Under the Health and Safety (First Aid) Regulations 1981, every employer in the UK must ensure adequate first aid equipment, facilities, and trained personnel are available to give immediate assistance to employees who are injured or taken ill at work.
But "adequate" is deliberately vague — because what's adequate for a 5-person accountancy firm in Clitheroe is very different from what's needed on a 200-person manufacturing floor in Burnley. That's where the first aid needs assessment comes in.
This guide covers every factor you need to consider, with practical guidance for Lancashire businesses across all sectors.
What Is a First Aid Needs Assessment?
A first aid needs assessment is a structured review of your workplace that answers one core question: what first aid provision does my business actually need?
It is not a generic checklist. It is specific to your workplace, your workforce, and your hazards. The HSE's guidance document L74 (First Aid at Work) sets out the factors you must consider — and we'll work through each one below.
Key legal point
The HSE does not prescribe a minimum number of first aiders or a specific course for every workplace. Instead, it requires you to assess your own needs and provide what is "adequate and appropriate." This means your needs assessment is the legal foundation for all your first aid decisions.
The 8 Factors the HSE Requires You to Consider
Workplace Hazards and Risk Level
This is the single most important factor. The HSE divides workplaces into two broad categories:
Low-risk workplaces include offices, retail units, libraries, schools, and professional services. The main hazards are slips, trips, and minor injuries.
Higher-risk workplaces include manufacturing, construction, warehouses, engineering, agriculture, care homes, and any environment with machinery, chemicals, or significant physical hazards.
Your risk level determines whether EFAW (1-day) or FAW (3-day) is the appropriate qualification for your first aiders.
Number of Employees
More employees generally means more first aiders are needed. The HSE's indicative guidance (not a legal minimum) is:
For low-risk workplaces: fewer than 25 employees — an appointed person may suffice; 25–50 employees — at least one EFAW first aider; over 50 employees — one FAW first aider per 50 employees.
For higher-risk workplaces: 5–50 employees — at least one FAW first aider; over 50 employees — one FAW first aider per 50 employees.
Remember: these are starting points, not ceilings. Your specific hazards may require more cover.
Shift Patterns and Working Hours
First aid cover must be available at all times when employees are at work — not just during core hours.
If you operate early morning, late evening, night shifts, or weekend working, you need trained first aiders on each shift. A single first aider who works 9–5 Monday to Friday does not provide adequate cover for a 24/7 operation.
Practical tip: train more first aiders than the minimum so you have cover for holidays, sickness, and shift changes. A good rule of thumb is to have at least 50% more trained first aiders than your minimum requirement.
Lone Workers
Lone workers present a specific challenge. If an employee is injured while working alone, there may be no one available to provide immediate first aid or call for help.
Your needs assessment must address lone workers specifically. Measures may include: ensuring lone workers hold their own first aid qualification, providing personal first aid kits, implementing check-in procedures, and using lone worker monitoring devices.
This is particularly relevant for delivery drivers, field service engineers, care workers visiting clients at home, and agricultural workers across rural Lancashire.
Workplace Geography and Layout
Large or multi-site workplaces need first aid provision at each location — not just at head office.
Consider: how long would it take a first aider to reach any employee in your workplace? In a large warehouse or multi-floor building, a single first aider may not be able to reach an injured person quickly enough.
If your business operates across multiple sites in Lancashire — for example, a care provider with homes in Burnley, Nelson, and Clitheroe — each site needs its own first aid provision.
Proximity to Emergency Services
How quickly can an ambulance reach your workplace? In urban areas of Lancashire like Burnley or Nelson, response times may be 8–12 minutes. In rural areas of the Ribble Valley or the Forest of Bowland, it could be significantly longer.
The further you are from emergency services, the more important it is to have well-trained first aiders on site who can provide sustained care while waiting for an ambulance. Remote workplaces should strongly consider FAW over EFAW, regardless of risk level.
Members of the Public and Visitors
The Health and Safety (First Aid) Regulations technically only require provision for employees — not members of the public. However, if your workplace is open to the public (retail, hospitality, leisure, schools), you have a duty of care under other legislation.
