For general information only; not legal advice.

1) Why this topic matters in Philippine workplaces

In the Philippines, workplace first aid is not treated as a “nice-to-have” benefit. It is part of an employer’s legal duty to keep workers safe and healthy. Separately, many employers want to make common over-the-counter (OTC) medicines (e.g., paracetamol, antacids) available at work—but doing so touches not only occupational safety rules, but also health-practice boundaries, product safety, and liability management.

This article explains (a) what Philippine employers are generally required to do for first aid and emergency care, and (b) how OTC access can be provided lawfully and safely without crossing into improper “dispensing” or unsafe self-medication.

2) The Philippine legal framework (high level)

Employer duties on workplace first aid and medical services are shaped by three overlapping pillars:

Occupational Safety and Health (OSH) law and regulations The Philippines imposes a general duty on employers to provide a safe and healthful workplace, implement OSH programs, and provide appropriate medical/first aid arrangements based on risk and workforce size (commonly associated with the OSH Law and its implementing rules, plus long-standing OSH Standards and DOLE issuances).
The OSH Standards / DOLE rules on occupational health services These typically address the need for first aid facilities, trained first aiders, occupational health personnel (nurse/physician/dentist depending on size and risk), emergency response, and recordkeeping.
Health product regulation and scope-of-practice boundaries Even when a medicine is OTC, employers must avoid creating a situation where unqualified staff are effectively “prescribing,” “dispensing,” or giving medical advice beyond first aid. Storage, labeling, expiry management, adverse event response, and documentation are core compliance and risk controls.

3) Core employer duties on workplace first aid

A. Provide first aid as part of hazard control and emergency preparedness

In Philippine OSH compliance, first aid is expected to be integrated into the employer’s overall safety system—not isolated in a cabinet.

Minimum expectations commonly include:

A workplace risk assessment that identifies injury/illness scenarios (cuts, burns, chemical exposure, heat stress, fainting, allergic reactions, etc.).
A written OSH Program and Emergency Preparedness / Response Plan appropriate to the hazards.
Defined roles (e.g., trained first aiders, safety officer, emergency response team, clinic staff if any).
Access to prompt medical assistance: either onsite (clinic/medical staff) or via reliable external arrangements (nearby hospital/ambulance), with clear escalation procedures.

B. Ensure adequate first aid facilities and supplies

Philippine practice typically expects employers to provide:

First aid kits that are:
- Adequate in number relative to workforce size and workplace layout;
- Stocked based on the hazards (office vs. industrial vs. construction vs. laboratory);
- Maintained (complete, clean, unexpired, tamper-evident where possible).
Accessible placement:
- Kits should be easy to reach quickly, not locked away without a process.
- Worksites with multiple floors/areas commonly require multiple kits.
Basic first aid equipment appropriate to risk:
- Bandages, sterile gauze, antiseptic, tape, gloves, scissors, burn dressings, cold packs, etc.
- For certain hazards: eye wash, splints, tourniquet (only if properly trained), CPR barrier devices, and specialized items required by the risk profile.
Sanitation and infection control:
- Gloves and proper disposal for biohazard waste.
- Procedures to prevent bloodborne exposure risks.

Key compliance idea: a first aid kit is not enough by itself—employers must also ensure trained responders and clear procedures.

C. Provide trained first aiders (and, when required, occupational health personnel)

A recurring OSH requirement is that workplaces have trained first aiders in sufficient number, with valid training (commonly from recognized providers), and refresher training at appropriate intervals.

Depending on workforce size and the nature of the work (especially hazardous workplaces), Philippine OSH rules often expect progressively higher levels of occupational health coverage, such as:

A designated trained first aider (for smaller/low-risk sites),
Onsite nursing services (for larger workforces and/or higher risk),
Access to or engagement of an occupational physician (and in some cases dentist), and
A clinic or medical room meeting minimum standards, when size/risk triggers apply.

Because the exact staffing thresholds can vary by rule set and category of workplace, a safe compliance approach is: treat workforce size and hazard level as the two drivers and document how the chosen staffing meets OSH expectations.

