First Aid Compliance Audit: A Practical Guide for Australian Workplaces
A first aid compliance audit is a structured review of whether your workplace can actually deliver first aid when someone is hurt. It checks the kit, the facilities, the people, the procedures and the paperwork against your duties under the Work Health and Safety (WHS) laws and the first aid Code of Practice. If you run a site in Western Australia, a mine camp in the Pilbara or a busy construction yard, this guide gives you a checklist you can use this month.
TL;DR
A PCBU must provide first aid equipment, facilities and trained first aiders, as far as is reasonably practicable, including at night and on remote sites.
There is no fixed number of first aiders. Your risk assessment sets it, based on hazards, site layout, headcount and distance to medical help.
A good audit tests readiness, not just stock: can people find the kit, is a trained first aider always reachable, and has anyone practised a response?
Review again whenever work practices change or an incident happens, not only once a year.
Keep evidence: dated checklists, training records, drill notes and the actions you closed.
Table of Contents
What a first aid compliance audit covers
The word “audit” makes some managers think of an external inspector. In practice, most first aid audits are internal reviews that you run yourself, or with a trainer, so that nothing surprises you later. The aim is to confirm that your arrangements match the risks of your work.
A complete audit looks at six areas:
Risk assessment: does it reflect today’s hazards, headcount and location?
First aid kits: right contents, in date, accessible.
Facilities: a first aid room or area where the risk calls for one.
First aiders: enough of them, with current training, on every shift.
Procedures: emergency contacts, communication and evacuation or retrieval.
Records and review: evidence that you check and improve.
Notice what is missing from that list: a simple tick for “we own a first aid kit”. Safe Work Australia’s Code of Practice treats compliance as an ongoing process. You review your arrangements regularly, in consultation with workers, particularly when work practices change or an incident occurs.
Who is responsible, and what the law expects
Under the model WHS laws, the duty sits with the person conducting a business or undertaking (PCBU). Safe Work Australia says you must provide access to at least one first aid kit, first aid facilities and trained first aiders, and your workers must be able to reach them.
The Model Code of Practice on first aid in the workplace is an approved code of practice under section 274 of the WHS Act. It is practical guidance, and following it is the most direct way to show you have met your duty. A code can be used as evidence in court, and an inspector may refer to it when issuing an improvement or prohibition notice.
Western Australia has its own version. WorkSafe WA publishes the First aid in the workplace Code of Practice for PCBUs, covering first aid kits, procedures, facilities and training. Its first aid guidance page makes the same point as the national material: requirements vary with the nature of the work, the hazards, workplace size and location, and the number of people present.
If you operate in another state or territory, check your own regulator’s version. Victoria, for example, uses a separate compliance code under its own occupational health and safety legislation. Our own context is Port Hedland and the Pilbara, so the examples below lean towards remote and industrial work.
Step 1: Start with the first aid risk assessment
Every other check in the audit depends on this one. If the risk assessment is out of date, a perfectly stocked kit can still be the wrong kit.
The Code says there is no universal number of first aiders. The number comes from your assessment, which should consider:
the type of work and the hazards involved (machinery, chemicals, heat, heights, confined spaces)
the size and layout of the workplace
how many employees, contractors and visitors are present, including on different shifts
how far you are from medical services and how long an ambulance or retrieval would take
When you audit, ask these questions:
When was the assessment last reviewed, and by whom?
Has anything changed since: new equipment, a new contractor crew, a larger shutdown, a new work area?
Were workers consulted? Those doing the job often know where injuries really happen.
If you want a simple method, our four-step first aid risk assessment walks through it for Australian workplaces.
Step 2: Audit the kits, and what is actually in them
This is where most people start, and where many stop. A kit audit should go further than counting bandages.
Check contents against hazards. The Code notes that extra equipment may be needed in remote workplaces, for example for serious burns, breathing difficulties or allergic reactions. A kit that suits an office will not suit a mine site or a fabrication workshop. Compare what is in each kit with the injuries your risk assessment predicts.