Practically speaking, if a customer collapses in your shop or a visitor has a medical emergency at your premises, your first aiders will respond. Ensure your provision is adequate for the realistic population of people on your site at any given time.
History of Accidents and Incidents
Review your RIDDOR records and accident book. What types of injuries have occurred? How frequently? Are there patterns — particular tasks, times of day, or areas of the workplace where incidents cluster?
If your accident history shows a pattern of serious injuries, this is strong evidence that you need FAW-trained first aiders rather than EFAW, regardless of your general risk classification.
Your accident history is also useful evidence that you have carried out a genuine needs assessment — not just ticked a box.
EFAW or FAW? A Practical Decision Guide
Once you've worked through the 8 factors above, you'll have a clear picture of your risk level. Use this guide to determine the right qualification:
1-Day Course
EFAW is right for you if…
- Office, retail, or professional services environment
- Fewer than 50 employees at low risk
- No significant machinery, chemical, or physical hazards
- Close to emergency services (urban Lancashire)
- No history of serious workplace injuries
- Staff work standard daytime hours
3-Day Course
FAW is right for you if…
- Manufacturing, construction, warehouse, or engineering site
- Care home, healthcare, or social care setting
- More than 50 employees in any environment
- Significant machinery, chemical, or physical hazards present
- Rural location with longer emergency service response times
- Shift work, night shifts, or 24/7 operations
- History of serious injuries in your accident records
When in doubt, choose FAW. The cost difference between EFAW and FAW is modest, but the difference in capability is significant. A FAW-trained first aider can manage a much wider range of emergencies — and in a genuine crisis, that breadth of training can be the difference between life and death.
What Is an "Appointed Person" — and Is That Enough?
An appointed person is someone designated to take charge in an emergency — calling 999, managing the situation, and looking after first aid equipment — but who is not required to hold a first aid qualification.
The HSE says an appointed person may be sufficient for very small, low-risk workplaces (typically fewer than 25 employees in a low-hazard environment). However, this is the absolute minimum — and it means that in a genuine medical emergency, no one on site is trained to provide first aid.
Important caveat
Relying on an appointed person alone is a high-risk strategy. If an employee suffers a cardiac arrest and no one on site can perform CPR, the consequences — both human and legal — can be severe. Even for very small businesses, we strongly recommend at least one EFAW-trained first aider.
First Aid Equipment: What Does Your Assessment Need to Cover?
Your needs assessment should also determine what first aid equipment you need. The HSE does not specify a mandatory list, but your assessment should consider:
First Aid Kits
At minimum, a stocked first aid kit in every work area. Higher-risk workplaces may need multiple kits, eye wash stations, and specialist equipment such as tourniquets or burn dressings.
Defibrillators (AEDs)
The HSE does not legally require AEDs, but they are strongly recommended for workplaces with 50+ employees, remote locations, or where employees are at elevated cardiac risk. Many Lancashire businesses now have them as standard.
Eye Wash Stations
Required wherever employees work with chemicals, dust, or other substances that could cause eye injury. COSHH assessments will identify where these are needed.
Accident Book
A legal requirement under RIDDOR. All injuries, near misses, and first aid treatments must be recorded. This record also feeds back into future needs assessments.
Sector-Specific Guidance for Lancashire Businesses
Manufacturing & Textiles (Burnley, Nelson, Colne)
FAW (3-day)Higher-risk environment with machinery, manual handling, and chemical hazards. FAW is almost always the appropriate qualification. Ensure cover across all shifts. Consider additional training in burns, eye injuries, and crush injuries relevant to your specific processes.
Offices & Professional Services
EFAW (1-day)Low-risk environment. EFAW is typically sufficient for teams under 50. Ensure cover is available throughout working hours. If you have a large open-plan office with 50+ staff, consider having 2–3 EFAW-trained first aiders to ensure coverage.
Care Homes & Healthcare (across Lancashire)
FAW (3-day)Despite not being a traditional 'high-risk' environment, care homes deal with complex medical emergencies involving vulnerable residents. FAW is strongly recommended. Ensure cover across all shifts including nights and weekends.
