Multi-Site First Aid Compliance: A Practical Guide for Australian Businesses
If your business runs more than one site, first aid compliance is not one policy copied across locations. Each site needs its own assessment, its own kits and facilities, and enough current first aiders on every shift, with one system tying it all together. This guide shows how to build that system, from the legal duty to the records you keep, with a focus on remote and industrial work.
TL;DR
Under the model WHS laws, the person conducting a business or undertaking (PCBU) must provide first aid equipment, facilities and trained first aiders at every workplace, and keep them accessible whenever people work, including night shifts and overtime.
Assess each site separately: hazards, size, location, and the maximum number of people present at one time, including contractors.
The Code of Practice guides first aider numbers at 1 per 50 workers (low risk), 1 per 25 (high risk) and 1 per 10 (remote high risk).
Remote and mobile crews need reliable communication, vehicle kits and a plan for aerial evacuation.
Keep one register of first aiders, kit checks, qualification expiry dates and treatment records, and review it after incidents or changes to the work.
Table of Contents
What the law asks of a multi-site business
The duty sits with the PCBU, and it applies to each workplace you control, not to the business as a whole. The Model Code of Practice: First aid in the workplace says a PCBU must provide access to first aid equipment and facilities, and an adequate number of trained first aiders, whenever workers are working. That includes night shifts and overtime. Where businesses share a workplace, the duty holders may coordinate so that workers can reach one another’s first aiders.
In practice, this means a head office with a well-stocked kit does not cover your depot, your site office or your crew at a remote camp. Every location has to stand on its own, and you need to be able to show that.
Codes of practice and the “reasonably practicable” test
A code of practice is guidance, not a second law. SafeWork SA explains that you are not strictly bound to follow a code if you can show a recommended control is not reasonably practicable, or that you have an alternative giving the same or a better safety outcome. That flexibility is useful for odd sites, but it puts the burden on you to document your reasoning. Most businesses find it simpler to follow the code and note any justified departures.
Which state rules apply
The model WHS laws are adopted with local variations, and each regulator publishes its own version of the code. In Western Australia, WorkSafe WA’s First aid in the workplace code applies to workplaces covered by the Work Health and Safety (General) Regulations 2022 and the Work Health and Safety (Mines) Regulations 2022. If your sites cross state lines, check each regulator’s current version rather than assuming the same wording applies everywhere. Our guide on WHS first aid duties for employers at remote sites covers the remote-work side in more detail.
Assess every site separately
A single risk assessment cannot describe a warehouse, a school canteen contract and a mine-site laydown yard. The Model Code asks you to consider, for each workplace:
the type of work and its hazards
the size and layout of the site, and how far it is from medical help
the number and make-up of workers and others on site
Count contractors, subcontractors and volunteers, and plan for the maximum number of people present at one time, not the average headcount. Review the assessment regularly and whenever circumstances change: a new process, a shutdown with extra contractors, a new hazardous substance, or a changed roster.
It is also worth asking each site about workers with known medical conditions. The WorkSafe Queensland code says their specific needs should be addressed by first aiders, with the worker’s consent and with health information kept confidential. Build that into your induction rather than leaving it to chance.
If you want a repeatable method, our 4-step first aid risk assessment gives you a template you can run site by site and file centrally.
A simple worked example
Imagine a civil contractor with three locations: a city office with 30 staff, a regional depot with 40 workers across two shifts, and a remote project camp with 22 people on a two-week roster. The office is low risk. The depot involves plant and manual handling, so it is higher risk. The camp is remote, so it is the most demanding. Three sites, three different answers, even though one company, one safety manager and one set of policies sits over the top.
How many first aiders each site needs
The Model Code gives these guide ratios of first aiders to workers:
Site type | Recommended ratio |
Low-risk workplace | 1 first aider per 50 workers |
High-risk workplace | 1 first aider per 25 workers |
Remote, high-risk workplace | 1 first aider per 10 workers |
Two points catch multi-site businesses out. First, the ratio applies to the people present on each shift, not the whole workforce. A depot with 40 workers split across two shifts needs first aiders on both shifts, and a first aider on leave or off roster does not count. Second, ratios are a starting point. If your assessment shows a higher chance of serious injury, or ambulance access is slow, you add more.
Applying the guide ratios to the example above, the office would have one first aider, the depot would aim for at least one per shift and more as headcount grows, and the remote camp, with 22 people, would look at two to three first aiders at any one time. Always put an extra margin on top for leave, illness and rotation, since a roster with one first aider can fail on the first sick day.
For a deeper breakdown, see our guide to how many first aiders Australian PCBUs need.
Kits and facilities: what each site should have
The Model Code says kits should be accessible, maintained and suited to the hazards you identified. Where a workplace has separate work areas, first aid facilities may be centralised, with kits provided in each area. A few practical rules follow:
Put kits where people work, not only in the manager’s office. Mark their locations on emergency floor plans.
Stock to the hazard. A site with chemicals, sharps or burns risk needs a different kit from an admin office.
Put portable kits in vehicles where the vehicle is the workplace, for example service vans and site utes.
Name one person per site as responsible for restocking and checking, and record each check.
Check expiry dates on dressings, saline and any other time-limited items on a fixed schedule.
Our audit-ready first aid kit requirements page sets out what to stock and how to evidence your checks. For sites where cardiac arrest is a credible risk, consider whether a defibrillator is warranted, and read our note on AED training for managers.
Make first aiders easy to find
A qualified first aider nobody can locate is little use during an emergency. The WorkSafe Queensland code suggests identifying where first aiders are during their shifts and considering high-visibility vests so that other workers can recognise them. On a multi-site roster, a simple shift board or app listing who is on each site, with phone numbers, does the same job.
