First aid and CPR on a crew working near energized conductors

Sep 21

16 min read

Section 3421(m) of Title 8 requires at least two persons trained in first aid and CPR for field work involving two or more employees, and gives a new hire 90 days. 29 CFR 1910.269(b)(1)(i) counts the same two and defines first-aid training to include CPR. California's one person exception reaches only a supervised trainee.

A two-person crew is parked on a shoulder at 9:40 on a Tuesday. One trimmer is in the bucket at 38 feet, taking a limb back off a 12 kV primary. The ground worker is feeding the chipper. The nearest ambulance is 22 minutes out on a good day.

California answers what happens in the next four minutes with a count. Two people on that shoulder have to hold current first aid and CPR training, and the rule counts bodies present rather than bodies free to help. If the ground worker's card lapsed in March, that crew was already noncompliant when it pulled out of the yard.

The California sentence, and the four duties inside it

The employer shall provide training in first aid and cardiopulmonary resuscitation (CPR). For field work involving two or more employees at a work location at least two trained persons in first aid and CPR shall be available. All new employees shall be trained in first aid and CPR within 90 days of their hiring dates. First aid and CPR training shall be performed by a certified instructor and shall be equal to that of the American Red Cross or the Mine Safety and Health Administration.

That is section 3421(m) of Title 8, quoted in full. Four sentences, and each one is a separate duty.

Sentence	What it requires	What fails it
First	The employer provides first aid and CPR training	Telling a hire to go get certified on their own time
Second	Two trained persons available for field work with two or more employees	A crew of two carrying one current card
Third	Every new employee trained within 90 days of hire	A hire dated March 2 with a course date of July 8
Fourth	A certified instructor, at a level equal to Red Cross or MSHA	An online-only completion certificate

The second sentence is the one an evaluator counts. It attaches to the work location rather than to the company, so a five-person crew that splits into two trucks has created two work locations and owes two carded people in each. The third sentence attaches to a hire date, which means the clock lives in payroll rather than in the safety binder. That is why it is the one that quietly runs out.

Section 3421 sits in Article 12 of the General Industry Safety Orders, and Article 12 follows a line clearance crew into its work rather than stopping at the edge of it. The current text of the section was filed September 25, 2012, and became operative on October 25, 2012.

Cal/OSHA restates the same count in its own field publication. The Tree Work Safety Guide puts the subject on the list a crew is trained in, and prints two bullets under it:

First aid and cardiopulmonary resuscitation (CPR). At least two trained workers must be available in a crew of two or more at a given work site. Training must be given within 90 days of hire.

That is the Division's own summary of subsection (m), and it stops where the subsection stops.

The federal sentence, and the definition that puts CPR inside it

For field work involving two or more employees at a work location, at least two trained persons shall be available. However, for line-clearance tree trimming performed by line-clearance tree trimmers who are not qualified employees, only one trained person need be available if all new employees are trained in first aid within 3 months of their hiring dates.

That is 29 CFR 1910.269(b)(1)(i). It writes first aid and stops there. The words cardiopulmonary resuscitation live in paragraph (x), where the section defines its own vocabulary:

First-aid training. Training in the initial care, including cardiopulmonary resuscitation (which includes chest compressions, rescue breathing, and, as appropriate, other heart and lung resuscitation techniques), performed by a person who is not a medical practitioner, of a sick or injured person until definitive medical treatment can be administered.

So the federal count is a CPR count too, by definition rather than by wording. OSHA reads its own rule that way. A memorandum of February 22, 1999 from Richard Fairfax to Regional Administrator Richard S. Terrill calls paragraph (b)(1) "the CPR and first aid provisions." That definition sentence appears in OSHA's final rule of April 11, 2014, published at 79 FR 20316, and a full-text search of the Federal Register returns that document alone for it.

Paragraph (b) reaches both federal tiers of trimmer. Paragraph (a)(1)(i)(E)(2) lists the eight paragraphs that apply "when performed by line-clearance tree trimmers who are not qualified employees," and (b) is among them. Which tier a name sits in changes the approach distance and leaves the first aid count alone.