Schools & Nurseries
Paediatric First Aid + EFAWSchools need both Paediatric First Aid (OFSTED requirement) and EFAW for staff. Nurseries must have at least one Paediatric First Aid-trained person on the premises at all times when children are present. Schools should also have EFAW-trained staff for adult emergencies.
Hospitality & Events (Clitheroe, Ribble Valley)
EFAW minimum; FAW for larger venuesRestaurants and pubs: EFAW is typically sufficient. Larger event venues, wedding venues, and conference facilities should consider FAW given the volume of public present. Ensure cover during all service hours including evenings and weekends.
Construction & Engineering
FAW (3-day) — mandatoryConstruction is one of the highest-risk sectors. FAW is effectively mandatory. The Construction (Design and Management) Regulations 2015 require specific first aid provisions on construction sites. Ensure first aiders are present on site at all times when work is in progress.
How to Document Your Needs Assessment
The HSE does not require a specific format, but your documentation should cover:
- 1Business details: Name, address, number of employees, industry sector, and working hours.
- 2Hazard identification: List the main hazards present in your workplace and their associated risks.
- 3Risk level conclusion: State whether your workplace is low-risk or higher-risk, with brief justification.
- 4First aider requirements: State how many first aiders you need, at what qualification level, and on which shifts.
- 5Named first aiders: List the names of your trained first aiders, their qualification, and certificate expiry dates.
- 6Equipment provision: List first aid kits, AEDs, eye wash stations, and their locations.
- 7Review date: State when the assessment will next be reviewed (at minimum annually, or after any significant change).
Frequently Asked Questions
What is a first aid needs assessment?
A first aid needs assessment is a structured review of your workplace that determines what first aid provision you legally need. It considers your workplace hazards, number of employees, shift patterns, lone workers, and proximity to emergency services. The HSE requires all employers to carry one out under the Health and Safety (First Aid) Regulations 1981.
How many first aiders do I need?
There is no fixed legal ratio, but the HSE provides guidance. Low-risk workplaces with fewer than 25 employees may only need an appointed person. Low-risk workplaces with 25–50 employees should have at least one EFAW-trained first aider. Higher-risk workplaces with 5–50 employees need at least one FAW-trained first aider. Above 50 employees in higher-risk settings, you need one FAW first aider per 50 employees.
Is EFAW or FAW right for my business?
EFAW (1-day) is suitable for low-risk workplaces such as offices, small retail units, and professional services. FAW (3-day) is required for higher-risk environments including manufacturing, construction, warehouses, care homes, and any workplace with significant machinery, chemical, or physical hazards.
Do I need to document my first aid needs assessment?
Yes. While the HSE does not prescribe a specific format, you should document your assessment findings and keep them on file. This demonstrates due diligence and is essential evidence during HSE inspections or in the event of a workplace incident.
What happens if I don't have adequate first aid provision?
Failing to provide adequate first aid is a breach of the Health and Safety (First Aid) Regulations 1981. The HSE can issue improvement notices, prohibition notices, or prosecute employers. In the event of a serious workplace injury, inadequate first aid provision can significantly increase employer liability.
Do lone workers need first aid cover?
Yes. Lone workers present a specific challenge because a trained first aider may not be immediately available. Your needs assessment must account for lone workers and put in place appropriate measures — this may include remote first aid training, check-in procedures, and ensuring lone workers carry personal first aid kits.
How often should I review my first aid needs assessment?
You should review your needs assessment whenever there is a significant change to your workplace — new processes, new hazards, changes in staff numbers, new shift patterns, or a move to new premises. As a minimum, review it annually alongside your general risk assessment.
Related Reading
How Often Do You Need to Renew First Aid Certificates?
EFAW, FAW, Paediatric, and Fire Marshal renewal timelines explained.
EFAW vs FAW: Which First Aid Course Do You Need?
A detailed comparison of the two main workplace first aid qualifications.
Workplace First Aid Courses
Book EFAW or FAW training delivered on-site at your Lancashire workplace.
Need Help With Your First Aid Needs Assessment?
PS Training Services works with Lancashire businesses of all sizes to determine the right first aid provision and deliver accredited training on-site at your premises. Call us for a free, no-obligation conversation about your requirements.