What first aid is required on Ontario construction sites?

Two regulations apply. Regulation 1101 under the Workplace Safety and Insurance Act sets the baseline — at least one qualified first aider per shift, a stocked first aid kit, and the required postings. Regulation 213/91 under the Occupational Health and Safety Act governs construction projects more broadly, including emergency response and competent supervision requirements. The practical effect: every Ontario construction project covered by WSIB needs at least one Standard First Aid + CPR-certified worker on every shift (or Emergency First Aid + CPR for shifts of 1–5 workers), plus an accessible first aid kit and clear emergency protocols.

Does Regulation 213/91 have specific first aid kit requirements?

Regulation 213/91 is the general Construction Projects regulation, covering everything from fall protection to scaffolding to emergency procedures. The specific first aid kit contents come from Regulation 1101's Schedule 1, which lists the required items by workplace size. In practice, Ontario construction sites maintain kits that meet the Reg 1101 minimum and add construction-specific items — extra burn dressings, larger trauma supplies, eye irrigation, and additional bandaging for the typical construction injury profile.

Do site supervisors need to be first aid certified?

There's no explicit blanket requirement under Reg 213/91 that every site supervisor must hold first aid certification. However, site supervisors are typically the 'competent person' under OHSA for the work they direct, and Reg 1101's requirement for at least one certified first aider per shift effectively means a designated worker on every shift is trained. In practice, most Ontario construction companies train every site supervisor and foreman in Standard First Aid + CPR regardless of crew size, because supervisors are on every project and crew size varies day-to-day.

Do small contractors and sole proprietors need first aid coverage?

If you have any employees on payroll, yes — Reg 1101 applies the moment you have a worker working for you. Sole proprietors working alone in their own business are not covered by Reg 1101 (the regulation applies to workplaces with workers). For very small crews (1–5 workers per shift), Emergency First Aid + CPR satisfies the requirement; for 6+ workers on a shift, Standard First Aid + CPR is required. Most small construction contractors train themselves and at least one other worker so coverage is always present.

Do projects on the same site count separately?

Each Ontario construction project is treated as its own workplace for compliance purposes, though there are nuances when multiple contractors share a project. Under Reg 213/91, the constructor (often the GC) has overall responsibility for the project's health and safety program — including ensuring first aid coverage is in place. Subcontractors typically maintain their own first aid coverage for their own employees, with coordination through the constructor. Larger projects often have JHSC oversight that includes first aid planning.

Construction

Construction First Aid in Ontario: A Compliance Guide for GCs and Site Operators

How Regulation 1101 and Regulation 213/91 interact, and what compliance actually looks like on an Ontario construction project.

Quick Answer

Ontario construction projects are covered by two regulations: Regulation 1101 (under the Workplace Safety and Insurance Act) sets the baseline workplace first aid requirements — kits, certified workers, postings. Regulation 213/91 (under the Occupational Health and Safety Act) governs construction project safety broadly, including supervision, emergency procedures, and project-specific obligations. Practically: every project needs at least one Standard First Aid + CPR-certified worker per shift (Emergency FA for 1–5 worker shifts), a Reg 1101–compliant kit on site, and clear emergency protocols. Most operators train more than the minimum because crew size and supervisor coverage vary day-to-day.

The two regulations, in one paragraph

Ontario construction sits at the intersection of two regulatory frameworks. Regulation 1101, made under the Workplace Safety and Insurance Act, governs workplace first aid — first aid kits, certified first aiders per shift, postings, and basic emergency response. Regulation 213/91, made under the Occupational Health and Safety Act, governs construction projects specifically — fall protection, scaffolding, excavation, supervision, emergency procedures, JHSC requirements, and the project-wide safety obligations of constructors and employers. The first aid kit contents and the “certified first aider per shift” rule come from Reg 1101; the broader site safety program and the responsibilities of the constructor come from Reg 213/91.