The gate sits at 50 volts

Paragraph (b)(1) opens with a condition:

When employees are performing work on, or associated with, exposed lines or equipment energized at 50 volts or more, persons with first-aid training shall be available as follows:

OSHA's eTool explains where the number comes from. The requirements "apply when a person is potentially exposed to 50 volts or more, which is the recognized level that can result in enough current to cause cardiac arrest or ventricular fibrillation." The 1999 memorandum ties the threshold back to the rulemaking, where OSHA clarified that the provision was required only for employees exposed to shock hazards while performing work on or associated with lines energized at 50 volts or more.

For this trade the gate is academic. A 120/240 volt secondary hanging off the pole clears 50 volts twice over at its lowest leg, and the 12 kV primary above it clears the threshold by a factor of 240. A crew close enough to a conductor to need an approach distance is over the gate.

California filed its own version with the Electrical Safety Orders

Two more California sections reach the same crew. Section 3400 is the General Industry Safety Orders' medical services rule, and it carries a Note that routes electrical work somewhere else:

Medical services and first aid provisions for electrical workers shall also comply with Sections 2320.10 (Low-Voltage) and 2940.10 (High-Voltage) as applicable.

Section 2940.10 is California's answer to 29 CFR 1910.269(b), and it names this work in its scope. Subsection (a)(5) applies the section to "Line-clearance tree-trimming operations," with a Note sending the reader to Article 38 for the trimming rules themselves. Subsection (c)(1) then does what the federal paragraph does, in plainer words:

Cardiopulmonary resuscitation and first aid training. When employees are performing work on or associated with exposed lines or equipment energized at 50 volts or more, persons trained in first aid including cardiopulmonary resuscitation (CPR) shall be available as follows: (A) For field work involving two or more employees at a work location, at least two trained persons shall be available.

Three California sections therefore reach the same crew, and they stack rather than compete.

Section	Where it lives	What it adds
3400	General Industry Safety Orders, Article 10	Trained first aiders where no clinic is in near proximity, plus supplies and a way to call for help
3421(m)	General Industry Safety Orders, Article 12	Two carded people for any field work with two or more employees, and 90 days for a new hire
2940.10	High-Voltage Electrical Safety Orders, Article 36	The 50 volt trigger, the 4 minute rule for fixed locations, the weatherproof kit

Article 38 governs the trimming itself and leaves first aid to section 2940.10, its companion filed one article earlier. A reader who looks for the requirement where the trimming rules are will look past it.

The one person exception, and the four different gates on it

Every version of this rule carries relief that drops the count from two to one. Each version draws the gate somewhere else.

Rule	Who the relief reaches	The condition
29 CFR 1910.269(b)(1)(i)	Line-clearance tree trimmers who are not qualified employees	All new employees trained in first aid within 3 months of hire
8 CCR 2940.10(c)(1)(A), Exception	Line-clearance trainees under the direct supervision and instruction of a qualified line clearance tree trimmer	All new employees trained in first aid, including CPR, within 3 months of hire
8 CCR 2320.10(c)(1), Exception	Any crew, with no gate on who is doing the work	All new employees trained in first aid, including CPR, within 3 months of hire
ANSI Z133-2017, section 3.2.5	Any field crew of two or more workers	All new employees trained in first aid within three months of hire

California's high-voltage version is the narrow one. Its Exception reads:

For line clearance operations performed by line-clearance trainees under the direct supervision and instruction of a qualified line clearance tree trimmer, only one trained person need be available if all new employees are trained in first aid, including CPR, within 3 months of their hiring dates.

The federal relief turns on a tier. The California relief turns on a pairing, and specifically on the pairing that puts a trainee under direct supervision and instruction. It runs to that pairing and stops there, which leaves a crew of two qualified line clearance tree trimmers outside it. The current wording came in through a rulemaking filed February 27, 2018, operative April 1, 2018. Section 2951 in Article 38 was amended by the same filing on the same day, which is where the second person language was reworked.

Section 2320.10 in the Low-Voltage Electrical Safety Orders was left alone in 2018, and its last amendment was filed September 5, 2012, so its Exception is still the open one. Section 2700 defines High Voltage as a sustained voltage of more than 600 volts, which puts a secondary service drop under the low-voltage orders and the primary above it under the high-voltage orders. The same crew can cross that line in an afternoon.

