Ask DSC: Is First Aid training mandatory?

ASK DSC: I’ve got a simple question, which I suspect is not going to have a simple answer: are frontline disability support required to have up-to-date first aid training?

By far the most common question I get asked, when working on consultancy projects and facilitating training, is “do support workers need first aid training?”

So, I guess this is topical.

The short answer is = no. There is no specific requirement for support workers to complete first aid training. BUT, as you rightly guess, in practice it’s a bit more complex than that.

First let’s clarify the difference between a nominated first aid officer and a worker who has first aid duties as part of their role.

Nominated first aid officer

A nominated first aid officer is a person who has been asked to take on the responsibility of being the go-to person in the team if someone needs first aid. Plus, they would look after the first aid supplies. Under most awards. this person is paid an extra allowance.

If you have a nominated first aid officer, you will need some way to capture if the worker has completed the first aid course, and then monitor that their annual CPR and the three yearly full refresher courses are completed on schedule. You will also need to have a system to ensure that if the person moves roles or leaves, that another worker is assigned the role.

To determine if you need a nominated first aid officer or not, refer to the relevant code of practice for your state or territory. In Victoria that is the First aid in the workplace compliance code (worksafe.vic.gov.au), for other jurisdictions either refer to model Code of Practice: First aid in the workplace or visit your state/territories relevant WHS agencies website.

The codes also list the minimum number of nominated first aid officers each work site should have. (Note these are workers on site, not the total number employed).

In Victoria

• 1 first aid officer for every 10–50 employees.
• 2 for every 51–100 employees.  
• 3 for every 200 employees.
• An additional first aid officer for every extra 100 employees.

For other jurisdictions

One first aid officer for every:

• 50 workers in low-risk workplaces. 
• 25 workers in high-risk workplaces. 
• 10 workers in remote high-risk workplaces.

To assist you to assess your needs, the Model Code of Practice: First aid in the workplace has a sample risk assessment. 

What about frontline workers?

A support worker who may be required to respond to an emergency and provide basic first aid to a participant, is not classified as a nominated first aid officer.

And the NDIS Practices standards do not specifically state that workers need to be first aid trained.

But, if something were to go wrong, an investigator (e.g., SafeWork/WorkSafe, Coroner, NDIS Commission etc.) might ask why workers were not trained in First Aid and how you came to the decision not to train them. So, the responsibility really is on the employer to be satisfied that the worker is adequately trained for the work they are doing.

So how do employers make this assessment? As with everything safety related - start with a risk assessment.

Assess the impact if something goes wrong. You may consider things such as:

• Could a participant be seriously injured/ill or die if they do not have urgent first aid attention?
• How would workers feel if they had to support a participant who required first aid and they did not have the skills to assist them?
• What would the impact be on your reputation?
• Are there financial or legal implications?

Assess the likelihood of something going wrong. You may consider things such as:

• How often in the past have participants required first aid assistance?
• The age and health conditions of the people you support.
• What health support needs they have – does this include high intensity support?

Identify what other control measures you have in place such as:

• Are there alternative, readily available medical treatment options or is the worker working in a remote or isolated location?
• Are workers part of a team or working alone?

What other considerations are there?

What the NDIS Commission expects.

The Code of Conduct requires supports and services to be provided in a safe and competent manner, with care and skill. The Guidance for NDIS Providers states, that this means having the relevant training.

The NDIS Practice Standards require registered providers to demonstrate that:

• Risks to participants, workers and the provider are identified and managed.
• Participant’s support needs are met by workers who are competent in their role and hold relevant qualifications.
• Protocols are in place for each participant on how to respond to medical emergencies for them.
• Each worker providing support to them is trained to respond to such emergencies (including how to distinguish between urgent and non-urgent health situations).

High Intensity Skills

If you are registered to provide support listed under the High Intensity Skill Descriptors, you have additional requirements due to the increased risks and skills involved.

In summary these include:

Dysphagia Support

• Up to date first aid knowledge and techniques for suspected choking including how to promptly identify choking and clear airways of food.

Ventilator Support

• Follows emergency procedures to apply basic first aid or initiating cardiopulmonary resuscitation and basic life support if required.

Tracheostomy

• First aid techniques to check and clear airways, administer CPR, and place a person in a recovery position.
• Applies basic first aid and initiates CPR and basic life support if required.

Epilepsy/ Seizure Management

• First aid techniques to check and clear airways, administer CPR, and place a person in a recovery position.

For further details refer to the High Intensity Skills Descriptors which are available at: www.ndiscommission.gov.au/providers/registered-ndis-providers/provider-obligations-and-requirements/ndis-practice-standards-1#paragraph-id-2433

What does the participant expect?

Participants have the right to be supported in the way they want, including if they would prefer support workers to have current First Aid qualifications.

Why don’t you ask your participants what they think? You may be surprised by their response! And the NDIS Practice Standards do require that registered providers provide opportunities for participants to have input into the development of organisational policy and processes relevant to the provision of supports.

What do the WHS laws require?

Providers have a legal duty to take all reasonable steps to keep participants, as well as workers and others safe. This again includes a requirement to identify and manage risks.

WHS laws also require that you consult your workers on your risk assessment, and that you review it regularly. 

To assist you to monitor and review, I suggest that you capture it as part of your risk register (if you have one).

So, you decide to make First Aid Mandatory

Is this everyone, just support workers, or people who work alone, or who support clients with high-risk health support needs?

If you are only training  a selected group, then you will need to have a process in place to monitor and roster the right people for certain shifts. Also, think about if you’ll also require back-up workers, irregular causal workers and/or agency staff to complete first aid training.

You may also decide whether you want workers to complete the annual CPR refresher or just the refresher every three years. When making this decision, assess the risk i.e., the health support needs of participants, and the likely emergency response a worker may be required to take.

Finally, check what your policy and procedures say. If you have a document that says - yes everyone is trained, then this is what the auditor is going to expect to see, and they will ask for evidence. So, whether you decide to train workers or not, check and update your policies, procedures, and training plans etc., to reflect reality.  Because we often see audit nonconformities arise from organisations not implementing their policies and procedures consistently.

Whatever way you go, your decision must be considered and consistent.

Got a question you want answered by one of our NDIS Whizkids? Submit it here!