It is common to use a self-commissioned survey to market one’s services but sometimes the evidence does not support some of the marketing statements. The latest survey by St John Ambulance is a good example of this.

According to St John Ambulance’s media release on 13 March 2013:

“Only 13 per cent of Australian workplaces know how to keep their employees safe according to new research released … by … St John Ambulance Australia.”

Cover of First aid in the workplace - code 2012This is reworded in the report (page 2) as

“…only 13% of Australian businesses are compliant with the new [First Aid in the Workplace Code of Practice]’s requirements…”

The survey sample does not support the generalisations above.

Page 6 of the survey report states:

“Surveys* of 600 employees and 100 employers (CEOs, senior managers, OHS managers) in low risk industries, namely the retail, hospitality and education sectors.”

It seems odd that only low risk industries are surveyed. Logically surveying high risk industries would be more relevant to a study of first aid due to their risk nature, particularly if one is to make sweeping generalisations, as above.. How important is first aid to a small retail store, perhaps, located in a shopping centre? How much more important is first aid in a high risk occupation such as a construction site or a remote mining operation? (discussed further below)

Government primary and secondary schools often have stricter first aid requirements imposed on them by their local Departments of Education.  These requirements may be based originally on the principles of the Safe Work Australia Code but are refined through administrative requirements due to a heightened duty of care and the application of in loco parentis.

The St John Ambulance data is also being reported inaccurately on the internet. For instance HCOnline states:

“Figures released today reveal an alarming 87% of Australian businesses are failing at first aid.”

“…failing at first aid”!! Where did that come from and what does it mean?

Additional and Prior Research

The author of the report, David Neal of Empirica Research, mentions the lack of high-risk occupation data on page 6 but makes a curious statement:

“Prior research in this area has often focused on high risk occupations that have more stringent first aid requirements (e.g. labourers, machinery operators) and therefore by default are likely to be more compliant with the first aid guidelines of the Code.”

This prior research does not seem to be referenced in the report with the other five references on page 24 yet it is important to be able to verify the statement that ” high risk occupations … have more stringent first aid requirements”. It is also odd to say that “by default” high risk occupations are likely to be more compliant with the guidelines of a First Aid Code that has only been in existence for nine months.

Additional Data Sources

St John Ambulance’s report states that additional information sources are used in the report ( “e.g. Australian Bureau of Statistics, Safe Work Australia, academic papers) and relevant regulatory frameworks (WHS Act)” page 3). However, St John Ambulance fails to clearly delineate between data from its own survey and that from secondary sources. For instance, the chapter on “frequency of first aid incidents” pages 9 & 10, starts with data from the Australian Bureau of Statistics (ABS) but the source of the data for Figures 1 & 2 are not listed. Without references it is possible to infer that all of the data in this chapter comes from the ABS which does not appear to be the case.

This lack of attention is odd in a report that is promoted as authoritative and from

” Australia’s largest and trusted supplier of first aid training and services…” (page 2).

Work Health and Safety Acts

It is also important to note that the Safe Work Australia Code has not been accepted by two Australian States (Western Australia and Victoria) as the Work Health and Safety Acts through which the Code gains its authority have not been passed by the States’ governments. This complicates the application of the secondary data sources and further weakens the generalisations which the media campaign uses.

St John Ambulance’s CEO, Peter LeCornu, acknowledges that WA and Victoria have not passed the WHS laws (page 2) but fails to explain how this could affect his survey’s use of national statistics and the report’s generalisations.

First Aid Risk Assessments

Further problems are raised by the report’s quote that:

“…only 13% of Australian businesses are compliant with the new [First Aid in the Workplace Code of Practice]’s requirements…”

For many years some Australian States have applied two options for first aid compliance, one is prescriptive and the other is based on a first aid needs assessment. The Safe Work Australia Code is based on risk management:

” This Code provides information on using a risk management approach to tailor first aid that suits the circumstances of your workplace, while also providing guidance on the number of first aid kits, their contents and the number of trained first aiders that are appropriate for some types of workplaces.” (page 4)

How has St John Ambulance been able to determine compliance when each workplace is likely to have a different combination of first aid equipment and training needs? A prescriptive Code may allow for such compliance statements but the First Aid in the Workplace Code of Practice is based on risk management principles that allow, and encourage, workplace variations.

The report’s information on compliance has not been independently verified as the survey sample is from employers and employees, as mentioned above.


The St John Ambulance report “First Aid Readiness in the Australian Workplace” should be considered as principally a marketing exercise (the body of the report includes repeated references to St John Ambulance’s phone numbers and services) even when the CEO refers to a “fact” that is not justified by the report:

“Alarmingly, the research highlighted that only 13% of Australian businesses are compliant with the new Code’s requirements, which represents a disturbing situation for the country. Many employers are failing to put the correct first aid measures in place and are putting their employees, customers and their businesses at risk. This fact, combined with a serious knowledge gap about the new Code is extremely concerning. In particular, 65% of employers are unaware that it is being implemented throughout most of the country.” (page 2, emphasis added)

It is common practice to build a marketing campaign around a survey but St John Ambulance states that

” The report aims to assist Australian employers and workplaces achieve best practice first aid standards and become compliant with Safe Work Australia’s new harmonised First Aid in the Workplace Code of Practice.” (page 2)

This is disingenuous as the aim of the report is clearly to sell St John Ambulance’s products and services through which companies may move towards compliance. The Australian Government’s First Aid Code of Practice can claim more legitimacy as its purpose is to provide:

“… practical guidance for persons conducting a business or undertaking on how to comply with duties under the WHS Act and Regulations to provide adequate first aid facilities in the workplace. It includes information on first aid kits, procedures, facilities and training for first aiders.” (page 2)

Workplace First Aid also needs to be seen in context of safety management principles where hazard controls are required to be implemented that specifically reduce the need for first aid. First aid is considered an administrative control in the hazard management hierarchy and companies need to be reminded that first aid is a post-incident activity that only reduces the cost of the injury and does not prevent the injury.

Some argue that first aid training may raise the awareness for safety in the minds of the first aiders but the only research SafetyAtWorkBlog has seen to support this was over twenty years ago from a small study in the Tasmanian forestry industry. That study was quoted by St John Ambulance for many years in its promotions. Clearly it has changed its strategy.

Kevin Jones

Note: Kevin Jones was employed by St John Ambulance for a couple of years in the 1990s.