TL;DR
- There is no legal ratio of first aiders to employees. HSE's own answer to "How many first-aiders do I need?" is that "There are no hard and fast rules on exact numbers". The duty in regulation 3(2) is to provide "such number of suitable persons as is adequate and appropriate in the circumstances", and the assessment decides that number.
- HSE does publish indicative numbers, and labels them as suggestions. In leaflet INDG214, a low hazard workplace with fewer than 25 employees needs at least one appointed person, and one with more than 50 needs "At least one first-aider trained in FAW for every 100 employed (or part thereof)". HSE adds that "The numbers given in Table 2 are suggestions only".
- Since 1 October 2013 the Regulations no longer refer to training HSE approves. Regulation 3(2) was substituted by S.I. 2013/1512 and now says a person is not suitable unless they have "such training and has such qualifications as may be appropriate in the circumstances of that case". The duty to provide trained people did not change.
Most searches about first aid at work want one number: how many first aiders do we need. No official UK source publishes a ratio, because the law does not work that way. What it requires is an assessment, and the assessment produces your number.
That reads like an evasion until you read the duty. Then it tells you where the effort belongs: not in counting heads against a table found online, but in a short dated assessment you can show an inspector. This article sets out what the Regulations say, what HSE's own guidance suggests, and the points employers most often get wrong. It covers Great Britain, and it is general information rather than legal or medical advice.
Certificates expire, people leave and cover slips. Keeping the training record attached to the role rather than to a spreadsheet is a process problem, and New Dynamics workflows let you build the reminders and approvals into the process that already runs.
What the Regulations actually require
The duty comes from the Health and Safety (First-Aid) Regulations 1981, which under regulation 1 "shall come into operation on 1st July 1982". Regulation 3 extends to England, Wales and Scotland.
Regulation 3(1) requires an employer to provide "such equipment and facilities as are adequate and appropriate in the circumstances for enabling first-aid to be rendered to his employees if they are injured or become ill at work". Regulation 3(2) applies the same test to people: "such number of suitable persons as is adequate and appropriate in the circumstances". Regulation 3(4) allows an appointed person instead of a first aider where that is adequate, having regard to the nature of the undertaking, the number of employees at work and the location of the establishment. Regulation 4 requires an employer to "inform his employees of the arrangements that have been made in connection with the provision of first-aid, including the location of equipment, facilities and personnel". Regulation 5 covers the self-employed.
HSE's legislation page on first aid states the scope plainly. The Regulations "apply to all workplaces including those with less than five employees and to the self-employed", and "What is 'adequate and appropriate' will depend on the circumstances in the workplace". There is no small employer exemption.
For scale, HSE's key figures for Great Britain 2024 to 2025, updated on 30 June 2026, record 59,219 injuries to employees reported under RIDDOR and 680,000 working people who sustained an injury at work according to the Labour Force Survey. Our HR statistics hub has the wider picture.
There is no legal ratio of first aiders to employees
HSE says this directly. In its first aid FAQs, the answer to "How many first-aiders do I need?" is: "The findings of your first-aid needs assessment will help you decide how many first-aiders are required. There are no hard and fast rules on exact numbers and you will need to take into account all the relevant circumstances of your particular workplace."
HSE does publish indicative numbers, and it is careful about their status. Table 2 of its leaflet First aid at work: your questions answered (INDG214(rev2), published May 2014) gives "Suggested numbers of first-aid personnel to be available at all times people are at work". For low hazard work, such as offices, shops and libraries: fewer than 25 employees, "At least one appointed person"; 25 to 50, "At least one first-aider trained in EFAW"; more than 50, "At least one first-aider trained in FAW for every 100 employed (or part thereof)". For higher hazard work, such as light engineering and assembly, food processing, warehousing, construction and chemical manufacture, the bands are fewer than 5, 5 to 50, and more than 50, where it becomes "At least one first-aider trained in FAW for every 50 employed (or part thereof)".
Then the qualification that gets left out of every summary of that table. HSE writes: "The numbers given in Table 2 are suggestions only. You should assess your first-aid needs in the light of your particular circumstances." It adds that with shift work or sites with several buildings "there may need to be more first-aid personnel than set out in Table 2", and that "You will also need to increase your provision to cover for absences."
Treat the table as a floor to argue up from, not a test to pass.
What the first aid needs assessment must consider
HSE's checklist is Table 1 of INDG214, under five headings. Hazards comes first: low level hazards, of the kind found in offices and shops, mean the minimum provision, an appointed person and a suitably stocked kit. Higher level hazards, such as chemicals or dangerous machinery, mean you should consider "providing first-aiders", "additional training for first-aiders to deal with injuries caused by special hazards", additional equipment, its precise location, "providing a first-aid room" and "informing the emergency services in advance".
