Every employer in the UK carries a legal duty to protect the people who come to work for them. That duty extends to first aid provision—and the starting point for getting it right is not booking a course or buying a kit. The starting point is a first aid needs assessment. Without one, you are guessing at what your workplace actually requires. With one, you make informed decisions that protect your staff, satisfy your legal obligations, and ensure that someone in your building knows exactly what to do when an emergency unfolds.
This guide walks you through the entire process step by step—from understanding the legal framework to reviewing your provision once it is in place. If you run a business in London, whether a small office in Shoreditch, a hospitality venue in Soho, a security operation across multiple sites, or a construction project in East London, this article gives you a practical and thorough foundation for getting your first aid arrangements right.
What Is a First Aid Needs Assessment, and Why Does It Matter?
A first aid needs assessment is a structured review of your workplace that determines what first aid equipment, facilities, and trained personnel you need. The Health and Safety (First-Aid) Regulations 1981 require every employer in the UK to make adequate and appropriate first aid provision. What counts as adequate depends entirely on your specific circumstances—and the only way to determine that is to carry out a proper assessment.
The HSE does not set fixed numbers or prescribe a single approach. Instead, it places the responsibility on you as the employer to assess the risks, identify what your workplace needs, and act accordingly. Carrying out the assessment is not optional. It is a legal requirement, and failing to complete it—or completing it poorly—leaves your business exposed to enforcement action and, more importantly, leaves your staff exposed to harm.
For London businesses especially, the assessment carries added complexity. The city’s diverse industries, multi-site operations, shift patterns, lone workers, and high footfall environments all create specific considerations that a generic checklist will not address. A thorough, documented assessment tailored to your actual working environment is the only approach that satisfies both the law and the practical reality of running a business in the capital.
Step 1—Identify the Hazards and Risks in Your Workplace
The first step in any first aid needs assessment is to identify the specific hazards present in your work environment. Walk through every area of your premises during different times of the working day, including early starts, late finishes, and quieter periods when fewer staff are present. Look at the work your people actually perform, not just the work described in job titles.
For a London office, hazards might include slips and trips, screen-related health issues, electrical equipment, and stress-related conditions. For a hospitality venue, add burns and scalds, cuts from kitchen equipment, and potential intoxication incidents involving the public. For a security operation, add the risk of physical confrontations, lone working in unsafe areas, and the need to manage casualties in high-pressure public environments. For a construction site, the hazard profile expands significantly to include machinery, working at height, manual handling injuries, and potential exposure to hazardous substances.
The nature and severity of your hazards determine how advanced your first aid provision needs to be. A low-hazard office environment with under 25 employees may only require an appointed person to manage the first aid kit and call the emergency services. A higher-risk workplace with more staff needs at least one qualified first aider present at all times—and emergency first aid training becomes a baseline requirement rather than an optional extra.
Step 2—Consider Your Workforce Size and Characteristics
Once you have mapped the hazards, turn your attention to the people who work in your building. The number of employees you have directly influences how many trained first aiders you need, but workforce size is not the only factor worth examining.
Consider whether any of your staff have pre-existing medical conditions that increase their likelihood of requiring first aid—diabetes, epilepsy, severe allergies, or heart conditions all warrant specific consideration. Think about whether you employ young workers, pregnant employees, or staff whose first language is not English, as each of these groups may require additional planning around first aid communication and response.
Think about your shift patterns. If your business operates across morning, afternoon, and night shifts, you need to ensure that trained first aiders are available across all of those shifts—not just during standard office hours. A single trained first aider who works a nine-to-five Monday to Friday does not cover your 11pm Saturday shift. This is a gap that many London businesses discover only after an incident has occurred.
The HSE guidance suggests the following structure for low-risk environments: fewer than 25 employees need at least one appointed person, 25 to 50 employees need at least one person who has completed emergency first aid training at EFAW level, and more than 50 employees should consider at least one qualified first aider per 100 members of staff. For higher-risk environments, these numbers increase substantially.
Step 3—Assess the Work Location and Site Layout
Where your workplace sits and how it is arranged matters more than many London employers realize. The physical distance between your premises and the nearest emergency services affects how long an ambulance will take to reach you—and in a medical emergency, that gap in response time can be the difference between a good outcome and a tragic one.
Central London locations benefit from relatively fast emergency response times, but heavy traffic, pedestrian congestion, and access restrictions in certain areas can delay ambulances significantly. Peripheral London locations, particularly those on industrial estates or in outer boroughs, may face longer response windows. Your needs assessment should account for this reality and ensure your first aid provision fills the gap appropriately.
Site layout also influences how many first aid kits you need and where you position them. A single large floor plate may require multiple kits to ensure that every workstation sits within a reasonable walking distance of first aid supplies. A multi-floor building needs kits on each level. A workplace where staff move between different areas throughout the day—a hotel, a hospital ward, a large retail floor—needs provisions that travel with the work rather than sitting in a fixed location.
Step 4—Determine the Right Level of First Aid Training
Your assessment findings should directly inform the type of training your designated first aiders need. The HSE recognizes two primary qualification levels for workplace first aiders.
