Proposed changes to first aid kit requirements for federally regulated employers

On October 3, 2026, the Government of Canada published proposed amendments to several occupational health and safety regulations under the Canada Labour Code (the “Code”).  

If adopted, the amendments would alter workplace first aid kit requirements for federally regulated employers.

What is changing?

Currently, five occupational health and safety regulations under the Code prescribe the contents of workplace first aid kits through detailed schedules and lists. The proposed amendments would repeal those existing provisions and instead incorporate requirements based on the CSA Standard Z1220, First Aid Kits for the Workplace (the “CSA Standard”).

Under the CSA Standard clauses 5 and 6, the appropriate type and size of first aid kit are based on workplace-specific factors. These factors would include assessing workplace risks and the number of employees present. The CSA Standard also establishes a classification system for workplace first aid kits and sets minimum requirements for their contents and maintenance.

Why are the first aid kit requirements being updated?

The Regulatory Impact Analysis Statement proposes this amendment will harmonize federal first aid kit requirements with other Canadian provinces and territories as well as fulfill the federal government's commitments under the National Occupational Health and Safety Reconciliation Agreement.

The government also expects the changes to simplify procedures and reduce regulatory burdens by allowing employers to use more commonly available workplace first aid kits.

How would changes affect administrative monetary penalties?

The proposed amendments would not create a new administrative monetary penalty regime. Rather, they would align the existing Administrative Monetary Penalties Regulations (“AMP”) framework with the revised first aid requirements by updating the list of designated occupational health and safety violations that may attract a monetary penalty. Employers in federally regulated workplaces are already subject to the AMP regime, which has been in force since January 1, 2021.

The amount of a baseline penalty is determined by the nature of the violation and whether the alleged violator is an employer or an employee. For violations under Part II of the Code, designated violations are assigned a classification ranging from Type A to Type E. More serious violations are assigned higher classifications based on the level of risk or harm involved.

As a result, employers should view the proposal as more than an administrative update. Compliance with the new first aid kit requirements, if adopted, could form part of ongoing occupational health and safety inspections and enforcement activities.

What should federally regulated employers do now?

Although the amendments have not yet been finalized, federally regulated employers may wish to assess how the proposed requirements could affect their existing first aid arrangements.

In particular, employers should consider:

• reviewing existing workplace first aid kits and supplies;
• identifying which operations may require a workplace-specific first aid risk assessment;
• evaluating whether current kit classifications and contents would comply with CSA Standard Z1220; and
• monitoring the progress of the proposed amendments and any final implementation timelines.

Our Labour & Employment Group will continue to monitor the progress of these proposed amendments and provide updates as they move through the regulatory process. If you have any questions about the proposed amendments, please contact a member of our team.