Life-Threatening Bleeding at Work: What HSE Expects and What to Have

Search for this and you will mostly find people selling bleed kits. The better suppliers are straight with you that the kit is not legally required; the question they leave unanswered is how you decide whether you need one. Here is the actual position: what HSE changed in 2024, which workplaces it applies to, what the current clinical guidance says to do, and why buying the equipment without the training is the one outcome worth avoiding.

Last reviewed: 20 September 2026 against HSE guidance L74 (January 2024 amendments) and the Resuscitation Council UK’s 2025 Resuscitation Guidelines, published 27 October 2025.

What counts as life-threatening bleeding?

Bleeding that will kill the casualty in minutes if it is not stopped — typically arterial bleeding from a limb, a deep wound to the neck, armpit or groin, a traumatic amputation, or a major crush or machinery injury. It is distinguished from ordinary “major bleeding” by speed: direct pressure and a dressing are not keeping up, and the casualty is losing blood faster than an ambulance can arrive.

Every First Aid at Work and Emergency First Aid at Work course already covers a casualty who is “wounded and bleeding”. What is being discussed here sits on top of that: the small number of injuries where standard pressure and dressings are not enough, and where specific equipment and technique buy the time an ambulance needs.

What HSE changed in 2024

The third edition of L74 was reissued in January 2024 with three amendments. One of them was to “change the term ‘catastrophic bleeding’ to ‘life-threatening bleeding’ with more guidance on what employers should do if they identify this as a risk in their workplace”.

The wording is worth noticing, because a great deal of the material still in circulation — including pages published well after 2024 — calls it “catastrophic bleeding”. That is the pre-2024 term. It is not wrong as English, and plenty of good training still uses it, but on a compliance page it is a reasonable clue that the author has not been back to the current guidance.

What the amended guidance actually adds is in three places:

• The needs assessment checklist (L74 Table 1) now prompts you, when reviewing your accident record, to note “any life-threatening events (eg severe or life-threatening bleeding)” and how and where they happened.
• Additional equipment (paragraph 39) lists haemostatic dressings, tourniquets and wound packing materials among the items an assessment might call for.
• Training (paragraph 59): “if the needs assessment has identified that first-aiders may have to manage life-threatening bleeding, employers should ensure the training provider includes this on an FAW course.”

That last one is the sentence most employers have not read, and it is the actionable one. It does not tell you to buy a separate course. It tells you to tell your provider.

Is a bleed control kit a legal requirement?

No. There is no regulation requiring a bleed control kit, a tourniquet or a haemostatic dressing in any workplace, and HSE does not require them everywhere. The legal duty is the same one that governs every other piece of first aid equipment: provision that is adequate and appropriate in your circumstances, decided by your first aid needs assessment.

What has changed is that “we never thought about it” is now a weaker answer than it was, because the guidance explicitly asks you to think about it. For a call centre, the assessment will conclude no. For a sawmill, it is difficult to see how it could.

Which workplaces should consider it?

L74’s Appendix 4 lists examples of additional training that may be needed after a needs assessment. Two entries are relevant here:

Reading across from the hazards in your own risk assessment, the realistic triggers are:

What current guidance says to do

The Resuscitation Council UK published its 2025 Resuscitation Guidelines on 27 October 2025, and for the first time they include a dedicated First Aid section. RCUK is the body L74 names as a standard-setter for what first aid courses should teach, so this is the sequence your training should match.

RCUK also makes a practical point that matters on a real site: “In the absence of any first aid dressings, any clean material can be utilised.” Pressure with a clean shirt beats waiting for the right dressing.

This is a summary of published guidance so that you know what your training should cover. It is not training, and reading it does not make anyone competent to do it under pressure. That is the entire argument for the training half of this.

Tourniquets: what the 2025 guidance actually says

Tourniquets went through a long period of being taught as a last resort of last resorts. Current RCUK guidance is more direct: apply one as soon as possible for life-threatening limb bleeding that direct pressure is not controlling. The specifics matter:

• Placement: “Place the tourniquet around the traumatised limb 5-7cm above the injury, but not over a joint.”
• Tightness: “Tighten the tourniquet until the bleeding slows and stops.” A tourniquet that has not stopped the bleeding is not tight enough and is doing harm without benefit.
• Time: “Write the time the tourniquet was applied.” The ambulance crew and the hospital need it.
• Do not release it: “Do not release the tourniquet. It should only be released by a healthcare professional.”
• A second one: “In some cases, you may need to apply a second tourniquet, above the first tourniquet, to control the bleeding.”

