Working as a subcontractor does not automatically mean you need a completely separate first aid kit. The important question is whether you and your workers can reliably access suitable first aid wherever the work is actually being carried out.
Not necessarily. A subcontractor does not automatically need an individual first aid kit simply because they are a subcontractor. Shared site arrangements can be appropriate, provided suitable first aid equipment, facilities and trained first aiders are genuinely accessible to the workers who may need them.
If you work on construction sites, it is easy to assume that first aid is entirely the head contractor's responsibility.
Larger sites often already have first aid kits, designated first aiders, signage and emergency procedures in place. But the answer is more nuanced than saying either every subcontractor must carry their own kit or that the principal contractor takes responsibility for everything.
What matters is whether the people carrying out your work have reliable access to appropriate first aid whenever and wherever they are working.
On a well managed construction site, those arrangements may be shared between several businesses. In other situations, particularly when you work alone, move between sites, travel in a work vehicle or work away from the main site facilities, carrying your own first aid kit may be the most practical option.
What Are the First Aid Requirements for Subcontractors?
Australian work health and safety requirements are generally based around the duties of a person conducting a business or undertaking, commonly referred to as a PCBU.
Depending on how your business is structured, a subcontractor, sole trader or contracting company may itself be a PCBU.
PCBUs have duties relating to the health and safety of their workers and other people who may be affected by their work. First aid forms part of those workplace arrangements.
Workplace first aid should include access to:
- at least one first aid kit
- appropriate first aid facilities
- trained people who can administer first aid
The level of first aid provided should reflect the risks of the work, the workplace, its location and the people who may require assistance.
This means there is no single rule stating that every subcontractor on every construction site must carry an individually assigned first aid kit.
Can Subcontractors Use the Principal Contractor's First Aid Kit?
Yes. Shared first aid arrangements can be appropriate.
On a construction project involving multiple contractors and subcontractors, it may make little sense for every individual business to establish a completely separate first aid station in the same location.
The principal contractor may organise site wide first aid arrangements that include clearly identified first aid kits, trained first aiders, emergency procedures and first aid facilities appropriate to the size and risk of the site.
- Clearly identified first aid kits
- Trained first aiders
- A first aid room where appropriate
- Emergency contact procedures
- Signage showing where first aid is located
Other businesses working on the site can potentially rely on these shared arrangements.
However, that does not mean a subcontractor should simply arrive on site and assume adequate first aid is available.
Businesses with overlapping WHS duties are expected to consult, cooperate and coordinate with each other. If another duty holder is providing the first aid facilities, you should still make sure those facilities are suitable and genuinely accessible to the people carrying out your work.
A Shared Site Kit Does Not Remove Your Own WHS Responsibilities
The presence of a principal contractor does not automatically transfer every workplace health and safety responsibility away from other businesses.
If you employ workers or operate your own contracting business, you still need to consider whether the arrangements available on the site adequately address the risks associated with your work.
Questions worth asking before work starts
- Where is the nearest first aid kit?
- Can my workers access it quickly?
- Who are the trained first aiders?
- Are they available during the hours we work?
- Are we working a long distance from the main site facilities?
- Are we moving between different locations during the day?
- Are there hazards specific to our work that require additional first aid supplies?
If there are gaps in the shared arrangement, additional first aid equipment or other arrangements may be required.
When Should a Subcontractor Carry Their Own First Aid Kit?
Even where a shared site kit is available, there are plenty of situations where carrying your own kit is practical.
1. You Work Alone
Sole traders and subcontractors frequently move between jobs without being surrounded by a large site workforce.
You might spend part of the day on a major commercial site and the next part working alone at a residential property, workshop or smaller job.
The first aid arrangements available on the large site may no longer exist once you leave it.
If you regularly work independently, having a portable kit means your first aid access can move with you.
2. You Work From a Ute, Van or Work Vehicle
For many trades, the vehicle is effectively a mobile workplace.
Safe Work Australia guidance recommends first aid kits in work vehicles where workers travel as part of their job.
If your day involves moving between sites, call outs and smaller jobs, relying entirely on a kit back at the depot or whatever happens to be available at each destination may not be practical.
We cover this in more detail in our guide to first aid kits in work vehicles.
3. You Work Away From the Main Site Compound
Construction sites can cover a large area.
A first aid kit may technically be somewhere on the site while still being several floors, hundreds of metres or a substantial walk away from the crew carrying out the work.
First aid equipment needs to be accessible when it is required.
For mobile crews or workers operating away from the main site office or crib room, an additional portable kit closer to the work area may be appropriate.
4. You Move Between Multiple Sites
One site may have extensive first aid facilities. The next may have a much simpler setup.
Carrying your own kit can provide a consistent backup rather than depending entirely on different arrangements at every job.
5. You Perform Higher Risk Work
Construction is generally a higher risk working environment, but the actual risks can differ substantially between trades and tasks.
Your work may involve power tools, sharp materials, grinding, cutting, hot work, electrical hazards, working at height, chemicals, dust, heavy materials or machinery.
Your first aid arrangements should reflect the credible injuries associated with your work rather than simply copying another business's setup.
Does Every Worker Need Their Own First Aid Kit?
No.
There is an important difference between requiring workers to have access to first aid and requiring every worker to carry an individual first aid kit.
For a crew working together in one area, one appropriately stocked and accessible kit may be more practical than issuing an identical kit to every person.
If workers regularly split up, use separate vehicles or work at different locations, multiple kits may be more appropriate.
The right number of kits should be determined by the workplace risk assessment and the way the business actually operates.
Our guide to how many first aid kits a business needs explains this in more detail.
