Does OSHA Allow for Locking First Aid Cabinets in the Workplace?
Scenario: You are the plant safety director for a metal forming and processing operation consisting of approximately 500 employees. You have a trained, in-house medical/first aid team of about 25 employees as well as adequately stocked first aid supply cabinets strategically placed throughout the facility which are easy to locate. You have discovered an ongoing problem involving employees who are receiving small injuries such as a cut and using the supplies in the first aid cabinets to self-treat and not reporting these events. This practice is causing you two major concerns. The first is that these minor injuries are going unreported; the second is because your supplies are being depleted without anyone’s knowledge, the cabinets may not be restocked in a timely manner. In an attempt to improve the reporting of small injuries to proper personnel, you decide to start locking first aid cabinets, supplying each of your designated first aid providers, supervisors, and area managers with a key to each of the cabinets. Shortly thereafter, your employee relations manager comes to you stating that the employees are upset that you started locking first aid cabinets and denied them access to the first aid supplies and he cites 29cfr1910.151(b) where it states “Adequate first aid supplies shall be readily available” believing that this applies to all employees. Your stance is employees should not be self-treating, you need these minor injuries reported, and the “Adequate first aid supplies shall be readily available” applies to access for those who are designated to provide first aid treatment, and doesn’t mean for each employee to have unfettered access. You state you are going to continue locking first aid cabinets for that reason.
Question: Is your stance correct and if OSHA were called in to investigate, would/could you be cited for not having the first aid supplies available to “all” employees?
Answer: In a letter of interpretation dated January 23, 2007 to Rikki Pottebaum of Affirmed Medical Services, OSHA states the following “To answer your question succinctly, yes, first aid cabinets can be locked”. It is important to share that the letter does go on to say “however, they must be readily accessible in the event of an emergency”. Additional verbiage states “If the employer has persons who are trained in first aid, then adequate first aid supplies must be readily available for use. These supplies need to be stored in a convenient area available for emergency access.” We would argue that in this scenario you have fulfilled this requirement by providing each of your designated first aid providers and supervisors with a key to each cabinet. In the event of an emergency, there would be adequate personnel who have immediate access to the first aid cabinets. Keep in mind, the standard and the letter of interpretation both state “in the event of an emergency”. It doesn’t state that it has to be available to all or for treatment of minor injuries.
Not having First Aid providers trained and certified can result in OSHA fines. Click here to read more.