D. Ensure emergency response, transport, and referral arrangements

Employers are typically expected to have:

Emergency communication: posted emergency numbers and clear escalation chain.
Transport plan: how to bring an injured/ill worker to a clinic/hospital quickly (vehicle/ambulance arrangements).
External coordination: nearest hospitals/clinics identified; for remote sites, stronger transport and contingency planning.
Drills and training: fire drills are common, but medical emergency drills (CPR/AED where feasible, chemical exposure response, heat illness response) may also be appropriate depending on hazards.

E. Recordkeeping, incident reporting, and continuous improvement

A strong Philippine OSH program typically includes:

A first aid log (who, what happened, what was done, who assisted, disposition—returned to work or referred).
Incident/accident reports consistent with OSH reporting requirements.
Investigation and corrective action to prevent recurrence.
Inventory logs for kits/clinic supplies, including expiry and replenishment cycles.

F. Pay for OSH measures and avoid shifting legal duties to workers

As a general principle, OSH compliance measures are funded by the employer. Policies that require workers to shoulder mandatory OSH costs (e.g., required PPE, required first aid provisions) can create legal and labor-relations risk.

4) Special workplace scenarios

A. Construction, manufacturing, and other high-risk operations

High-risk sectors typically demand more robust first aid readiness:

More trained first aiders per shift,
Better-equipped kits and dedicated medical area,
Stronger emergency transport arrangements,
Tighter contractor controls (see below).

B. Multi-employer worksites and contractors

Where multiple employers share a site (e.g., building management + tenants; general contractor + subcontractors), best practice is to clarify in writing:

Who maintains common first aid stations,
Who provides first aiders per shift,
How incidents are reported and escalated,
How costs are allocated, while ensuring each employer still meets its non-delegable OSH duties to its own workers.

C. Night shift, remote work, field work

First aid coverage must match operating reality:

If the workplace runs 24/7, first aiders must be available per shift, not just daytime.
Remote sites need stronger transport/referral planning and sometimes enhanced onsite capability.

5) OTC medicines at work: what employers may do—and what they should avoid

A. The key distinction: “making available” vs. “dispensing” vs. “practicing medicine”

Even OTC products can create problems if:

Non-medical staff “recommend” medicines as if diagnosing,
Medicines are handed out without basic screening (allergies, contraindications),
Records are not kept, or
Storage/expiry controls are weak.

A practical way to stay on the safe side is:

If you have clinic staff (nurse/physician): OTC access should flow through the clinic protocol (assessment, limited advice, documentation, referral when needed).
If you do not have clinic staff: treat OTC availability like a controlled welfare item, with strict limits, clear disclaimers, and minimal-to-no “medical advice” from unqualified personnel.

B. Why OTC access is not automatically required (and why it can still be smart)

Philippine OSH rules focus on first aid and emergency care, not on providing routine medication for comfort. So, employers are generally not legally required to provide OTC medicines for headaches, colds, or dyspepsia. However, some employers choose to provide limited OTC access as part of health and productivity initiatives—if managed properly.

C. Safe and compliant ways to provide OTC access

Option 1: Clinic-managed OTC (recommended where a clinic exists)

OTC inventory stored in the clinic/medical room.
Release only by the nurse/authorized clinic personnel under a protocol.
Basic screening questions:
- allergies, pregnancy, current medications, known conditions (hypertension, asthma, ulcer disease, kidney/liver disease).
Documentation in a clinic log (name, date/time, complaint, product, dose, advice given, disposition).
Clear escalation: warning signs trigger physician consult or ER referral.

