Compliance Corner

Answer (Eric Brideau, Chief Compliance Officer)

Great questions! These are the kinds of practical considerations that come up often when setting up first aid facilities.

New Brunswick’s First Aid Regulation sets out requirements for first aid rooms, but it also allows flexibility so employers can design spaces that work for their specific workplace.

In terms of proximity to a washroom, the regulation requires that a first aid room have easy access to a toilet. While no specific distance is defined, the intent is that a toilet be readily and conveniently accessible. Workers or first aid providers should be able to reach it quickly, without unnecessary travel, obstacles, or delays during treatment.

The regulation also requires that the first aid room include a sink with potable running water to support proper hygiene.

With respect to location, a first aid room does not have to be inside the main building. A trailer or separate structure may be acceptable, provided it meets all regulatory requirements and is located as close as practicable to the workers it serves.

When assessing whether a location is appropriate, employers should consider practical factors such as distance, accessibility, weather conditions, and how easily the room can be reached during an emergency.

For full requirements, see Section 12 of the First Aid Regulation (2004-130).

Answer (Eric Brideau, Chief Compliance Officer)

This is a great question, and it’s one we hear often.

The short answer is no, not every machine, tool or piece of equipment requires a written lockout procedure. Lockout requirements are based on risk and exposure to hazardous energy, not simply on whether something is called a “machine” or “equipment.”

In some situations, such as changing a blade on a plug-in or battery-powered hand tool, simply unplugging the tool or removing the battery (and keeping it under the worker’s control) may be sufficient. In other cases, particularly when workers are exposed to stored or potential energy while cleaning, maintaining, adjusting, or repairing equipment, a formal lockout procedure is required to prevent unexpected movement or re-energization.

Heavy equipment, complex machinery, and systems with multiple energy sources generally require more detailed lockout procedures. The key is understanding when a task places a worker at risk and ensuring that energy sources are properly controlled before work begins.

To help clarify when lockout is required, when it isn’t, and what an acceptable lockout procedure looks like, we’ve published a detailed interpretation of Sections 239 and 240 of the General Regulation.

👉 Read the full Lockout Interpretation: When do machine and equipment need a lockout procedure?