardous chemicals, or workplace changes
Frequently asked questions
Is the Code of Practice legally binding?
Since 1 July 2026, effectively yes. Section 26A of the WHS Act 2011 (NSW) commenced on that date, creating a duty for PCBUs to comply with approved codes of practice — or to manage the relevant hazard or risk in a different way that provides an equivalent or higher standard of health and safety. Approved codes are now the minimum performance standard, not optional guidance, and a failure to meet an applicable code's standard can itself support a breach of the Act. (Before 1 July 2026, codes were admissible evidence of what was reasonably practicable rather than a direct duty.)
Is workplace first aid training legally required in NSW?
Yes, in effect. Clause 42 of the WHS Regulation 2017 requires every PCBU to provide an adequate number of trained first aiders (or access arrangements), determined by a risk assessment. For almost all workplaces, that means at least one worker holding a current nationally recognised first aid qualification.
How many first aiders do I need for 20 staff?
In a low-risk workplace, the recommended minimum is one trained first aider (1 per 50 workers).
In a high-risk workplace, you'd still need one at 20 staff (1 per 25) — but you must ensure coverage across all shifts and consider leave, so most workplaces train at least two.
What first aid training do I need if my workplace has oxygen equipment?
HLTAID015 Provide Advanced Resuscitation and Oxygen Therapy is the nationally recognised unit covering oxygen administration, bag-valve-mask ventilation and airway management. If your risk assessment puts oxygen equipment on site, staff expected to use it should hold this unit.
Who is responsible for first aid when multiple businesses share a site?
Duties overlap. PCBUs sharing a workplace must consult and coordinate — first aiders and facilities may be shared, but each PCBU remains responsible for ensuring its own workers have access.