Technical Corner

The Quiet Evolution of the Recreation Facility Frontline First Responder

December 22, 2022

There was a time when our profession discussed the liability of providing a band-aid to a public skating participant or that we should not provide ice resurfacer snow dump chips to reduce swelling from an injury.  In today’s recreation world, the increased expectation of frontline staff being able to respond to all forms of human health crisis continues to evolve. Let’s walk back and take a look at how we got to this point in time. Back in the day, when ice hockey was really a “blood sport”, ice arenas included a “First Aid” room in rink design so that the traveling team doctor had a place to perform medical response in hope of getting the player back on the ice. On the other side of the facility, aquatic management was being directed to have a spinal board on site as there seemed to be a high number of back injuries that were being caused by diving incidents. So, what are the legal obligations for first response in a recreation facility?

There are two pathways that need to be navigated, one for workers, the other for users of the facility. Facility managers need to be familiar with and comply with Regulation 1101. Regulation 1101 requires all employers to ensure that first aid boxes and stations are in the charge of workers who hold valid first aid certificates issued by a training agency recognized by the Board. Employers should arrange for first aid training directly with the recognized training organization of their choice.

Regulation 1101 further states:

10. (1) Every employer employing more than fifteen and fewer than 200 workers in any one shift at a place of employment shall provide and maintain at the place of employment one stretcher, two blankets and a first aid station with a first aid box containing as a minimum.

11. (1) Every employer employing 200 or more workers in any one shift at a place of employment shall provide and maintain a first aid room.

There is no legal obligation for a recreation facility to have an actual First Aid room unless they have 200 plus workers. Nowhere in Regulation 1101, does it require any employer to prepare for public First Aid response. The minimum of providing comfort and care to a person in need is a moral obligation – not a legal requirement. Any decision to make this part of the services to be provided by facility staff to the public is an internal matter that should be approached as a business plan to the operation.

Deciding if the facility will house an automated external defibrillator (AED) is an additional managerial review obligation. Installing AED equipment has grown to be common practice in many public buildings including recreation infrastructure. These devices have proven themselves as an important first response tool. What has become lost at times is that the original intent was to make them available for public use – not to become a first response tool for facility staff to ensure public safety. However, once installed, these devices require inspection, maintenance and replacement based on projected lifecycle of the device.

Naloxone kits are the most recent addition to possible first response tools for public locations. These kits again allow the “public” to respond to an opioid health crisis as required. When first introduced, the kits were an option to be considered.  However, changes to the Occupational Health and Safety Act that will come into effect in June of 2023 shifts the duties of all employers “Where an employer becomes aware, or ought reasonably to be aware, that there may be a risk of a worker having an opioid overdose at a workplace where that worker performs work for the employer, or where the prescribed circumstances exist, the employer shall have such kits on-site”. Please refer to the Occupational Health and Safety Act, R.S.O. 1990, c. O.1 (

There is no argument that recreation facilities should be adequately prepared to provide first response. The question becomes is the community prepared to invest in this service and are frontline staff prepared to accept these responsibilities as part of their duties? Recreation frontline staff are dedicated professionals that are focused on providing the cleanest and safest environment possible. Facility managers, like many other workplaces, are struggling to attract and maintain a qualified workforce. The news is continually speaking to the trauma individuals experience based on first response. I am not suggesting that recreation staff are under these same daily pressures but when they do occur, they can impact a worker’s mental health. Will this quiet expectation be one more deterrent to attracting staff?

The earlier suggestion that these additions to facility service needs to be presented as a business plan approach suggests that facility first aid needs should have their own separate budget line. The costs of training, equipment, supplies, etc. all need to be clearly identified as part of the operational budget. Tools such as AED’s need to be added to the facilities Recreation Facility Asset Management (RFAM) operational and replacement plans.

Shifts in public behaviour will continue to be a challenge. What has not changed is the human compassionate response to any person’s health crisis. Facility management must have a clear plan on how these matters will be approached that is supported by a plan to maintain all the working parts to meeting these goals. Understanding the strict regulated obligations surrounding worker first aid requirements and if, or how, they overlap into public first response requires individual internal research. It is a complicated subject that can be highly charged by public poorly understood expectations. Facility managers would be wise to get in front of controlling their operations by developing clear policy and procedures.

    Comments and/or Questions may be directed to Terry Piche, CRFP, CIT and Director, Training and Research Development, Ontario Recreation Facilities Association

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