Check dates and condition. Look for expired items, damaged packaging, used stock that was never replaced and missing items. Record the date and who checked.
Check access. Is the kit where people expect it? Is it clearly signed, unlocked and reachable from the work area without climbing, crossing a hazard or asking permission? Vehicles and remote work crews need their own kits too.
Check awareness. Ask three workers on different shifts where the nearest kit is. If they hesitate, your signage or induction needs work, whatever the shelf says.
We have a longer explainer on audit-ready first aid kit requirements if you want to build a kit checklist.
Step 3: Check first aid rooms and facilities
Not every workplace needs a dedicated first aid room, but larger or higher-risk sites often do. The Code lists what a first aid room should contain, including a first aid kit suited to the workplace, hand cleanser and paper towels, an examination couch with a waterproof surface, an examination lamp, a cupboard for storage, a sharps container, a telephone or emergency call system, and the names and contact details of first aiders and emergency organisations.
For the audit, walk the room and check:
Is it clean, stocked and easy to get to, including for a stretcher?
Does the phone or call system work, and are emergency numbers current?
Is the list of first aiders posted and correct for today’s roster?
Our guide to first aid room requirements and onsite training covers what inspectors tend to look at.
Step 4: Audit your first aiders
This is the part that most often fails in practice, especially on rotating rosters.
Safe Work Australia’s guidance says a trained first aider must be accessible, including on night shifts and remote operations. So the audit question is not “do we have first aiders?” but “is there one on every shift, in every work area, every day?”
Build a simple matrix:
Check | What to look for |
Names and shifts | At least one current first aider per shift and per work area, with cover for leave |
Certificate currency | Each first aider holds the unit your risk assessment calls for, and it is in date |
CPR currency | Refresher dates recorded and diarised |
Identification | Hi-vis markings, hard hat stickers or a posted list so people can find them |
Fit for the job | Remote or isolated sites assessed for the need for higher-level skills |
A few notes on matching training to risk:
General workplaces: HLTAID011 Provide First Aid is $240 per participant, and HLTAID009 Provide Cardiopulmonary Resuscitation is $150.
Remote or isolated sites: HLTAID013 Provide First Aid in Remote or Isolated Site is $400, and it fits crews where help is hours away.
Higher-risk sites: HLTAID014 Provide Advanced First Aid and HLTAID015 Provide Advanced Resuscitation and Oxygen Therapy are $400 each.
For how long certificates stay valid and when to refresh, see our pieces on first aid certificate validity and refresher requirements. Put every expiry date in a register and review it quarterly, so no one lapses without notice.
Step 5: Test the procedures with a mock emergency
The Code suggests running a mock first aid emergency to confirm your procedures work. It is the most overlooked step in the audit and often the most revealing.
A short drill on a night shift or at a remote work front can answer questions no checklist will:
How long did it take to reach the casualty with a kit?
Did the radio or phone reach the control room or emergency services?
Could the caller give an exact location that a responder could find?
Did anyone know who the first aider was?
Was there a clear route for an ambulance or retrieval vehicle?
Write down what happened, fix what failed, and repeat. Two minutes of honest observation during a drill is worth more than a signed checklist nobody tested.
Step 6: Keep records an inspector can follow
Documentation is how you show your work. You do not need a heavy system. You need one that is dated, signed and kept current. Keep:
the latest risk assessment and the date it was reviewed
kit inspection logs, with replacement actions
first aider register and certificates
drill reports and corrective actions
incident reviews, showing whether first aid arrangements worked
The Code also says that after an incident requiring first aid, you should evaluate how effective the response was and change things if needed. If you learn of a previously unidentified hazard, review your first aid measures. Those prompts give you natural audit triggers between the scheduled reviews.
A scoring sheet you can copy
Score each line as Compliant, Partly or Gap. Anything marked Partly or Gap needs an owner and a date.