Employees covers headcount on site, and whether there are inexperienced workers, including those on work experience, or employees with disabilities or particular health problems. Accidents and ill-health records asks what has occurred and where, with an instruction to "Monitor accidents and ill health, and review your first-aid provision as appropriate".
Working arrangements is the heading most assessments skip. It asks about employees who travel a lot, work remotely or work alone; shift and out of hours work, where provision must be adequate "at all times people are at work"; premises spread across several buildings or floors; remoteness from emergency medical services; employees on sites occupied by other employers, where "A written agreement between employers is strongly recommended"; and cover for planned and unplanned absence. Non-employees closes it: you have no legal duty to the public, "but HSE strongly recommends that you include them in your first-aid provision".
Our post on health and safety tips at the workplace covers the risk assessment this sits inside, and lone working covers the travelling and remote cases.
First aider or appointed person, and when each is enough
An appointed person is the minimum, not a lesser first aider. HSE: "When an employer's first-aid needs assessment indicates that a first-aider is unnecessary, the minimum requirement is to appoint a person to take charge of first-aid arrangements." The role covers "looking after the first-aid equipment and facilities and calling the emergency services when required", plus emergency cover where a first aider is absent for unforeseen reasons. HSE is explicit that "annual leave does not count" as one.
Two limits follow. "To fulfil their role, appointed persons do not need first-aid training." And "Appointed persons are not first-aiders and should not attempt to give first aid for which they have not been trained."
A first aider is "someone who has done training appropriate to the level identified in the needs assessment": first aid at work (FAW), emergency first aid at work (EFAW), or some other appropriate level. Where you have enough of them, HSE says an appointed person "is not necessary".
The two training routes, their durations and requalification
HSE's information sheet Selecting a first-aid training provider (GEIS3(rev2), first published January 2024) sets the durations an employer should check for.
- First aid at work (FAW). Training and assessment "should be at least 18 hours (not including breaks) over a minimum period of three days".
- FAW requalification. The same syllabus, "at least 12 hours (not including breaks) over a minimum period of two days".
- Emergency first aid at work (EFAW). "At least six hours (not including breaks) over a minimum period of one day."
- EFAW requalification. The same syllabus and duration as the initial course, "ie six hours, not including breaks".
GEIS3 also asks employers to check that the certificate carries the training organisation's name, the qualification title, a reference to the Health and Safety (First-Aid) Regulations 1981, the date of issue and "confirmation the certificate is valid for three years".
Annual refresher training is where policies go wrong. HSE's answer to "Is annual refresher training a mandatory requirement?" is: "No. It is strongly recommended to employers to help trained first aiders maintain their basic skills and keep up to date with any changes in first-aid procedures." Strongly recommended is not optional in practice, but it is not a legal requirement, and a policy that claims otherwise invites a challenge.
What changed on 1 October 2013
The original regulation 3(2) said a person was not suitable unless they had undergone "such training and has such qualification as the Health and Safety Executive may approve for the time being". That wording is gone. Regulation 3(2) was substituted with effect from 1 October 2013 by the Health and Safety (Miscellaneous Revocations and Amendments) Regulations 2013 (S.I. 2013/1512), regulation 4, and now ends: "a person shall not be suitable unless he has undergone such training and has such qualifications as may be appropriate in the circumstances of that case."
What changed is the approval step: HSE no longer approves first aid training or qualifications. The duty to provide suitable trained people did not change, so showing the training was appropriate is now your job. That is why GEIS3 frames choosing a provider as due diligence and why HSE states that it "does not advocate, promote or support any particular option". Keep the evidence of the checks you made.
The first aid box: no legal contents list
HSE: "There is no mandatory list of items to put in a first-aid box. It depends on what you assess your needs to be." As a guide, where work activities involve low level hazards, INDG214 suggests a leaflet giving general guidance on first aid, 20 individually wrapped sterile plasters of assorted sizes, two sterile eye pads, four individually wrapped triangular bandages, six safety pins, two large sterile unmedicated wound dressings, six medium sized sterile unmedicated wound dressings and at least three pairs of disposable gloves. HSE calls that "a suggested contents list only".
British Standard BS 8599-1 exists for first aid kits, but HSE states it "is not a regulatory requirement under the Health and Safety (First-Aid) Regulations 1981 to purchase kits that comply with this standard". Either a compliant kit or another kit works, so long as the contents match the assessment. Medication is out: "It is recommended that you don't keep tablets and medicines in the first-aid box", and "First aid at work does not include giving tablets or medicines to treat illness", with the single exception of aspirin for a suspected heart attack. On replacement there is no timetable, only this: "Although there is no specified review timetable, many items, particularly sterile ones, are marked with expiry dates. They should be replaced by the dates given."