The Reg 1101 baseline applied to construction

Workers on a shift	Minimum certified first aiders	Required certification
1–5	1	Emergency First Aid + CPR C AED
6+	1 (minimum)	Standard First Aid + CPR C AED
Multiple shifts	1 per shift	Each shift independently meets the requirement

Reg 1101 also requires a first aid kit on every workplace, sized to the workforce. Schedule 1 of the regulation lists the kit contents — bandages, gauze, antiseptic, gloves, scissors, and so on, with required quantities by workplace size.

Where construction differs from a typical workplace

Construction adds operational realities that a fixed workplace doesn’t face:

Site locations change. Today’s project is in Etobicoke; next month’s is in Hamilton; the one after is a remote site in Northern Ontario. The first aid coverage and kit travel with the project, not the worker.
Crew size varies daily. A residential framing crew might be 4 today and 8 tomorrow. The certification level needed (Emergency FA vs Standard FA) changes with crew size.
Multiple employers on one project. A typical GC project has a general contractor plus 10–30 subcontractors. Each employer has its own Reg 1101 obligations for its own workers, but the constructor coordinates the overall site safety program under Reg 213/91.
Higher injury risk profile. Construction has consistently higher injury rates than most other sectors. Falls, struck-by injuries, lacerations, crush injuries, burns from welding, eye injuries from grinding, electrical incidents. Standard First Aid + CPR training addresses every one of these scenarios.
Remote and isolated sites. EMS response time on a downtown Toronto project is 5–7 minutes. On a rural or remote project, it can be 30+ minutes. The first aid coverage needs to bridge that gap.

The constructor’s responsibility under Reg 213/91

On most Ontario construction projects, one entity is the “constructor” — typically the general contractor, sometimes the owner if they’re managing the project directly. The constructor has overall responsibility under OHSA for the project’s health and safety program, including:

Notifying the Ministry of Labour, Immigration, Training and Skills Development of the project (Form 1000 / Notice of Project for projects over certain thresholds)
Ensuring all workers are trained appropriately for the work assigned to them
Coordinating with subcontractors on overlapping health and safety obligations
Maintaining the joint health and safety committee (JHSC) for projects with 20+ workers
Ensuring emergency procedures are in place — including first aid response, evacuation, rescue from confined spaces and at height, and EMS access

The constructor doesn’t directly provide first aid coverage for subcontractors’ workers — that’s the sub’s own Reg 1101 obligation — but the constructor ensures coordination so the site has appropriate coverage during all work hours.

The competent person concept

OHSA refers to the “competent person” — someone who is qualified by knowledge, training, and experience to perform the work, is familiar with the OHSA provisions that apply, and has knowledge of any potential or actual danger to health or safety in the workplace. On construction projects, the competent person standard applies to supervisors and senior workers directing other workers.

The competent person framework doesn’t strictly require first aid certification — but in practice, construction supervisors and foremen are almost always trained in Standard First Aid + CPR because:

They’re on every project regardless of crew size, providing reliable Reg 1101 coverage
They’re the first line of decision-making during emergencies
They coordinate with EMS when paramedics arrive
They often coordinate emergency response across multiple trades on multi-employer sites

See our site supervisor post for the detailed competent person analysis.

Project size thresholds that affect compliance

Several construction-specific thresholds change what’s required at a project:

Notice of Project (NOP)

Construction projects above certain thresholds require the constructor to submit a Notice of Project to the Ministry before work begins. The current thresholds (subject to regulatory updates) include projects with an expected duration of 3 or more months, project value over a specific dollar amount, projects involving Designated Substances, work at depth or height above set parameters, and certain other criteria. The NOP doesn’t directly mandate first aid — but projects that require an NOP also typically warrant more comprehensive emergency planning.

JHSC requirement at 20 workers

Construction projects employing 20 or more workers at the project for 3 months or longer must have a Joint Health and Safety Committee (JHSC). The JHSC includes worker-elected and employer-appointed representatives and reviews health and safety practices on site — including first aid coverage adequacy and emergency response planning.

