Workplace AED programs and the law in the US

An AED on a wall does not save lives by itself. It saves lives when it can be reached quickly, when its battery and pads are ready, when people nearby know where it is and are willing to use it, and when the workplace has thought through what happens before, during and after a cardiac arrest. This is the work of an AED program, sometimes called a public access defibrillation program. This lesson explains the elements of a good program and the legal framework that applies in your country.

Deciding whether and where to place AEDs

Start with a needs assessment, as for first aid in HSE-110. Factors that point toward having AEDs include a large number of workers or visitors, older workers or clients, physically demanding work, electrical hazards, public spaces such as lobbies, gyms, arenas and transit stations, remote locations far from paramedics, and long emergency response times. Many organizations now treat an AED as standard equipment in any workplace with more than a handful of people, much like a fire extinguisher.

Placement is about time. Guidance from resuscitation organizations commonly aims for an AED to be retrieved and brought to the person within about 3 minutes, which means it should be within about a 1.5-minute walk each way. In practice, place AEDs in visible, central, well-signed locations along normal walking routes: main entrances, reception, elevator lobbies, cafeterias, gyms and high-risk work areas. On multi-floor buildings, consider an AED on every floor or every few floors near the elevators. On large industrial sites, consider vehicles and remote work areas. AEDs should be unlocked and accessible to everyone whenever the area is occupied; an AED locked in an office is of little use at night.

Maintenance: the AED must be ready

AEDs run regular self-tests and show a status indicator, often a green light, check mark or hourglass, that tells you whether the device is ready. A red light, an X, a beeping alarm or a blank display means it needs attention. Batteries and pads have expiry dates, commonly every two to five years depending on the model; pads are single-use and must be replaced after every use. A designated person should check every AED on a regular schedule, recording the results.

People: training, awareness and drills

Every worker should know where the nearest AED is and that anyone may use it. A core group of responders should be trained in CPR and AED use through a recognized course and keep certification current, usually by retraining every one to three years depending on the provider and regulation. Refresher sessions in between help skills stick; CPR skills fade within months without practice. Include AED locations in orientation, post them on floor plans, and run drills: a simulated cardiac arrest that tests calling 9-1-1, fetching the AED, meeting paramedics at the door and timing each step reveals problems such as locked doors, missing keys or unclear addresses before a real event does.

The legal framework

In the US, every state has laws about AEDs, but they vary widely. There is no federal OSHA standard requiring AEDs in workplaces. The main legal elements are:

• Mandatory placement in some places. Many states require AEDs in certain settings, such as schools, health clubs, sports facilities, state buildings, large public venues or swimming pools; New York, for example, requires AEDs in health clubs and public schools. Since 2023, a wave of state laws has required schools to have cardiac emergency response plans with AEDs, training and drills. Federal rules require AEDs on US airliners that carry a flight attendant, and federal buildings follow public access defibrillation guidelines.
• Civil liability protection. The federal Cardiac Arrest Survival Act of 2000 protects people who use an AED in good faith, and those who acquire one, where state law does not already provide immunity, except for gross negligence or wilful misconduct. All states also have their own Good Samaritan or AED immunity provisions, some of which apply only if the owner meets requirements such as training, maintenance or registration.
• Workplace safety law. OSHA has no AED standard but encourages employers to consider AEDs, and has published guidance on AEDs in the workplace. OSHA's first aid standard, 29 CFR 1910.151, requires trained first aid providers where medical help is not in near proximity, and some standards require CPR training, such as 1910.269 for electric power generation, transmission and distribution and the rescue provisions for permit-required confined spaces in 1910.146. Under the General Duty Clause, an employer's hazard assessment may point to an AED as a reasonable precaution.
• Registration and program requirements. Many states require or encourage AED owners to notify local emergency medical services or register the device, keep it maintained according to the manufacturer and train expected users. Some states have dropped earlier requirements for physician oversight; others still require it. Check your state's law when setting up a program.

After an event

When an AED is used, the work does not end when the ambulance leaves. Steps include: replacing the pads and checking the battery so the AED is back in service quickly; restocking the rescue kit; downloading the event data from the AED if the manufacturer or emergency service requests it, because it records the rhythm and the timing of shocks and CPR, which helps hospital teams; completing incident and first aid records; and reporting to the workplace safety regulator or workers' compensation board if required.

Responders also need support. Giving CPR is physically and emotionally intense, and outcomes are often poor despite everyone's best efforts. Responders may feel guilt, replay events or worry they did something wrong. A short, supportive debrief soon after the event, focused on what happened, what went well and what could be improved rather than on blame, helps people process the experience. Offer access to an employee assistance program or other support, and follow up in the days and weeks afterward. HSE-109 covers psychological support after traumatic events. Survivors and their families, too, may want to meet and thank the responders, and workplaces can help arrange this if everyone wishes it.

Reviewing the program

A good AED program is reviewed at least annually and after every use or drill: are AEDs in the right places, are inspections being done and recorded, are enough people trained on every shift, do the 9-1-1 instructions on posters and in the emergency plan give the right address and entrance, and have changes to the building, the workforce or the law been accounted for?

Inspecting and recording

Keep a simple log for each AED with its location, serial number, the dates of each inspection, the expiry dates of pads and batteries, any problems found and corrective action taken. A tag on the cabinet showing the last inspection date reminds the checker and reassures users. Wireless monitoring systems offered by some manufacturers can report status automatically, but a regular in-person check is still needed to confirm the cabinet is accessible, the rescue kit is complete and the signs are visible.

Program managers should also keep a list of trained responders on each shift, with their certification expiry dates, and arrange retraining before certificates lapse. When responders leave or change shifts, the list and the coverage plan need updating.

Finally, involve workers in the program. People are more likely to use an AED they have seen, touched and practiced with. Short demonstrations at staff meetings, a visible map of AED locations and a named program contact who answers questions all help turn an AED on the wall into an AED that gets used when it matters.