The one trained person sentence is not a lighter rule for tree crews. It is a trade, and the price is a hiring-date obligation for every new employee in the company. That obligation lives in payroll, which is the last folder anybody opens during an inspection.

Section 3421(m) takes the relief back

Section 3421(m) requires two trained persons for field work involving two or more employees. It contains no exception, no proviso and no cross reference to section 2940.10. Article 12 applies to the crew on its own terms. A trainee and a supervising qualified trimmer are two employees at a work location, so the second sentence of 3421(m) is live, and it asks for two carded people whatever section 2940.10 would have allowed.

This is a genuine conflict between two sets of safety orders, and Cal/OSHA has published no interpretation reconciling them. The safe reading is the stricter one. Staff two carded people on every crew, and treat the Exception to section 2940.10(c)(1)(A) as relief that Article 12 quietly took back. Where an employer wants to rely on the Exception, the first answer comes from the Division's compliance officer, and the Occupational Safety and Health Appeals Board hears the contest.

"Available" carries one number, and it is for substations

Both the federal paragraph and section 2940.10 put a number on availability, and both put it in the wrong place for a tree crew:

For fixed work locations such as substations, the number of trained persons available shall be sufficient to ensure that each employee exposed to electric shock can be reached within 4 minutes by a trained person.

Four minutes, for a substation. The field work sentence says only that two trained persons "shall be available," and neither rule defines the word for a crew that moves five times a day. A carded groundman two spans down the street is available. The same groundman running a chipper truck back to the yard for a swap is an open question.

The 1999 memorandum draws one boundary worth knowing. It states that the CPR and first aid provisions of 1910.269(b)(1) "are dependent upon the type of electrical work performed by employee(s) and not the working alone issue." First aid staffing and two-person work rules are separate duties with separate triggers. Each is satisfied on its own terms, and the second person section 2951(d) puts within earshot is there for a different reason.

Three rules that drop the near proximity gate

29 CFR 1910.151(b) requires trained first aiders only under a condition:

In the absence of an infirmary, clinic, or hospital in near proximity to the workplace which is used for the treatment of all injured employees, a person or persons shall be adequately trained to render first aid.

Section 3400(b) of Title 8 carries the same condition in nearly the same words. Both are written for a fixed workplace, where an employer can point at an emergency room across the parking lot and be done.

That condition stops there. 29 CFR 1910.269(b)(1), section 3421(m) and section 2940.10(c)(1) each drop it, so a crew trimming a primary 600 feet from a hospital entrance still owes two carded people. Proximity to care answers section 1910.151 and section 3400, and the three rules that govern this crew ask a different question.

What counts as a card

The fourth sentence of section 3421(m) sets the standard California accepts: training "shall be performed by a certified instructor and shall be equal to that of the American Red Cross or the Mine Safety and Health Administration." Two benchmarks are named. The American Heart Association sits outside that pair, and an AHA card clears the bar on the words "equal to" rather than by appearing in the text.

The disqualifier is online delivery. OSHA's letter of interpretation of August 2, 2012, signed by Thomas Galassi, answers the question directly for 1910.269:

Online training alone would not meet the requirements of these training standards.

Galassi's reason is that the standards require physical skills, and that practicing them is the only way to learn them. The same letter carries a second sentence that is easy to miss: "the standards cited above do not require verification of competent performance, except as follows."

The three exceptions it then names are the confined space standard, the logging standard's mandatory Appendix B, and the diving standard. 1910.269 sits outside that list. A hands-on course is required and a documented skills test is the employer's own addition, which is why proof of competence has to be written into the program.

Where a third party sets its own condition it can be stricter than the code. TCIA makes an in-person first aid and CPR card a prerequisite of the EHAP certificate, on the strength of this same letter.

Three clocks on one worker

No California section and no federal paragraph sets an expiration date for a first aid or CPR card. The dates on a worker's file come from three different places.