Reg 1101 thresholds based on crew size

The 6-worker threshold for Standard First Aid + CPR applies on construction the same as anywhere — but crew size on construction varies dramatically through the project lifecycle. A foundation crew of 4 becomes a framing crew of 10 becomes a finishing crew of 25. Most operators train Standard FA + CPR for supervisors and a percentage of trades workers regardless of any given day’s crew size.

IHSA industry best practice

The Infrastructure Health & Safety Association (IHSA) provides industry-specific guidance for Ontario construction beyond the regulatory minimums. IHSA’s safety programs include:

The COR (Certificate of Recognition) certification program for construction safety management systems
Working at Heights training (mandatory for many construction workers under separate Ontario regulation)
Construction-specific first aid and emergency response guidance
Industry safety standards exceeding the regulatory baseline

Most large GCs follow IHSA-aligned safety programs. Small contractors and sub-trades vary in how closely they align to IHSA best practice — but compliance with the regulatory baseline (Reg 1101 + Reg 213/91) is the floor for everyone.

Common construction first aid scenarios

The injury profile that shapes construction first aid training:

Lacerations from tools, sharp materials, broken glass — leading cause of construction medical visits
Eye injuries from grinding, welding flash, debris — requires eye irrigation supplies and prompt response
Burns from welding, cutting torches, hot bitumen, chemical exposure
Crush and struck-by injuries from falling materials, moving equipment, swinging loads
Falls from heights — head injuries, fractures, spinal injuries; immobilization principles matter
Heat illness in summer outdoor work; cold exposure in winter work
Electrical incidents — burns, cardiac arrhythmias, falls following shock
Cardiac events in older trades workers under physical exertion
Confined space and chemical exposure incidents requiring rescue procedures

How most Ontario construction operators handle training

Every supervisor, foreman, and lead hand trained in Standard First Aid + CPR — provides reliable per-shift coverage regardless of crew size
A percentage of trades workers (typically 10–20%) trained in Emergency or Standard First Aid for redundancy
On-site sessions during planned shutdowns — winter slowdown for outdoor builders, post-completion before next project mobilization
Saturday morning training cohorts for crews that can’t afford a weekday off the site
Recertification scheduled annually as part of company-wide safety meeting cycles
New hires put through certification within their first 30–60 days as standard onboarding

Documentation construction sites need

WSIB Form 82 posted at the site office trailer or main entrance, listing designated first aiders
Photocopies of current first aid certificates beside Form 82
First aid kit location signage at the site trailer and major work areas on multi-zone projects
Emergency response procedures document covering first aid response, EMS access, and incident escalation
For NOP projects: the Notice of Project submission and site-specific safety documentation
For 20+ worker projects: JHSC records, meeting minutes, and site inspection reports

Note: This article is a plain-language overview. Regulation 1101 (under the Workplace Safety and Insurance Act) and Regulation 213/91 (under the Occupational Health and Safety Act) are the legal sources — review the regulations themselves or consult a construction health and safety advisor for compliance specific to your operation. IHSA also publishes detailed construction-specific guidance.

Pricing for construction on-site training

Course	Public open class	On-site (8–20 workers)
Standard First Aid + CPR	$120/person	$70–$130/person
Emergency First Aid + CPR	$85/person	$60–$100/person
CPR Level C only	$35/person	$25–$55/person

Get a quote for your construction operation

On-site Standard First Aid + CPR for site supervisors, foremen, and trades teams. Scheduled around your project calendar — winter shutdown, between mobilizations, or Saturday cohorts.

Request a Construction Quote

Frequently Asked Questions

What first aid is required on construction sites?

Reg 1101 baseline (kit, certified first aiders per shift) plus Reg 213/91 broader project safety program. Most operators train more than the minimum.

Do supervisors need to be certified?

Not strictly required as a blanket rule, but supervisors are almost always trained in Standard First Aid + CPR as best practice.

What if my crew is sometimes 4 and sometimes 10?

Train Standard FA + CPR to cover the 6+ scenario. Once trained, the certification covers smaller crews too.

Who’s responsible on multi-contractor sites?

Each employer is responsible for first aid for their own workers; the constructor coordinates site-wide.