Telling employees, and who is covered
Regulation 4 is a duty in its own right and it is cheap to meet. HSE: "You have to inform your employees of the arrangements you have put in place for first aid. Putting up notices telling staff who and where the first-aiders or appointed persons are, and where the first-aid box is, will usually be enough." It adds that you "will need to make special arrangements to give first-aid information to employees with reading or language difficulties". Most organisations also restate the arrangements in the handbook, which our post on the employee handbook covers.
Self-employed people are covered by regulation 5, which requires equipment "adequate and appropriate in the circumstances to enable him to render first-aid to himself while he is at work". HSE applies it proportionately: low hazard work in your own home means "you would not be expected to provide first-aid equipment beyond your normal domestic needs", while continuous driving may mean "the need to keep a personal first-aid kit in your vehicle".
Homeworkers deserve an accurate answer, because HSE publishes no separate first aid rule for them and its homeworking guidance does not mention first aid at all. They are covered by regulation 3 like any other employee, and where they appear in HSE's own material is the needs assessment checklist, under employees who "travel a lot, work remotely or work alone". The prompt there is to consider personal first aid kits and personal communicators or mobile phones.
Jurisdiction matters. HSE's guidance and the 1981 Regulations cover Great Britain. Northern Ireland has its own instrument: HSENI lists the key legislation as the Health and Safety (First-Aid) Regulations (Northern Ireland) 1982 as amended. The substance is closely aligned, but cite the Northern Ireland Regulations for a Northern Ireland site.
Frequently asked questions
How many first aiders do we legally need?
No law sets a number. HSE's answer is that "There are no hard and fast rules on exact numbers and you will need to take into account all the relevant circumstances of your particular workplace". Regulation 3(2) of the Health and Safety (First-Aid) Regulations 1981 requires "such number of suitable persons as is adequate and appropriate in the circumstances", and your needs assessment decides what that is.
Does HSE publish any numbers at all?
Yes, as suggestions. Table 2 of HSE leaflet INDG214 suggests at least one appointed person for low hazard work with fewer than 25 employees, at least one EFAW trained first aider from 25 to 50, and at least one FAW trained first aider for every 100 employed above 50. For higher hazard work the bands are fewer than 5, 5 to 50, and one FAW first aider for every 50 employed above 50. HSE states that these "are suggestions only".
Is an appointed person the same as a first aider?
No. An appointed person takes charge of the arrangements, looks after the equipment and facilities and calls the emergency services. HSE states that appointed persons "do not need first-aid training" and that they "are not first-aiders and should not attempt to give first aid for which they have not been trained". A first aider has completed training at the level the assessment identified.
How long does a first aid certificate last, and is refresher training required?
Three years. GEIS3 asks employers to check the certificate carries "confirmation the certificate is valid for three years". Annual refresher training is not a legal requirement: HSE's answer is "No. It is strongly recommended to employers to help trained first aiders maintain their basic skills and keep up to date with any changes in first-aid procedures." Requalification is separate, at least 12 hours over two days for FAW and six hours over one day for EFAW.
Can a first aider give painkillers?
No. HSE states that "First aid at work does not include giving tablets or medicines to treat illness", with one exception, aspirin given to a casualty with a suspected heart attack in accordance with currently accepted first aid practice. HSE also recommends that tablets and medicines are not kept in the first aid box.
Do the Regulations cover self-employed people and members of the public?
Self-employed people, yes, under regulation 5. Members of the public, no: HSE states the Regulations "do not require employers to provide first aid for members of the public", but "strongly recommends that employers include the public in their first-aid needs assessment and make provision for them".
Your next step: write the assessment, then size the provision
- Split the site by hazard level, starting from your general risk assessment. Offices and shops take the low hazard column; engineering, warehousing, construction and chemical work take the higher hazard one.
- Work through HSE's five headings in writing: hazards, employees, accident and ill health records, working arrangements, non-employees. One dated page is enough.
- Only then look at Table 2, as a starting point. Add for shift patterns, multiple buildings, remote sites and absence cover, which HSE names as reasons to go above the suggestion.
- Decide the level for each person, appointed person, EFAW or FAW, and record why. That is the decision you will be asked to justify.
- Diary the three year expiries and the recommended annual refresher now, name who covers each first aider during leave, put up the regulation 4 notice, and set a review date tied to any change of site, activity or headcount.
For the handbook section that carries the first aid arrangements, read and download our employee handbook guide. The guide is free to read, and the PDF uses our short download form.
Want certificate expiries, refresher dates and cover arrangements to leave a trail rather than live in one manager's inbox? Book a New Dynamics demo and bring your current first aid needs assessment. You can also email contact@new-dynamics.com.
