WHS First Aid: 4 Duties for Australian Employers at Remote Sites
Under WHS law, a PCBU (person conducting a business or undertaking) must provide first aid equipment, ensure workers have access to facilities, and provide access to an adequate number of trained first aiders. The starting point for meeting this duty is a proper workplace risk assessment, followed by a visible kit, confirmed first aider coverage and booked, nationally recognised training.
TL;DR:
There is no fixed first aider to worker ratio; determine coverage from workforce size, hazards, site layout, distance from emergency services, and shift patterns.
Kits should match assessed hazards: add burns dressings or eyewash for exposure risks, avoid general medication, and assign someone to track expiry dates and restocking.
General workplace first aiders need HLTAID011, while remote or higher risk crews may need advanced training; refresh CPR annually and other qualifications about every three years.
At shared worksites, PCBUs should coordinate coverage for contractors and host staff, posting first aider names and kit locations where every shift can see them.
Table of Contents
What the WHS Act, WHS Regulations and the model Code of Practice require
The legal duty is set out plainly in the regulations and echoed in guidance published by Safe Work Australia and state regulators. In Western Australia, Division 3 of the Work Health and Safety (General) Regulations 2022%20Regulations%202022%20-%20%5B01-a0-00%5D.html?OpenElement=) sets out this duty under clause 42: every PCBU must provide first aid equipment, ensure access to facilities for administering it, and ensure access to an adequate number of workers trained to administer it. This applies to every workplace we operate in, from a Port Hedland office to a remote construction site.
The model Code of Practice: First aid in the workplace fills in the practical detail the regulations leave open. It explains how to work out what equipment, facilities and training a workplace actually needs, and it recommends a risk-based approach rather than a generic, one-size-fits-all kit.
A few things are worth keeping straight as you plan your approach:
The regulation states the legal duty; the Code of Practice explains how to meet it in practice.
Compliance is outcome-focused: alternative measures are acceptable if they achieve an equivalent or better safety outcome than the Code describes.
Jurisdictional detail matters, so WA employers should read the WA regulations alongside national guidance rather than relying on one or the other alone.
The Code of Practice treats first aid as a risk management exercise, not a checklist: it recommends tailoring kit contents, first aider numbers and facilities to the specific hazards and layout of each workplace, which is why two businesses in the same industry can have very different first aid arrangements and both be compliant.
Who must act: PCBU, officer, manager and worker duties
Compliance isn’t a single person’s job. Each duty holder in the chain has a distinct part to play, and understanding where your role starts and stops makes the whole system work.
The PCBU carries the primary duty: assess first aid needs, provide equipment and facilities, arrange adequate trained first aider coverage, and review arrangements as the business or its risks change.
Officers (directors, senior managers) must exercise due diligence, which means actively checking that first aid resources exist and are adequate, not simply assuming someone else has handled it.
Day-to-day managers and supervisors are usually the ones who action the plan: booking training, restocking kits, rostering first aider coverage across shifts.
Workers have a duty to cooperate: using equipment correctly, reporting when supplies run low, and following first aid procedures during an incident.
WorkSafe WA guidance makes clear that where multiple businesses share a worksite, such as a head contractor and subcontractors on a construction site, the PCBUs involved should consult and coordinate so first aid arrangements cover everyone, with no gaps and no needless duplication.
A simple manager’s checklist helps keep this visible day to day: assign named first aider roles per shift, publish kit locations and first aider contact details where everyone can see them, and check access isn’t blocked by locked doors, remote sheds or vehicles that move off-site.
Pro Tip: Put first aider names and photos on a noticeboard near the kit, and update it the same day a rostered first aider changes.
How to assess your first aid needs: a risk-based framework
A proper risk assessment is what turns a generic obligation into a workplace-specific plan, and it’s the step most businesses skip or do too quickly.
Identify the hazards: what could realistically hurt someone during normal operations and during foreseeable abnormal events.
Assess likelihood and severity: a cut from paper handling and a crush injury from mobile plant need very different responses.
Decide on equipment, facilities and training that match what you found, rather than buying a standard kit off the shelf.
Review the assessment whenever the work, workforce or site changes, and at set intervals even if nothing obviously has.
Our 4 step first aid risk assessment guide walks through this process in more detail for Australian workplaces.
Factors that shift the outcome include:
The type of work and the specific hazards it involves.
Workforce size, composition and any known vulnerabilities among staff.
Site location, including distance from emergency services.
Shift patterns and whether cover is needed outside standard hours.
Remote sites, workplaces handling hazardous chemicals, and those where a serious injury is plausible (confined spaces, live electrical work, heavy mobile plant) typically need higher-level training, additional equipment and sometimes an onsite first aid room.
First aid kits, facilities, rooms and AEDs: what to provide and maintain
Every worker needs access to at least one appropriately stocked first aid kit, full stop. What goes inside it, and whether a kit alone is enough, depends on the risk assessment you’ve already done.
A standard kit typically covers wound care, burns dressings, bandages and basic resuscitation aids, but the model Code of Practice advises against stocking general medication in workplace kits. Specific additions matter more than volume:
Burns dressings and eyewash where heat or chemical exposure is a realistic risk.
Chemical-specific antidotes or safety data sheet references where hazardous substances are handled.
Anaphylaxis and asthma response items, considered carefully alongside training on their correct use and storage.
Remote response additions such as extended trauma supplies where professional help is hours away.