Clock	Length	Who sets it
New hire to first training	90 days in California, 3 months federally if relief is claimed	8 CCR 3421(m), 29 CFR 1910.269(b)(1)(i)
Card issue to card expiration	Two years	The American Heart Association and the American Red Cross
Retraining between cards	At least annually, advisory	OSHA 3317-06N, Best Practices Guide

The Red Cross states that a student completing Adult First Aid/CPR/AED receives a certificate "valid for two years," and the American Heart Association runs its course completion cards for the same two years. Writing in Tree Care Industry Magazine on June 9, 2026, John Ball states the arborist version of the same count under Z133 section 3.2, and adds that the certificates "must be renewed every two years."

The middle number is the one OSHA disputes, gently. Its Best Practices Guide: Fundamentals of a Workplace First-Aid Program, OSHA 3317-06N, published in 2006, sets out three findings on skills decay.

Numerous studies have shown a retention rate of 6 to 12 months for CPR and AED skills.
The American Heart Association's Emergency Cardiovascular Care Committee encourages skills review and practice sessions at least every 6 months.
"Instructor-led retraining for life-threatening emergencies should occur at least annually."

The guide states on its own cover page that it is not a standard or regulation and creates no new legal obligations. So a two-year card is compliant, and a two-year gap in practice is a decision the employer owns.

One worker, hired March 2, 2026, carrying a Red Cross card issued June 18, 2026, has a 90-day deadline met with a month to spare, an expiration of June 30, 2028, and a two-year gap that the employer either fills or leaves empty.

The kit, the container, and the annual inspection

The count is half of paragraph (b). The rest is supplies, and it carries two conditions that are specific to working outdoors.

29 CFR 1910.269(b)(2) requires first-aid supplies to be "placed in weatherproof containers if the supplies could be exposed to the weather."
29 CFR 1910.269(b)(3) requires the employer to maintain each kit, keep it readily available, inspect it often enough that expended items are replaced, and "inspect each first aid kit at least once per year."
8 CCR 2940.10(c)(2) and (c)(3) impose the same two duties in California, with the same annual floor.
8 CCR 3400(c) requires adequate first-aid materials approved by the consulting physician, kept sanitary and usable, with frequent inspection and replenishment.

Section 1512(c)(1) of the Construction Safety Orders names this trade out loud. It requires a weatherproof first-aid kit from "every employer working on or furnishing personnel on a construction project, on line crews and on other short duration or transient jobs." Line crews, in the regulation's own words, and a bucket truck is a transient job by any reading.

What goes in the kit, and the case for a Class B kit rather than the office-grade Class A, belongs with the rescue gear and is set out there. What belongs here is the date. A kit inspected once, when the truck was outfitted, goes stale at twelve months, and that inspection is the only annual record either rule asks for by name.

OSHA's own eTool hands the exception to the wrong tier

OSHA's eTool page on medical services and first aid contains this sentence:

Under certain circumstances, new employees who are otherwise 269-qualified may work but they must be trained in CPR and first aid within three months of hire.

The rule attaches the three month condition to the opposite group. 1910.269(b)(1)(i) grants the one person relief for "line-clearance tree trimming performed by line-clearance tree trimmers who are not qualified employees," and the three month condition is the price of that relief. A 269-qualified employee falls outside it, because the relief was written for the tier below.

The eTool is guidance and the regulation is the rule, so a reader who relies on the sentence is safe at an inspection. The cost lands in an audit, where a subcontractor quoting the eTool back at a prime is quoting a sentence that departs from the standard it summarizes. The same page carries one piece of guidance worth keeping: "Although not required by the '269' standard, OSHA suggests that CPR training include instruction on use of Automatic External Defibrillators (AEDs)."

What the file has to show

Nothing in section 3421(m) or in 29 CFR 1910.269(b) says to keep a record of first aid training. The record obligation arrives from one section over. Section 3421(d) requires training to be documented by the employer to certify satisfactory completion, and what a training file has to name and how long it is kept is set by section 3203(b)(2).

For this requirement, four fields answer every question a prime or a compliance officer asks.