The Emergency First Aid at Work qualification—the one-day EFAW course—covers the core life-saving competencies: adult CPR, use of an automated external defibrillator, management of choking, control of severe bleeding, treatment of shock, care of an unconscious casualty, and basic management of minor injuries. Emergency first aid training at this level suits low-risk workplaces where the hazard profile is limited and the workforce is relatively small.
The three-day First Aid at Work qualification goes considerably further. It covers everything in the EFAW curriculum and adds management of a broader range of injuries and medical conditions—including head and spinal injuries, chest injuries, burns and scalds, fractures, eye injuries, and medical conditions such as stroke, cardiac events, asthma attacks, diabetic emergencies, anaphylaxis, and seizures. This level of qualification suits any workplace where the risk profile is higher, the workforce is larger, or the nature of the work exposes people to a wider range of potential injuries.
Choosing emergency first aid training alone for a higher-risk London workplace is a compliance failure waiting to happen. Your assessment findings should drive this decision—not cost considerations or convenience.
It is also worth noting that since the HSE updated its guidance in 2024, employers now have an explicit responsibility to account for employees’ mental health in their first aid needs assessment. Mental health first aid is not yet a legal requirement, but the updated guidance makes clear that employers should consider whether mental health first aid provision forms part of an adequate overall first aid arrangement for their workplace.
Step 5—Evaluate Your First Aid Equipment and Facilities
A qualified first aider without the right equipment cannot deliver effective first aid. Your assessment must include a review of the equipment and facilities your workplace provides.
Every workplace needs at least one properly stocked first aid kit. The HSE does not prescribe a mandatory contents list, but it does provide guidance on what a kit should contain as a minimum—individually wrapped sterile plasters, sterile eye pads, triangular bandages, safety pins, sterile wound dressings in multiple sizes, disposable gloves, and a general first aid guidance leaflet. You should not include medication—including aspirin or paracetamol—in any workplace first aid kit.
Higher-risk environments may need additional equipment. Workplaces where life-threatening bleeding is a realistic risk should consider tourniquets and hemostatic dressings. Sites where eye injuries are possible; we need eyewash stations. Environments with a significant number of employees or members of the public—centers, transport hubs, large event venues—should seriously consider providing automated external defibrillators. AED survival rates for cardiac arrest increase dramatically when a device is available within three to five minutes of collapse, and London’s urban density means trained responders with a nearby AED genuinely save lives.
Larger premises or those with significant health and safety risks may also need a dedicated first aid room—a space that is easily accessible, clearly signposted, has adequate lighting and ventilation, contains a couch with a waterproof cover, clean running water, a telephone, and appropriate first aid materials.
Step 6—Account for Absence and Cover Continuity
One of the most commonly overlooked aspects of a first aid needs assessment is continuity of cover. Your assessment should identify what happens when your designated first aider is absent—on annual leave, attending training, on sick leave, or working remotely.
The HSE makes clear that first aid provision must remain adequate at all times when people are at work. That means training a single first aider and hoping they are never absent is not a compliant approach. Most workplace safety advisors recommend training at least two people per location to provide genuine redundancy.
For London businesses with multiple sites, consider how cover is managed across locations. A first aider based at your Canary Wharf office cannot respond to an incident at your Brixton location. Each site requires its own provision, assessed independently.
Step 7—Document Your Assessment and Review It Regularly
Once you have completed your assessment, document every finding and decision in writing. Record the hazards you identified, the workforce characteristics you considered, the training levels you selected, the equipment you provisioned, and the names and qualification expiry dates of your trained first aiders.
This documentation serves multiple purposes. It demonstrates to HSE inspectors that you carried out a proper assessment. It provides a baseline for future reviews. And it creates an audit trail if an incident occurs and your first aid provision is later scrutinized.
Review your needs assessment at least annually and immediately following any significant change to your business—a move to new premises, an expansion of your workforce, a change in the nature of your work, or an incident that revealed a gap in your existing provision. First aid needs are not static, and your assessment should evolve as your business does.
For any London employer whose assessment identifies a requirement for emergency first aid training—whether at EFAW or FAW level—acting on that finding promptly is the difference between legal compliance and a gap that could have serious consequences for the people in your workplace.
Frequently Asked Questions
Yes. The Health and Safety (First-Aid) Regulations 1981 require every employer to assess their first aid needs. The assessment determines what equipment, facilities, and trained personnel your specific workplace requires to comply with the law.
For low-risk offices, the HSE recommends one appointed person for under 25 staff, one EFAW-trained first aider for 25 to 50 employees, and one qualified first aider per 100 staff for larger teams. Higher-risk environments need more provision.
An appointed person manages first aid arrangements and calls emergency services but holds no formal first aid qualification. A trained first aider holds either an EFAW or FAW certificate and can provide active first aid treatment in an emergency.
Both the EFAW and FAW certificates are valid for three years. The HSE strongly recommends annual refresher training between certifications to maintain practical skills, particularly CPR, which deteriorates significantly without regular practice.
The law requires first aid provision only for employees. However, the HSE strongly recommends that employers include non-employees—visitors, customers, and contractors—in their assessment and make appropriate provision for them too.
Yes. Any incident—including near misses—should trigger an immediate review of your first aid provision. The incident may reveal gaps in training, equipment, or coverage that your original assessment did not identify or adequately address.
