This is a swingeing reading of the law. Health and Safety (First-Aid) Regulations 1981 (oh yeah, we're getting into legislation now) says companies only have to make provision for their employees. So FCC is legally in the right. Morally however... HSE guidance "strongly recommends that non-employees are included in an assessment of first-aid needs and that provision is made for them". This is the principle that covers children in schools, and we definitely had our grazed knees and bumped heads looked after post-1981.
Is FCC's refusal to extend first aid care to its paying passengers an example of the creeping fear of litigation, spreading from the United States, or them simply not being willing to provide whatever training or insurance cover is necessary? Surely, rather than relying on members of the public, employees of a company that comes into contact with thousands of people every day (some packed into hot, cramped carriages) should be able to put someone into the recovery position until an ambulance arrives?