Field	Why it is asked for
The worker's hire date	Starts the 90 day clock in section 3421(m)
The course date and the issuer	Shows the 90 days were met, and that the issuer is equal to Red Cross or MSHA
The expiration date	Shows the card was current on the day of the work being reviewed
Delivery, in person or blended with an in-person skills session	Answers the August 2, 2012 letter of interpretation

The check an evaluator actually runs is a crew roster against a card list, on a named date. Two people on the truck on August 19, 2026, and two unexpired cards dated against them. That takes a minute, and it settles what a binder full of program documentation leaves open.

Where it bites

A crew of two with one current card is the common failure, and it lands on staffing rather than on paperwork. That crew cannot lawfully perform field work under section 3421(m) until a second carded person is on site. Sending it out anyway puts the employer in the position of having staffed a work location one person short of a rule written for cardiac arrest at 12 kV.

The second failure is the 90 day clock. It runs from a hire date, and hire dates live in payroll, so a seasonal hire taken on in April can reach July having done everything asked of them and still put the employer out of compliance. The fix is a calendar entry made on the day the hire is entered into payroll.

The third is the assumption that the federal one-person sentence travels. It is real, it is federal, and California narrowed it in 2018 and then required two anyway in Article 12. An employer running one carded person on a California crew is relying on a reading that section 3421(m) does not support.

Where this is unsettled, and who decides

Does section 2940.10's Exception survive section 3421(m)? Two safety orders reach the same crew and give two different counts. Cal/OSHA has published no interpretation reconciling them, and the Division's compliance officer answers first. The Appeals Board hears a contested citation. Until one of them speaks, the stricter count is the defensible one, and it costs one course fee.

What does "available" mean for a crew that moves? The only number in either rule is the 4 minutes for fixed work locations, and neither rule extends it to field work. An employer that sets its own standard in the Injury and Illness Prevention Program, such as a carded person within sight or hearing of every work position, is choosing the number the Division will later judge. An employer that stays silent leaves that choice to the compliance officer.

How current is current? The rules set no expiration, the issuers set two years, and OSHA's own guide advises annual instructor-led retraining. A prime's contract frequently sets something shorter than any of them. Worth knowing which document you are being audited against before somebody counts the cards.

Frequently asked questions

How many people on a California tree crew need a first aid and CPR card?

Two. Section 3421(m) of Title 8 requires that for field work involving two or more employees at a work location, at least two trained persons in first aid and CPR shall be available. The subsection carries no exception. A crew of two therefore needs both workers carded, and a crew whose second card expired last month is short.

Does OSHA require CPR training for line-clearance tree trimmers?

Yes, through a definition. 29 CFR 1910.269(b)(1) requires trained persons to be available and uses the term first-aid training. Paragraph (x) defines first-aid training as training in the initial care, including cardiopulmonary resuscitation. OSHA's own February 22, 1999 interpretation calls paragraph (b)(1) the CPR and first aid provisions.

When can a line clearance crew get by with only one trained person?

Federally, 29 CFR 1910.269(b)(1)(i) allows one for line-clearance tree trimming performed by line-clearance tree trimmers who are not qualified employees, if all new employees are trained in first aid within 3 months of their hiring dates. California wrote the relief differently. The Exception to section 2940.10(c)(1)(A) reaches only line clearance operations performed by line-clearance trainees under the direct supervision and instruction of a qualified line clearance tree trimmer. Section 3421(m) still requires two, and it has no exception.

How long is a first aid and CPR card good for?

No California section and no federal paragraph sets an expiration. The issuers do. American Heart Association course completion cards run two years, and an American Red Cross Adult First Aid/CPR/AED certificate is valid for two years. OSHA's 2006 best practices guide advises that instructor-led retraining for life-threatening emergencies should occur at least annually, and that guide is advisory.

Does an online first aid and CPR course satisfy OSHA?

No. OSHA's letter of interpretation of August 2, 2012, signed by Thomas Galassi, states that online training alone would not meet the requirements of the training standards at 29 CFR 1910.151, 1910.146, 1910.266, 1910.269, 1910.410 and 1926.950. The same letter notes that those standards do not require verification of competent performance, with three named exceptions that do not include 1910.269.

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