Two things follow for employers. First, a tourniquet is only useful on a limb — it does nothing for a wound to the neck, armpit or groin, which is where packing and pressure come in. Second, the “write the time” step is the one that gets forgotten, and a marker pen is the cheapest item in the kit.

We do not reproduce improvised tourniquet technique here. RCUK’s guidance does not describe one, and an improvised tourniquet applied without training is as likely to cause harm as help. If the assessment says you need a tourniquet, buy a proper one and train people on it.

Haemostatic dressings and wound packing

A haemostatic dressing is a dressing impregnated with an agent that speeds up clotting. RCUK’s wording is that a standard dressing will do but a haemostatic one is preferable — “a standard or ideally a haemostatic dressing” — applied directly to the bleeding point, with firm pressure on top.

Wound packing is pushing the dressing into a deep wound so that pressure reaches the bleeding vessel rather than the surface. It is the technique for junctional wounds — groin, armpit, neck — where a tourniquet cannot be used, and it is the part of this that is hardest to do correctly without having practised it. HSE lists wound packing materials, alongside haemostatic dressings and tourniquets, among the additional equipment a needs assessment might call for.

What goes in a bleed control kit

As with ordinary first aid kits, there is no mandatory contents list. A kit assembled for life-threatening bleeding typically contains a tourniquet, a haemostatic dressing, compressed gauze for packing, a trauma or pressure dressing, strong gloves, shears able to cut through clothing, a foil blanket and a marker pen. Some organisations also site Public Access Trauma (PAcT) kits in publicly accessible cabinets, designed so that an untrained bystander can use them with the instructions provided.

If you want a purchasing shortcut, BS 8599-1 — the voluntary British Standard for workplace kits, currently BS 8599-1:2019+A1:2026 — includes a critical injury pack category alongside the ordinary kit sizes. As always, the standard is not law and your assessment still decides. The wider picture on kits is in workplace first aid kit requirements.

Site the kit where the hazard is, not in the office. A critical injury pack two buildings away from the saw is decoration.

Training: what a FAW course already covers, and what is additional

The failure mode to avoid is buying the kit and not the training. Equipment nobody has handled does not get used, or gets used badly — a loose tourniquet increases blood loss rather than stopping it. If the assessment justifies the equipment, it justifies the training; if it does not justify the training, question whether it justifies the equipment.

Refresh it too. Bleeding-control skills decay like any other practical skill, which is part of why HSE strongly recommends annual refresher training across the three-year certificate period.

Martyn’s Law: what it does and does not require

The Terrorism (Protection of Premises) Act 2025, known as Martyn’s Law, received Royal Assent on 3 April 2025. It is being cited in a good deal of bleed-kit marketing, so it is worth being clear about what it says.

That does not make the question irrelevant. If you run a venue in scope, you will be writing public protection procedures anyway, and HSE’s own guidance separately asks hospitality and events employers to consider additional training for injuries from violent incidents. Those are two good reasons to look at it. “The law now requires a bleed kit” is not one, because it does not.

After the incident: RIDDOR, and looking after the responder

An injury of this severity is very likely to be reportable to HSE under RIDDOR. The list of specified injuries to workers includes “amputation of an arm, hand, finger, thumb, leg, foot or toe” and crush injuries causing “injuries to the brain or internal organs in the chest or abdomen”. Separately, an accident that leaves a worker unable to do their normal duties for more than seven consecutive days — not counting the day of the accident, but including weekends and rest days — must be reported within 15 days. Check the specific injury against the RIDDOR criteria: a first aid record is not a RIDDOR report, and the two have different deadlines.

Record the incident in the first aid book, and feed it straight back into the needs assessment: a life-threatening bleed that actually happened is the strongest possible evidence about what your provision should look like.

Then look after the person who dealt with it. RCUK’s 2025 guidelines explicitly recognise that attempting resuscitation can be distressing for lay rescuers and that systems should provide support afterwards; the same applies, if anything more so, to someone who has just packed a wound or applied a tourniquet to a colleague. Make sure they are not simply sent back to work.

Common mistakes

What this guide does not cover

It is not first aid training and does not teach technique — the steps above are a summary of published guidance so you know what your training should include. It does not cover improvised tourniquets, pre-hospital care beyond first aid, military or tactical protocols, or the clinical management of internal bleeding. It is written for Great Britain.

