Federal First Aid Kit Rules Harmonized

Summary#

The government published the proposed Regulations Amending Certain Regulations Made Under the Canada Labour Code (First Aid Kits) on October 3, 2026. The change would make federally regulated workplaces follow the CSA Standard Z1220 for first aid kits, replacing old lists of required kit contents in five federal occupational health and safety rules.

What it does#

• Replaces the current federal lists of required first-aid items in five OHS regulations with an ambulatory incorporation of CSA Standard Z1220. The five regulations affected are:
  • Canada Occupational Health and Safety Regulations
  • On Board Trains Occupational Health and Safety Regulations
  • Oil and Gas Occupational Safety and Health Regulations
  • Maritime Occupational Health and Safety Regulations
  • Aviation Occupational Health and Safety Regulations
• Requires employers to use a workplace first-aid risk assessment to choose one of the kit types in the Standard (Type 1 — personal, Type 2 — basic, Type 3 — intermediate) and to size kits by number of workers per shift.
• Repeals old schedules and tables that list specific kit contents in those five regulations.
• Updates the Administrative Monetary Penalties (Canada Labour Code) Regulations to match the new rules so the Labour Program can enforce them.
• Gives employers a one-year transition period after the regulations come into force to keep using existing kits.
• This is a proposed change. The Canada Gazette notice invited comments within 30 days of publication.

Who's affected#

• Employers and workplaces under the Canada Labour Code (federally regulated sectors). That includes, for example:
  • air, rail and road transport
  • marine transportation and ports
  • pipelines and grain handling
  • banks and many federal Crown corporations
  • postal and courier services
  • some mines and resource operations
  • First Nations band councils and other workplaces under federal control
• The government estimates approximately 20,738 workplaces in scope.
• Small businesses are included; about 18,188 small federally regulated employers would be affected. The average incremental cost per small business is estimated at about $155 (present value over 10 years) under the government’s analysis.

Why it matters#

• It harmonizes federal rules with all provinces and territories. That makes it easier for employers that operate in multiple jurisdictions to buy and manage first aid supplies.
• Kits will be chosen based on workplace risk. Higher-risk workplaces will be more likely to have trauma supplies (tourniquets, large dressings, etc.), while low-risk workplaces keep basic supplies. That should improve readiness for real injuries.
• There is a modest cost to employers for switching or upgrading kits. The government estimates total incremental costs of about $4.8 million in present value over a 10-year period (annualized about $685,000). Many employers already meet the Standard, so actual impacts will vary.
• The Standard will be incorporated on an ambulatory basis. That means future updates to CSA Standard Z1220 would automatically apply in the federal regulations, keeping kit contents current without repeating regulatory amendments.
• Employers should watch the comment period and the coming-into-force timing. The proposal allows a one-year transition so most workplaces have time to adjust.