Proposed Federal First Aid Kit Rules Would Adopt CSA Z1220: What Federally Regulated Employers Should Know
Short answer: Ottawa has proposed, but not yet finalized, replacing the federal first aid kit lists in the Canada Occupational Health and Safety Regulations with CSA Z1220. Federally regulated employers would do a risk assessment and choose Type 1, 2 or 3 kits. Today's Schedule-based rules still apply until a final regulation is published in Canada Gazette, Part II.
When a cut, burn or crush injury happens, the first few minutes depend on what's in the kit on the wall, in the truck or in the cab. The federal government's own regulatory notice calls first aid "a final safeguard, to be used when adequate hazard protection and PPE fail or an unforeseeable injury occurs." For federally regulated workplaces, Ottawa has proposed changing the rules for what goes in that kit. The change is not final yet, and this article explains the proposal.
What's happening (and what isn't yet)
On October 3, 2026, Employment and Social Development Canada's Labour Program, with Transport Canada, Natural Resources Canada and Indigenous Services Canada, published proposed Regulations Amending Certain Regulations Made Under the Canada Labour Code (First Aid Kits) in the Canada Gazette, Part I. The notice opened a 30-day comment period.
This is a proposal, not a final rule. As of November 11, 2026, it has not been published as a final regulation in the Canada Gazette, Part II (we checked editions through November 4, 2026), and today's rules still apply. The final text could differ from what was proposed. If it's finalized as proposed, it would come into force on the day it's registered, with a one-year transition period during which kits that meet the old rules would still be accepted.
Today's rules vs the proposal
Today: under section 16.7 of the Canada Occupational Health and Safety Regulations (COHSR), the type of first aid kit a workplace needs (type A, B, C or D) depends on the number of employees, using Schedule I to Part XVI. The required contents are listed in Schedules II and III. Kits built to these lists, such as the Wasip Federal Occupational kits listed below, remain the standard until a final rule is in force. The Labour Program notes these content lists haven't had a comprehensive review in over 25 years.
Proposed: section 16.7 would be replaced with one requirement: "At every work place, the employer must provide first aid kits that meet the requirements set out in CSA Standard Z1220, First aid kits for the workplace, as amended from time to time, in the manner specified in that standard." Schedules I to III would be repealed.
The same change would be made in four other federal regulations: the Aviation, Maritime, Oil and Gas, and On Board Trains OHS regulations. The proposal would also update the Administrative Monetary Penalties (Canada Labour Code) Regulations, listing a violation of the new section 16.7 as a type D violation, the category the AMPs regulations use for high-risk hazards.
Because the reference is "as amended from time to time," future editions of CSA Z1220 would apply automatically. The notice says CSA published the second edition of the standard in 2024.
What CSA Z1220 asks employers to do
As described in the Gazette notice, CSA Z1220 sets out three kit types:
- Type 1, Personal: for a worker who works in isolation or doesn't have access to a workplace kit.
- Type 2, Basic: for lower-risk workplaces.
- Type 3, Intermediate: for higher-risk workplaces.
Under the proposal, every employer would do a first aid risk assessment to choose the type. The notice lists what that assessment looks at: workplace hazards, the injuries or illnesses that could happen and how likely and severe they are, remoteness, the number of employees per shift, the workplace's injury history, and how quickly emergency services can get there.
For Type 2 and Type 3 kits, the size and number depend on employees per shift. The notice gives these examples:
| Employees per shift | Kits (as proposed) |
|---|---|
| 2–25 | One small kit |
| 26–50 | Two small kits or one medium kit |
| 51–100 | Four small, two medium, two small and one medium, or one large kit |
| Each additional 1–50 | Add one medium or two small kits |
Who this applies to
Only federally regulated workplaces under Part II of the Canada Labour Code. The Gazette notice lists sectors such as air, rail, road and marine transportation, pipelines, banks, telecommunications and broadcasting, postal and courier services, grain elevators and feed and seed mills, uranium mining, Crown corporations, First Nations band councils and the federal public service.
Provincially regulated workplaces aren't affected by this change. According to the notice, every province and territory has already incorporated CSA Z1220 into its own OHS regulations, and the federal government is the last to do so. If you also run provincially regulated sites, see our first aid kits and spill containment range.
What federally regulated employers can do now
- Confirm your jurisdiction for each site and fleet. Many employers run both federal and provincial operations.
- Start the first aid risk assessment. It's the step that decides kit type, and it's useful whether or not the rule is final yet. If it turns up chemical splash hazards, plan for eyewash stations and emergency showers as well.
- Count employees per shift at each location, including vehicles and remote work, to see what sizes and how many kits you'd need.
- Inventory current kits and note when each is due for restocking or replacement. That's a natural point to switch.
- Watch the Canada Gazette, Part II for the final regulation, then plan to be compliant within the one-year transition.
Keyline Safety's stand
Don't wait for the final regulation to do the risk assessment. A kit list sized only by headcount can leave a higher-risk crew short of the supplies it actually needs. Matching the kit to the hazard is the point of CSA Z1220, and it's good practice in any jurisdiction.
We'd also rather see the right kit within reach than the biggest kit on one wall. Spreading kits across the workplace, the fleet and the people who work alone, and keeping them stocked, is what makes first aid fast when it counts.
What Keyline Safety does
Keyline Safety stocks workplace first aid kits for both today's federal rules and CSA Z1220:
- CSA Z1220-24 kits from Wasip in every type and size: Type 1 Personal; Type 2 Basic in small, medium and large; and Type 3 Intermediate in small, medium and large.
- Kits built to today's federal rules, which still apply while the proposal is under review, including the Wasip Federal Occupational A, B, C and D kits.
- Custom first aid kits and the wider workplace first aid and AED supplies range for restocking and additional supplies.
Working out which Z1220 type and size fits each of your sites or vehicles? Contact Keyline Safety with your headcount per shift and the work you do.
Frequently asked questions
Is CSA Z1220 required for federal workplaces now?
No. As of November 11, 2026, it is a proposal published in Canada Gazette, Part I. Today's federal kit rules still apply until a final regulation is published.
What are the CSA Z1220 first aid kit types?
Type 1 Personal, for a worker who works alone or without access to a workplace kit; Type 2 Basic, for lower-risk workplaces; and Type 3 Intermediate, for higher-risk workplaces.
Who would the proposed federal first aid kit rules apply to?
Federally regulated workplaces under Part II of the Canada Labour Code, such as air, rail, road and marine transportation, banks, telecommunications and the federal public service.
Would there be a transition period?
As proposed, there would be a one-year transition period during which kits meeting the old rules would still be accepted.
Keep reading
- Common Workplace Hazards
- Why Is Safety Important? Protecting Employees and Preventing Accidents
- Cold-Weather Work in Canada: A PPE and Supervisor Checklist
Sources
- Canada Gazette, Part I, Vol. 160, No. 40, Regulations Amending Certain Regulations Made Under the Canada Labour Code (First Aid Kits), Oct 3, 2026 (proposed text, Regulatory Impact Analysis Statement, transitional provision)
- Justice Laws Website, Canada Occupational Health and Safety Regulations (SOR/86-304), Part XVI, s. 16.7 (current text)
- Employment and Social Development Canada, First Aid Kits regulatory initiative: summary of changes
- Canada Gazette, Part II, Volume 160 index (checked Nov 11, 2026; no final First Aid Kits regulation through the Nov 4, 2026 edition)