Area | Question | Rating |
Risk assessment | Reviewed within the last 12 months and after any major change? | |
Kits | Contents match site hazards, in date and signed? | |
Kits | Every work area, vehicle and remote crew covered? | |
Facilities | First aid room or area provided where risk calls for it? | |
First aiders | One on every shift, including nights and shutdowns? | |
Training | Certificates and CPR refreshers current and recorded? | |
Procedures | Emergency contacts and location details current? | |
Drills | Mock emergency run and actions closed? | |
Records | Evidence available to show an inspector? |
The twelve-month interval is a sensible internal benchmark rather than a legal figure. The Code asks for regular review and does not set one date, so choose an interval that suits your risk and stick to it.
Our perspective: what we see on remote sites
We train crews in Port Hedland and across the Pilbara, and the same audit gaps come up again and again.
The first is treating the kit as the whole answer. A box on a wall feels like compliance, but readiness is about people. Can a night-shift worker find the kit, reach a trained first aider, and call for help with a clear location? That is what the audit should prove.
The second is a roster that quietly drifts away from the training plan. A site starts with enough first aiders, then people move, certificates lapse and a new contractor crew arrives with none. We encourage clients to tie their first aider register to the roster rather than to a training date.
The third is generic content. Training that ignores your hazards leaves people unsure what to do in your actual conditions. That is why we customise course content to the industry and risks of each client, and why we deliver onsite, including outside standard business hours, so crews on rotating shifts do not miss out.
One more point, because it stops people volunteering. Managers sometimes worry that a trained first aider could be held liable for a mistake. The Australian Resuscitation Council’s guidance on legal issues in emergency response is the right place to read about how the law treats those who help, and the standard expected of someone acting within their training. The employer’s responsibility is to make sure the training is adequate and current. That responsibility is worth more of your attention than the fear of litigation.
— Vapour
Closing the gaps: onsite training and fit testing
Once your audit shows where the gaps are, the fixes are usually practical: more first aiders on a shift, a refresher for people whose CPR has lapsed, or a higher-level course for a remote crew.
We deliver first aid training onsite at your workplace, including remote mine and construction sites across the Pilbara, with course content tailored to your risks and scheduling that fits your roster. Certificates are issued promptly after completion, so your records stay current. If your audit also touches other site safety obligations, we offer courses in working at heights, confined spaces, gas testing and more, plus respirator and hearing protective device fit testing. Browse our course list, or contact us at Prime First Aid and Training and tell us what your audit found. We would love to work with you on a plan.
If you are also checking your wider WHS duties, read about the four first aid duties for employers at remote sites.
FAQ
Is a first aid compliance audit a legal requirement in Australia?
The WHS laws do not use the phrase “first aid audit” as a standalone obligation. They require you to provide first aid equipment, facilities and trained first aiders, and the Code of Practice expects you to review your arrangements regularly. An audit is how you prove you are doing that.
How many first aiders do we need?
There is no set number. The Code says the number depends on your risk assessment, including hazards, site size and layout, how many people are present, and how far you are from medical services. Remote and high-risk sites usually need more cover than low-risk offices.
How often should we audit?
The Code asks for regular review and does not specify an interval. Many businesses check kits more often, then review the whole system at least once a year. Review it sooner after an incident, a change in work practices or the arrival of a new hazard.
What does an inspector look at first?
They will look at whether your arrangements fit your actual risks. That usually means your risk assessment, the kits and facilities, evidence that trained first aiders are available on every shift, and your records. WorkSafe WA’s first aid page explains how requirements vary by workplace.
Are first aiders protected if something goes wrong?
Good Samaritan protections exist in Australian jurisdictions, and the Australian Resuscitation Council encourages people to help within the limits of their training. The details depend on your state or territory and the circumstances, so read the ANZCOR legal guidance or seek legal advice for a specific situation.
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