Option 2: Controlled “comfort items” with strict limits (no clinic)

If no nurse/physician is present:

Limit to a very short list of low-risk OTC items (example categories):
- single-ingredient paracetamol (not combination cold meds),
- oral rehydration salts (where heat risk exists),
- simple antacid,
- topical antiseptic (often already part of first aid),
- glucose tablets for suspected hypoglycemia (with escalation protocol).
Keep products in sealed original packaging with manufacturer labeling intact.
Distribution handled by a designated officer (e.g., safety officer or admin) only as a “request-based release,” not proactive recommendations.
Require the worker to:
- read a short information sheet,
- confirm no known allergy to the product,
- agree to seek medical care if symptoms persist/worsen.
Maintain a basic release log (product, quantity, date/time, recipient).

What this option must not become: a mini-pharmacy where unqualified staff provide medical judgments.

D. Things employers should avoid (high risk)

Stocking or releasing prescription-only medicines without proper medical authorization.
Giving antibiotics (even if commonly requested) without prescription.
Stocking medicines that are higher-risk without medical supervision (e.g., strong NSAIDs, sedating antihistamines, combination cold products, muscle relaxants).
Allowing “self-serve” open access where employees take what they want without controls (increases misuse, adverse reactions, and inventory/expiry failures).
Providing medical advice that implies diagnosis (“You have gastritis; take this for 7 days”).

E. Storage, labeling, and inventory controls (even for OTC)

A defensible OTC program includes:

Temperature and humidity control (follow label storage requirements).
First-expire-first-out (FEFO) inventory rotation.
Regular inspection schedule (monthly/quarterly depending on volume).
Removal and proper disposal of expired/damaged products.
Restricted access to prevent pilferage and misuse.
Clear labeling that the product is OTC and not a substitute for medical consultation.

F. Managing adverse events and liability

Employers should plan for:

Allergic reactions, drowsiness, drug interactions, masking serious conditions.
Referral triggers: chest pain, severe headache with neuro signs, shortness of breath, persistent fever, dehydration, severe abdominal pain, suspected dengue warning signs, etc.

Good practice controls:

Written protocols and staff training (even for non-clinic distributors).
Documentation: what was given and why.
No coercion: workers must be free to decline and seek their own care.
Confidential handling of health information in logs (only necessary information, limited access).

6) Practical compliance checklist (Philippine workplace-ready)

First aid and emergency care

Risk assessment identifies likely injuries/illnesses and high-risk processes.
OSH Program includes first aid and emergency response components.
Adequate number of first aid kits placed for quick access.
Kits are hazard-appropriate; inspected; unexpired; restocked.
Trained first aiders are available per shift and per work area.
Clear emergency procedures and hospital referral plan.
Incident logs and reports maintained; corrective actions documented.
Contractor/shared site arrangements clarified.

If providing OTC access

Decide model: clinic-managed vs. controlled release (no clinic).
Limit products to a vetted low-risk list.
Keep original packaging; follow storage requirements.
Maintain FEFO inventory and expiry audits.
Use a simple screening and informed-acknowledgment process.
Keep a release log; treat health data confidentially.
Set red-flag symptoms and mandatory referral triggers.
Prohibit prescription-only drugs and high-risk OTC without supervision.

7) A sample workplace policy outline (adaptable)

Purpose: provide prompt first aid and safe access to limited OTC items (if adopted).
Scope: all employees, contractors (as defined), visitors (as defined).
Roles: first aiders, safety officer, clinic staff (if any), HR/admin custodians.
First aid procedures: response steps, PPE, incident documentation, referral criteria.
First aid supplies: kit locations, contents baseline, inspection schedule.
OTC access (optional): approved list, storage, release process, prohibitions.
Documentation and confidentiality: logs, access controls, retention.
Training: first aider certification, refresher schedule, drills.
Review: periodic review after incidents and at least annually.

8) Bottom line

In the Philippine context, employers must treat workplace first aid as a legal OSH function—risk-based, adequately supplied, staffed by trained responders, integrated into emergency response, and documented. Providing OTC medicines is usually optional, but if an employer chooses to do it, it should be structured to avoid unsafe self-medication and avoid crossing into unlicensed “dispensing” or medical practice—ideally through clinic protocols or, at minimum, controlled release with tight limits, clear warnings, and solid inventory controls.