019 - Waddington Educational Resources Pty Ltd

019 Waddington Educational Resources PTY LTD

Waddington Educational Resources Pty Ltd

Dear Safe Work Australia,

As an Australian based first aid kit manufacturer/supplier for more than 20 years, with academic qualifications in Teaching and Special Education (20 years), including 10 years experience as a trained workplace OHSW Representative and 8 years as a voluntary St John Ambulance Officer, I wish to provide the following feedback with regards to your proposed First Aid Codes of Practice in relation to First Aid Kit and Module contents. As the kit contents appear to be heavily based on the new SafeworkSA kits, required as of December 10, 2010, and given my organization is based in SA and has been supplying the new SA kits for over a year, I hope that my submission will be worthwhile and taken seriously.

1. The Remote Module calls for a cervical collar. I put you on notice that including a cervical collar could well be a serious hazard in itself and may result in a well-meaning first aider causing irreparable damage to an injured person by putting on this piece of paramedical equipment. In my view, this item has no place in a first aid kit. Even its size would be difficult to include and its type cursory (e.g. some medical practitioners question the effectiveness of soft type collars). If an injured person has a suspected spinal injury, then medical assistance (e.g. ambulance) must always be called. This would be in line with good general first aid practice (e.g. ref: Basic First Aid Notes (Waddington, 2011, reviewed by Ella Tyler). For Fractures, Sprains, Strains and Sports injury, or any injury where the person cannot move or requires a stretcher, then an ambulance should be called and the person kept safe from dangers and/or the game halted.

2. The Remote Module calls for a reference manual. This seems to suggest a large book rather than a brief approach to first aid instructions. If it is a large book, then I find this to be outside of the scope of what we would expect of a general first aider and not in keeping with better practice for risk assessments involving remote locations. First Aid instructions should always be straight-forward and as simple as possible. In cases where there is a risk of remote first aid, a mobile smart phone or emergency satellite phone/beacon would be a far better suggested recommendation rather than some big first aid ‘recipe’ type manual. At a minimum, the inclusion of a first aid manual could be a recommended inclusion rather than a mandatory inclusion. To make it mandatory opens up a situation where vested interests of the largest First Aid organizations will be satisfied and the works unavailable to smaller kit manufacturers. Another issue concerning large books/manuals, they are simply not easy to transport and are not being published as often these days when electronic forms are readily available on the Internet, more up-to-date and easily accessible via smart phones.

I recommend that a reference manual not be included but a statement regarding the recommended inclusion of a smart mobile phone and/or emergency satellite phone/beacon depending on the expected risk due to remote locations.

3. Saline 30ml should not be seen to be a standard for saline. 30ml size can be confused with ampoules of antiseptic which are more common in 30ml and would be hazardous if accidentally used in eyes. In my 20 years experience using saline in schools and in the field as a voluntary St John First Aider, whenever I used 30ml ampoules there was wastage in almost all occasions. 15ml saline was always more economical and more cost efficient.

I strongly recommend only 15ml be stated for eyewash, or at the very minimum, 2 x 15ml eyewash be an option. In consultation with Annette Kappler Principal Policy Officer Policy & Strategy Group SafeWork SA, this was highlighted 10/2/2010 and the response from her was 2 x 15ml saline would still meet the 30ml minimal requirement for the Standard Kit. 019 Waddington Educational Resources PTY LTD

4. 25g hydrogel tube for the Burns Module is also a poor choice. Once a tube is opened, it is contaminated and there is a potential for a lot of wastage. Like point 1 above, this is not the best option. Instead, 8 x 3.5g sachets should be stated, or at the very minimum, 8 x 3.5g sachets be an option. In consultation with Annette Kappler Principal Policy Officer Policy & Strategy Group SafeWork SA, this was highlighted 10/2/2010 and the response from her was 8 x 3.5g sachets would still meet the 25g tube requirement for the Burns Module.

5. If hydrogel dressing sizes are ever recommended, the base size should be 10x10cm as this would be the most efficient and cost effective size. For larger burns, multiple dressings can be applied.

6. I do not believe 50 dressing strips are necessary for a small kit. 20 would be sufficient as a recommended minimum.

7. The use of clean plastic sheets in a first aid situation may open up a can of worms with regards to Therapeutic Devices. Under TGA regulations, if a first aid kit item has a therapeutic use, it must be registered as a therapeutic device. I brought this to the attention of Principal Policy Officer Policy & Strategy Group SafeWork SA, 23/12/2009, as well as the chief medical officers at the Royal Adelaide Hospital Burns Unit (who established the Burns Module requirements), but it was never resolved. From what I understand, it emerged that surgical drapes were being used over burns, hence the discovery that clean plastic sheets were a better option as a burn cover. These drapes had a secondary use for burns. So, along with another supplier, we simply supply clean plastic sheets in 3 sizes for use as burn covers as, under recommendations by the Royal Adelaide hospital Burns Unit, in general field situations calling for a plastic covering, most people would use cling film (also not a listed as a device). So perhaps the requirement that clean plastic sheeting be a listed device is simply too pedantic.

8. It struck me as being odd that there are no real large dressings (e.g. combine 20x20cm) apart from that offered in the BPC No.15. Small 5x5cm dressings are ridiculously small. 7.5x10cm would be best described as small and can be cut down if needed. 10x10cm should be stated as medium and a large would be 20x20cm combine (which is not non-adherent).

9. In line with 2009 NT Snake Bite research, test trials conducted by Menzies School of Health Research student Elizabeth Canalea, 10 or 15cm Heavy Weight Elasticized Crepe should be the recommended minimum requirement for first aid response to snake bites.

10. The warning with regards to latex allergy makes for the possible inclusion of any latex gloves hazardous. Given the warning that there is a possibility that a first aider, or even the injured, could be allergic to latex, and that this may well be unknown at the time, it would be better to state only nitrile gloves. Vinyl gloves are not a preferred option in the medical industry any more as they can break more easily than nitrile and are sometimes prone to being porous.

I recommend that nitrile be listed as the preferred disposable glove.

Should you require further information, please do not hesitate to contact me.

Yours faithfully,

Neil Waddington Dip.T. B.Ed(Special Ed)