A first aid room becomes worth considering as workforce size grows, risk severity increases, or ambulance response times stretch out, and an automated external defibrillator (AED) is worth adding wherever cardiac events are a realistic possibility given the work or workforce profile. WorkSafe WA’s guidance frames these as tailored decisions rather than fixed thresholds, so the right answer depends on your site, not a generic rule.
Maintenance needs an owner: nominate a person responsible for checking kits on a set schedule, tracking expiry dates and restocking after use, and keep a simple log so you can show it’s actually happening.
Training that counts: units, levels and refresher timing
Not every first aid course satisfies the WHS duty to the same degree, and matching the training level to the actual risk is where many workplaces fall short.
The core nationally recognised unit for a workplace first aider is HLTAID011 – Provide First Aid, which covers the competencies expected of a general workplace first aid officer. Businesses needing CPR-only coverage can look at HLTAID009 – Provide Cardiopulmonary Resuscitation, while education and care settings have a dedicated unit in HLTAID012.
Higher-risk and remote environments call for more:
HLTAID014 – Provide Advanced First Aid suits workplaces with elevated injury severity or limited access to immediate medical help.
HLTAID013 – Provide First Aid in Remote or Isolated Site is built for mine sites, remote construction and isolated crews.
HLTAID015 – Provide Advanced Resuscitation and Oxygen Therapy adds resuscitation and oxygen competencies for serious incident response.
Refresher timing follows industry guidance rather than a single rule across all jurisdictions: CPR skills are generally refreshed annually, and full first aid qualifications are renewed roughly every three years. Keep each worker’s certificate and renewal date on file so gaps don’t appear during an audit or, worse, during an actual emergency.
Pro Tip: Match the unit to your risk assessment findings, not to what’s cheapest or fastest; a general kit and HLTAID011 won’t cover a crew two hours from the nearest hospital.
Delivery flexibility matters for many businesses: on-site group training reduces downtime, mobile registered training organisations (RTOs) bring the course to remote crews, and blended delivery combines online theory with practical assessment days.
Emergency plans, procedures and recordkeeping that prove compliance
A first aid kit means little without a plan for what happens when it’s actually needed, and the plan means little if nobody’s told how it works.
Build an emergency plan covering immediate response, evacuation routes, how emergency services are contacted, and who coordinates the response on-site.
Write clear first aid procedures: who responds, how they’re contacted (radio, phone, alarm), and how coverage continues across shifts, including contractor and visitor scenarios.
Communicate arrangements during induction, back it up with signage near kits and first aid rooms, and make first aiders identifiable with badges or hi-vis markers.
Keep records that demonstrate reasonable steps were taken: training certificates, incident and treatment logs, kit inspection checklists and risk assessment review notes.
Where your workforce includes people with health conditions, sensory differences or communication needs that affect how they respond in an emergency, it’s worth reviewing broader workplace supports; this practical guide to workplace accommodations covers considerations that can shape induction and emergency communication for a more diverse team.
What trainers see most: common gaps and simple fixes
In our experience delivering courses across industrial and remote sites, the same gaps turn up repeatedly: first aiders trained at the wrong level for the actual risk, kits that haven’t been checked in months, and staff who genuinely don’t know who the first aider is on their shift.
The fixes are rarely complicated. Nominate first aiders by name, make them visible, schedule kit checks like any other routine task, and choose training that matches what your risk assessment actually found, not what’s quickest to book.
— Vapour
How we help you meet your WHS first aid obligations
We deliver nationally recognised first aid training tailored to the hazards your workplace actually faces, with on-site and remote-capable delivery and prompt certification after training completion.
Our course range covers the full spectrum employers need to close compliance gaps:
HLTAID011 – Provide First Aid for general workplace first aider coverage.
HLTAID013 – Provide First Aid in Remote or Isolated Site for mine sites and isolated crews.
HLTAID014 – Provide Advanced First Aid and HLTAID015 – Provide Advanced Resuscitation and Oxygen Therapy for higher-risk environments.
Browse our full course offering or get in touch to talk through which units suit your risk assessment and your roster.
FAQ
What does WHS law require employers to provide for first aid?
A PCBU must provide first aid equipment, ensure workers have access to facilities for administering it, and ensure access to an adequate number of trained first aiders. In Western Australia this duty is set out in Regulation 42 of the WHS General Regulations 2022, with practical detail added by the model Code of Practice.
How many first aiders does a workplace need?
There’s no single fixed ratio; the right number depends on your risk assessment, including workforce size, hazard severity and site layout. Our guide to first aider numbers walks through the factors that typically drive this decision for Australian workplaces.
How often does first aid training need to be renewed?
CPR skills are generally refreshed annually, while a full first aid qualification is typically renewed about every three years, based on current industry guidance. Keep certificate dates on file so renewals don’t lapse unnoticed.
Do remote worksites need different first aid arrangements?
Yes. WorkSafe WA guidance confirms that remote and mobile workplaces often need higher-level training, additional equipment and sometimes extended response capability because professional medical help is further away.
What happens if a business doesn’t meet its first aid obligations?
Non-compliance with WHS first aid duties can lead to regulatory action under the relevant state WHS regulations, since the duty to provide equipment, facilities and trained first aiders is a legal requirement, not a recommendation. Reviewing your risk assessment and training records regularly is the most reliable way to check you’re meeting it.
Sources
For the exact legal wording and jurisdictional detail behind this article, these are worth bookmarking:
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