What About Subcontractors Who Are Sole Traders?
If you are a sole trader, working by yourself does not make first aid irrelevant.
In some ways, the practical issue becomes even more important because there may be nobody else immediately available to retrieve equipment for you.
If all of your work takes place on organised sites with confirmed first aid arrangements, you may already have suitable access.
- Work at private homes
- Perform call outs
- Work from a ute or van
- Work remotely
- Visit smaller job sites
If your work includes situations like these, having your own portable first aid kit can provide much more consistent access.
We have a separate guide covering first aid requirements for sole traders.
What Should Be in a Subcontractor's First Aid Kit?
There is no universal subcontractor kit that is right for every trade.
The contents should reflect the work being carried out and the injuries that could reasonably occur.
Common construction first aid considerations include:
- cuts, grazes and puncture wounds
- more serious bleeding
- eye injuries
- minor burns
- sprains and strains
- fractures
- shock
The contents should come from a workplace risk assessment rather than simply choosing the largest kit available.
You can also read our broader guide to what should be in a construction site first aid kit.
Don't Forget First Aid Access When Working Out of a Vehicle
This is one of the most relevant situations for Australian subcontractors.
Electricians, plumbers, carpenters, mechanics, landscapers and other mobile trades can spend large parts of their working day moving between locations.
A kit mounted inside the main site office is not much use once you have driven to the next job.
Keeping a dedicated first aid kit in your work vehicle can provide a consistent first aid setup regardless of which site you are attending.
- Easy to locate
- Accessible without unloading half the vehicle
- Protected from unnecessary heat, moisture and contamination
- Secured so it does not become a loose object while driving
- Checked and restocked when supplies are used
For more detail, see our guide to where to keep a first aid kit in a work vehicle.
A Plumbing Subcontractor Working Across Multiple Sites
Imagine a plumbing subcontractor with two workers attending a large commercial construction site.
The principal contractor has a clearly marked first aid room, several trained first aiders and kits positioned throughout the active work areas. During the site induction, the subcontractor confirms that their workers can use those facilities.
In that situation, it may not be necessary for the plumbing crew to establish a duplicate first aid station beside the principal contractor's facilities.
But those same plumbers also spend two afternoons each week attending maintenance call outs in separate vans.
Once they leave the construction site, the shared first aid arrangements no longer follow them.
A first aid kit in each work vehicle may therefore be an appropriate part of the company's overall first aid arrangements.
A better question is:
“Can our workers reliably access suitable first aid wherever they actually work?”
That is generally more useful than simply asking whether there is technically a first aid kit somewhere on the site.
First Aid Checklist for Subcontractors
Before starting work on a new site, it is worth running through a simple first aid check.
- Is there an accessible first aid kit?
- Have I confirmed where it is located?
- Do my workers know where it is?
- Are trained first aiders available while we are working?
- Are the arrangements suitable for the hazards involved in our work?
- Will we be working away from the main first aid facilities?
- Will workers travel between sites?
- Do our work vehicles need their own kits?
- Do we need additional first aid supplies for specific hazards?
- Is our own portable kit stocked and ready if we carry one?
So, Do Subcontractors Need Their Own First Aid Kit?
Not necessarily.
A subcontractor does not automatically need a completely separate first aid kit simply because another business has engaged them to work on a site.
Shared first aid arrangements can be reasonable where they provide workers with suitable and reliable access to first aid.
Subcontractors and other PCBUs still need to consider their own workers, hazards and working arrangements rather than assuming the principal contractor has taken care of everything.
For mobile trades, sole traders, workers using vehicles, crews moving around large sites or anyone regularly working away from established facilities, carrying an additional portable first aid kit may be a practical part of the overall first aid setup.
Portable First Aid Options for Tradies and Subcontractors
Trade Aid Kits are designed around the way tradies actually work, with portable options for vehicles, job sites, workshops and mobile crews.
For a smaller portable option, see the Trade Aid Compact Kit.
For a larger workplace setup with a broader range of first aid supplies, see the Trade Aid Classic Kit.
Businesses managing multiple workers or vehicles can also view our bulk first aid kit options.
Frequently Asked Questions
Does every subcontractor legally need their own first aid kit?
No. The requirement is not simply that every subcontractor must own an individual kit. The key issue is whether appropriate first aid equipment, facilities and trained first aiders are accessible to workers while they are working.
Can I rely on the builder's first aid kit?
Potentially, yes. Businesses working at the same workplace can coordinate shared first aid arrangements. You should still confirm that the arrangement covers your workers and is suitable for the work being carried out.
Does a subcontractor's ute need a first aid kit?
If workers travel for work, keeping a first aid kit in the work vehicle can be an appropriate way to maintain access to first aid while away from a fixed workplace.
How many first aid kits should a subcontracting business have?
There is no single number that suits every business. Consider your workers, vehicles, work locations, hazards, travel patterns and how quickly each worker can access a kit.
Is construction considered a high risk workplace?
Construction is used as an example of a high risk workplace in Safe Work Australia first aid guidance. The model Code recommends one first aider for every 25 workers in a high risk workplace, but this is guidance rather than a universal standalone statutory ratio in every Australian jurisdiction.
Who is responsible for first aid when several contractors share a site?
There may be multiple businesses with overlapping WHS duties. They should consult, cooperate and coordinate their first aid arrangements. A principal contractor may provide shared facilities, but other PCBUs still need to ensure the arrangements are suitable for their own workers.
This article provides general information about workplace first aid in Australia and is not legal advice. WHS laws and approved Codes of Practice can vary between jurisdictions. Check the requirements of your state or territory regulator and undertake a workplace specific risk assessment.