Remote sites, mobile workers and shift crews
This is where multi-site compliance gets difficult, and where a generic city-office approach fails first.
Remote and isolated work. The Model Code requires a safe system of work that includes effective communication. Where travel time, poor roads or weather make access difficult, your arrangements should include aerial evacuation. That means a tested way to call for help (satellite phone, radio or a repeater-covered handheld), a known pickup point and a site address or coordinates that anyone can read out.
Mobile workers. People who work alone or travel between locations need clear instructions on what to do in an emergency and a kit in the vehicle where the vehicle is their workplace.
Night shifts and overtime. Because first aid must be accessible whenever people work, your roster has to be checked against first aider coverage, not just business hours. A site that has three first aiders, all on day shift, is non-compliant at 2 am.
When help is far away. The WorkSafe Queensland code says that if timely access to professional medical help cannot be assured, you should consider training first aiders in more advanced techniques such as oxygen use. For those crews, a standard first aid certificate may not be the right level. Courses built for isolated work, HLTAID013 Provide First Aid in Remote or Isolated Site and HLTAID015 Provide Advanced Resuscitation and Oxygen Therapy, are designed for exactly that gap.
Training and keeping qualifications current
The WorkSafe Queensland code says first aiders should hold a nationally recognised Statement of Attainment from a registered training organisation (RTO) for the Provide First Aid unit of competency, or a course giving equivalent skills. It also recommends annual CPR refreshers and renewal of first aid qualifications every three years.
Across many sites, the common failure is not lack of training but lapsed training. Certificates expire quietly, and a site that was compliant in January can be short of first aiders by October. Three habits prevent it:
Keep one central register with each first aider’s name, site, unit codes and expiry dates.
Set reminders at least three months before the CPR anniversary and the three-year expiry.
Book renewals in groups by site or roster block, so you never pull the whole crew off at once.
Our pages on first aid refresher requirements and three-year validity and annual CPR explain the renewal cycle step by step.
Which course for which role
Role or situation | Course to consider | Price |
Standard workplace first aider | $240 | |
Annual CPR refresher for everyone | $150 | |
Education and care settings | $250 | |
Higher-risk sites | $400 | |
Remote or isolated crews | $400 | |
Oxygen therapy and advanced resuscitation | $400 |
Prices are the individual course prices published on our site. For group bookings and on-site delivery, contact us to talk through your sites.
Records, audits and review across sites
The Queensland code expects you to document your first aid procedures: first aider contact details, where equipment is kept, and who maintains it. Review those arrangements in consultation with workers, especially after an incident or when work practices change.
For a multi-site business, a workable set of records looks like this:
Site assessment for each workplace, with the review date.
First aider register across all sites, with qualification and CPR dates.
Kit check log per kit, including vehicles.
Emergency communication plan for each remote site, with the aerial evacuation arrangements.
Treatment records for every first aid incident.
Treatment records are the most undervalued. A resource kit published through SafeWork SA’s library notes that first aid treatment records are essential for judging whether your arrangements are adequate and for spotting patterns of injury. If three sites each log a few hand lacerations, you may never notice. Put them in one register and you may find all three share the same task or the same tool. A structured group job audit checklist is one way to turn recurring findings into assigned follow-up actions.
Run the review on a fixed cycle, for example every year, and trigger an extra one after any serious incident, a change of roster, or the opening of a new site.
Our perspective: what we see across remote and industrial sites
We deliver first aid training on site across the Pilbara, including remote mine and construction sites, and the same patterns come up with multi-site clients.
The first is that compliance usually breaks at the edges: the night shift, the satellite camp, the contractor crew that arrived last week. The head office file looks perfect, and the real gaps are in places the safety manager visits twice a year.
The second is that generic courses are rarely the best fit. We customise course content to the hazards of each client’s sites, because a first aider who has practised scenarios from their own workplace responds with more confidence than one who has only practised on a classroom dummy.
The third is scheduling. Crews work rosters, not nine-to-five, so we offer flexible times outside standard business hours and bring the training to the site. Our trainers have industry-relevant experience, and participants receive their certificates promptly after completion, which keeps your register current without an administrative backlog.
Our advice: start with the site that would be hardest to reach in an emergency. Fix that one first, then use it as the template for the rest.
— Vapour
Training that comes to your sites
If you manage several locations, the simplest way to close gaps is to bring a trainer to your crews. We run on-site, mobile and online first aid courses, customised to your industry and delivered anywhere in the Pilbara, including remote sites. We also offer fit testing for respiratory and hearing protective equipment and a range of industrial safety units. See the full course list, or get in touch from our homepage to plan training across your sites. Our custom first aid training process explains how we move from risk assessment to delivery.
Frequently asked questions
Does every site need its own first aid kit?
Yes. The Model Code expects kits to be accessible and suited to the hazards of the place where people work. Where a workplace has separate work areas, facilities can be centralised, but kits should still be provided in each area. Vehicles that serve as a workplace need a portable kit.
Can one first aider cover several sites?
Not in any way that satisfies the duty. First aid must be accessible whenever workers are working at each site, so a person who is at another location cannot be counted. At a shared workplace, duty holders may coordinate access to each other’s first aiders, but that must be an agreed arrangement.
How often do first aiders need to renew?
The WorkSafe Queensland code recommends renewing first aid qualifications every three years, with CPR refreshed annually. Check your own state regulator’s current code too, since each publishes its own version.
Are codes of practice compulsory?
Not strictly. SafeWork SA explains that you may use an alternative if it gives the same or a better safety outcome, or if a recommended control is not reasonably practicable. You should record your reasoning so you can show it to an inspector.
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