First Aid Requirements for Queensland Workplaces: What the Law Requires

Vectr Medical

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If you run a business in Queensland, first aid isn't optional and it isn't a matter of judgement — it's a legal duty under the Work Health and Safety Act 2011 (Qld) and the accompanying Regulation. What's less clear to most operators is exactly what that duty requires in practice: how many kits, how many trained people, what goes in the kit, and whether a defibrillator is mandatory.

This guide sets out the framework and the practical questions you need to answer for your own site. (In other states? See our guides for Victoria, New South Wales, and South Australia.)

The legal basis

Queensland's WHS Regulation requires a person conducting a business or undertaking (a PCBU — which means essentially any employer) to ensure:

  • Adequate first aid equipment is provided for the workplace.
  • Each worker has access to that equipment.
  • Access to facilities for administering first aid is provided.
  • An adequate number of workers are trained to administer first aid — or workers have access to an adequate number of people who have been trained.

Note the word doing the heavy lifting: adequate. The Regulation deliberately doesn't prescribe a fixed number of kits or a set ratio of first-aiders. What counts as adequate depends on your workplace — and that means you're expected to assess it, not guess.

Safe Work Australia's First aid in the workplace Code of Practice, which Queensland has adopted, sets out how to make that assessment. A code of practice is admissible in proceedings as evidence of what is known about a hazard and reasonably practicable ways of managing it. In plain terms: if something goes wrong and you've ignored the Code, you'll have a hard time explaining why.

What determines "adequate" for your site

The Code directs you to consider:

The nature of the work and hazards present. A quiet accountancy office and a metal fabrication workshop have very different injury profiles. Manufacturing, construction, agriculture, and forestry are higher-risk and attract correspondingly higher first-aid expectations — which in Queensland matters, given the size of those sectors.

The size and layout of the workplace. A single kit at reception is not adequate access for a worker at the far end of a large site, or on a different floor. Multiple kits may be needed.

The number and composition of workers. Headcount matters, but so does shift structure — including whether trained first-aiders are actually rostered on across all shifts, not just weekdays.

The location of the workplace. This is particularly significant in Queensland. A worksite in inner Brisbane with an ambulance minutes away is in a very different position from one in a remote or regional location where emergency response time may be substantial. Where help is far away, your own first-aid capability has to be correspondingly greater — the Code is explicit about this.

Workers who don't work at a fixed location. Mobile workers, drivers, and field staff need first-aid provision too — typically a kit carried in the vehicle.

First aid kits

The Code sets out a recommended minimum contents list. Beyond the standard items — dressings, bandages, gloves, scissors, saline — the key practical points are:

  • Kits must be accessible. A locked kit in a manager's office is not accessible.
  • Kits must be clearly identified and their location known to workers.
  • Contents expire. Sterile items and saline have expiry dates. A kit that hasn't been checked in three years may be legally present and practically useless.
  • Additional items may be required based on your hazards — burn dressings where there's a burn risk, eyewash where there are chemicals, and so on.

Assign someone responsibility for checking and restocking kits on a schedule, and keep a record. That record is the evidence you were managing the duty, not just discharging it once at fit-out.

First aiders

The Code offers guidance ratios as a starting point — broadly, one first-aider per 50 workers in a low-risk workplace, and one per 25 in a high-risk workplace, with different considerations for remote work.

Treat these as a floor, not a ceiling. Practical considerations that matter more than the raw ratio:

  • Coverage across shifts. Three trained first-aiders who all work Monday to Friday days leaves your night shift with none.
  • Leave and turnover. If your only first-aider is on annual leave, you have zero.
  • Currency of training. First aid certification requires periodic refresher training. CPR competency in particular should be refreshed annually.

Is a defibrillator mandatory in Queensland?

This is the question we get asked most, and the honest answer requires care.

Queensland does not currently have legislation making AEDs mandatory for general workplaces in the way that South Australia has introduced. There is no blanket Queensland statute requiring every business to install one.

But that is not the end of the analysis, for two reasons.

First, the WHS Act imposes a general duty to eliminate or minimise risks to health and safety so far as is reasonably practicable. Sudden cardiac arrest is a foreseeable risk in any workplace with people in it. Survival falls by roughly 10% for every minute without defibrillation. AEDs are now relatively inexpensive, require no training to operate, and are demonstrably effective. When a control measure is that available and that effective, the argument that it isn't reasonably practicable becomes progressively harder to sustain — particularly for larger workplaces, public-facing sites, sites with an older or higher-risk workforce, and sites remote from ambulance response.

Second, Safe Work Australia's Code of Practice explicitly directs PCBUs to consider whether an AED is needed as part of the first-aid risk assessment. Considering it and documenting the reasoning is part of doing the assessment properly.

So the accurate position is: not mandatory by specific statute, but potentially required by the general duty depending on your circumstances — and something you are expected to actively consider and be able to justify either way.

We cover the Queensland AED position in more depth in AED requirements in Queensland, and the broader national picture in workplace first aid requirements Australia.

It's also worth watching the interstate trend. South Australia has legislated AED requirements for a range of buildings and workplaces. Where one state moves, others frequently follow — we cover that in the SA AED legislation guide.

If you do have an AED, maintenance is not optional

A frequently missed point: installing an AED creates its own ongoing duty. Under AS 3718 and the WHS Regulations, equipment must be maintained in accordance with manufacturer specifications. Most public liability policies also require documented maintenance records as a condition of cover.

The green self-test light on the front of the unit confirms the device powers up and passes an internal check. It does not verify that the unit will deliver the correct shock energy, and it is not a compliance document. Pads and batteries expire on dates that are easy to lose track of.

Vectr Medical provides NATA-certified AED testing and certification — full diagnostics, battery and pad inspection, firmware update, and a signed calibration certificate for your WHS file. More on why this matters in why the green light isn't enough.

A practical checklist

  1. Do a documented first-aid risk assessment. Hazards, size, layout, worker numbers, shifts, location, remoteness. Write it down.
  2. Provide kits sized and stocked to the assessment, accessible, clearly marked, and on a check-and-restock schedule with records.
  3. Train enough people — and check the coverage actually holds across shifts, leave, and turnover.
  4. Consider an AED explicitly as part of the assessment and record the reasoning either way.
  5. If you have an AED, maintain it — annual testing, certification, and tracked pad/battery expiry.
  6. Review periodically, and whenever the work, site, or workforce changes materially.

Equipment

Vectr Medical is operated by NATA-certified biomedical engineers based on the Gold Coast. We supply, service, and certify AEDs and medical equipment for Queensland workplaces — and because we test these devices as well as sell them, we can tell you what actually holds up in service.

Questions about your specific site? Contact us at joe@novabiomedical.com.au or 1300 723 900.


This article is general information about Queensland workplace health and safety obligations. It is not legal advice, and it does not account for the circumstances of any particular business. For advice on your own compliance position, consult a qualified WHS professional or refer directly to Workplace Health and Safety Queensland. Legislation and codes of practice change — verify current requirements before relying on this summary.

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