First aid supplies: Lock ‘em up or leave ‘em out?
One way employers try to handle skyrocketing inflation is to manage first aid supplies. But do OSHA regulations allow employers to lock first aid supplies as a way to control costs?
Our experts are often asked whether OSHA permits locking first aid supplies. In a January 23, 2007, OSHA letter of interpretation (LOI), OSHA confirmed that first aid cabinets can be locked. The LOI stated, however, that first aid supplies must be readily accessible in the event of an emergency. Additionally, 29 CFR 1910.151(b) states: “In the absence of an infirmary, clinic, or hospital in near proximity to the workplace which is used for the treatment of all injured employees, a person or persons shall be adequately trained to render first aid. Adequate first aid supplies shall be readily available.”
What is “readily available”?
OSHA defines “readily available” as accessible within three to five minutes and warns that locking first aid supplies, whether kits or cabinets, may limit employee accessibility per the standard. The agency advises that if an employer was relying on first aid services not provided by a clinic, infirmary, or hospital and adequate first aid supplies were not available when needed, then the employer would be in violation of 1910.151(b).
But my supplies are disappearing at an alarming rate!
If you’re concerned with supplies being used in a manner not intended by the company, there are ways to manage supplies. For example, employers could use vending machines that allow employees to scan their badges and get basic supplies or personal protective equipment free of charge. This can help employers manage their supply chain and evaluate by whom and for what supplies are being used.
If opting to lock your first aid supplies, remember to make supplies readily accessible (within three to five minutes). This may require that additional keys for locks be made available to multiple personnel at all times when workers are present.
What supplies are required for my first aid kits?
Although their recommendations are non-mandatory, OSHA suggests using the American National Standards Institute (ANSI) for reference to determine what supplies you need to have. The contents for Class A kits listed in the ANSI standard should be adequate for small worksites. Class B kits are designed with a broader range and quantity of supplies to deal with injuries in more complex or high-risk environments (for example, larger operations or multiple operations conducted at the same location).
It’s important to note that although OSHA is still citing ANSI’s 1998 standard, an updated version of the standard, ANSI/International Safety Equipment Association (ISEA) Z308.1-2021, was approved on April 15, 2022, and went into effect on October 15, 2022. Major changes to the standard included:
- Changing tourniquet type to ensure it meets first aid needs. The equipment intended to prevent blood loss should be at least 1.5 inches wide and be effective for limb sizes 7–33 inches around.
- Making foil blankets mandatory. This measure was enacted after assessing similar international standards and recognizing “the multiple purposes that the item can serve to respond to first aid emergencies.”
- Providing further guidance on bleeding control kits. According to ISEA, these “contain more advanced first aid supplies to immediately treat life-threatening external bleeding.”
Determining what first aid supplies should be accessible depends on the workplace hazards and potential injuries. A great place to begin is by assessing your Form 300 injury logs to see the types of injuries already reported. Most employers perform risk assessments, beginning with a review of the Form 300 logs, to drive their decisions. OSHA also provides guidance to employers in 1910.151 Appendix A.
Keys to Remember
Employers must understand the accessibility risks associated with locking first aid cabinets even though OSHA and ANSI do not prohibit this practice. First aid supplies must be readily accessible (within three to five minutes) in the event of an emergency.