Getting life-threatening bleeding onto your first aid training

If your needs assessment has identified this risk, L74 paragraph 59 tells you what to do about the training: make sure your provider includes it on the First Aid at Work course. That is a conversation, not a separate purchase — tell us what your assessment found and what your hazards are, and we will tell you honestly whether it belongs on your course and what it would involve. We have been running first aid at work courses across Greater Manchester and the North West since 1996, as open course places and as group training at your premises for up to 12 people.

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Frequently asked questions

Is a bleed control kit a legal requirement in UK workplaces?

No. No regulation requires a bleed control kit, tourniquet or haemostatic dressing. The legal duty is first aid equipment that is adequate and appropriate in your circumstances, decided by your first aid needs assessment. HSE’s 2024 guidance asks employers to consider life-threatening bleeding in that assessment, which is a prompt to decide, not a requirement to buy.

What did HSE change in 2024 about catastrophic bleeding?

The January 2024 reissue of L74 changed the term “catastrophic bleeding” to “life-threatening bleeding” and added guidance on what employers should do where they identify it as a risk: consider additional equipment such as haemostatic dressings, wound packing and tourniquets, and additional training, and ensure the training provider covers it on the FAW course.

Which workplaces does HSE say should consider bleeding control?

L74 Appendix 4 names agriculture, forestry and construction, and working locations in remote areas. It also says employers in hospitality, events and other relevant sectors should consider additional training for injuries to colleagues or the public resulting from terrorist acts or other violent incidents.

Does Martyn's Law require us to have a bleed control kit?

No. The Terrorism (Protection of Premises) Act 2025 requires in-scope premises to notify the Security Industry Authority and to have appropriate public protection procedures, with additional measures at the enhanced tier. It does not mandate first aid training, bleed control kits or medical equipment, and it is not yet in force — the Government has indicated an implementation period of at least 24 months from Royal Assent in April 2025.

Where should a tourniquet be placed?

Resuscitation Council UK’s 2025 guidelines say to place it around the injured limb 5–7cm above the injury, but not over a joint, and to tighten it until the bleeding slows and stops. Write down the time it was applied. A second tourniquet above the first may be needed if bleeding continues.

Should a tourniquet ever be loosened or removed by a first aider?

No. RCUK’s guidance is explicit: do not release the tourniquet — it should only be released by a healthcare professional. Loosening it to check the wound restarts the bleeding the tourniquet was applied to stop.

Does a First Aid at Work course already cover this?

FAW and EFAW both cover a casualty who is wounded and bleeding, using pressure and dressings. Tourniquets, haemostatic dressings and wound packing are additional training on top of that syllabus. Where your needs assessment identifies the risk, HSE says to ensure your training provider includes it on the FAW course.

Can anyone use a bleed control kit, or do they need training?

Public Access Trauma kits in public cabinets are designed to be usable by an untrained bystander with the instructions supplied. For workplace provision, HSE treats this as additional training, and for good reason: a tourniquet applied too loosely can increase blood loss rather than stop it. Buying the equipment without the training is the outcome to avoid.

What should I do right now if someone is bleeding severely?

Call 999 and apply firm, direct manual pressure to the bleeding point — with a dressing if one is to hand, or any clean material if not. Keep the pressure on until help arrives. If a limb is bleeding uncontrollably and a tourniquet and a trained person are available, current guidance is to apply it as soon as possible.

Is a life-threatening bleed reportable under RIDDOR?

Very possibly, but it depends on the injury rather than on the bleeding. RIDDOR’s specified injuries to workers include amputation of an arm, hand, finger, thumb, leg, foot or toe, and crush injuries to the brain or internal organs in the chest or abdomen. Separately, an accident that stops a worker doing their normal duties for more than seven consecutive days must be reported within 15 days. Reporting is a separate duty from first aid record keeping.

Sources

• Resuscitation Council UK, 2025 Resuscitation Guidelines: First Aid Guidelines, published 27 October 2025
• HSE, First aid at work: Guidance on Regulations, L74, third edition, amended January 2024 — Table 1, paragraphs 28, 39 and 59, and Appendix 4
• HSE, Selecting a first-aid training provider, GEIS3 (rev2) — FAW and EFAW syllabus content
• ProtectUK, Martyn’s Law — Terrorism (Protection of Premises) Act 2025
• HSE, RIDDOR reporting requirements

For the wider legal picture see workplace first aid requirements; to decide whether this applies to you, work through the first aid needs assessment. What is current in CPR and defibrillation is in CPR and resuscitation guidelines. Questions? Call 0845 838 4643 or use the enquiry form on this page.