Locked first aid cabinets and emergency access

January 23, 2007

Rikki Pottebaum

Affirmed Medical Services

[Recipient address omitted]

Dear Ms. Pottebaum:

This is in further response to your November 10, 2005 letter to the Occupational Safety and Health Administration (OSHA) requesting assistance in the interpretation of OSHA's requirements regarding locked first aid cabinets in the work place.

To answer your question succinctly, yes, first aid cabinets can be locked; however, they must be readily accessible in the event of an emergency. Locking the cabinet may limit accessibility. Title 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."

Employers may elect not to provide first aid services if all such services will be provided by a hospital, infirmary, or clinic in near proximity to the workplace. 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.

However, if OSHA found that 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 29 CFR 1910.151(b).

I hope you find this information helpful. Please be aware that OSHA's enforcement guidance is subject to periodic review and clarification, amplification, or correction. Such guidance could also be affected by subsequent rulemaking. In the future, should you wish to verify that the guidance provided herein remains current, you may consult OSHA's website at http://www.osha.gov. If you have any further questions, please feel free to contact the Office of General Industry Enforcement at (202) 693-1850.

Sincerely,

Richard E. Fairfax, Director

Directorate of Enforcement Programs