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AED requirements from OSHA 1926

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Under OSHA 29 CFR 1926, there is no general construction requirement that employers provide an AED on every construction site. The core federal construction requirements are to make first-aid services and medical care available, ensure prompt medical attention for serious injuries, and have trained first-aid personnel available when outside medical treatment is not reasonably accessible. OSHA 1926\.23 requires first-aid services and provisions for medical care for every covered employee, and 1926\.50 requires employers to ensure availability of medical personnel for advice, make provisions before work starts for prompt medical attention, and provide a trained first-aid person at the site when an infirmary, clinic, hospital, or physician is not reasonably accessible in time and distance. [3] [1] [1] [1]

For AEDs specifically, the cited OSHA construction standards do not create a blanket AED mandate for ordinary construction sites. OSHA guidance does, however, strongly support considering AEDs as part of the workplace first-aid program. OSHA's best-practices guide states that an AED should be considered when selecting first-aid supplies and equipment, that all worksites are potential candidates for AED programs, and that each workplace should assess its own AED needs as part of first-aid response planning. [7] [9]

What OSHA 1926 requires for first aid, emergency response, and trained personnel:

  • Before the project starts, arrange for prompt medical attention for serious injuries.
  • Ensure medical personnel are available for occupational health advice and consultation.
  • If outside medical care is not reasonably accessible in time and distance, have at least one person with a valid first-aid certificate available at the worksite.
  • Keep first-aid supplies easily accessible.
  • Provide transportation for injured workers to a physician or hospital, or provide a communication system to contact ambulance service.
  • Where 911 is unavailable, post physician, hospital, or ambulance numbers conspicuously.
  • Where 911 is used, ensure the communication system effectively reaches EMS and, if the system does not automatically provide location data, post clear worksite location information.

[1] [1] [5] [5] [5] [5] On CPR-trained personnel, general construction standard 1926\.50(c) requires first-aid-trained personnel under the accessibility test above, but it does not expressly require CPR training for all construction sites. CPR is expressly required in certain specific construction activities, such as permit-space rescue and electric power transmission/distribution work. For permit-space rescue, at least one rescue team or service member with current basic first-aid and CPR certification must be available. For Subpart V electric power transmission/distribution work, employers must provide medical services and first aid under 1926\.50, and when employees work on or associated with exposed lines or equipment energized at 50 volts or more, trained persons must be available; for field work with two or more employees, at least two trained persons must be available. [6] [2] [2] [2]

For AED availability, placement, inspection, and maintenance, OSHA 29 CFR 1926 does not provide detailed federal construction rules comparable to first-aid kit rules. The federal rule does require first-aid supplies to be easily accessible, and first-aid kits must be in weatherproof containers with sealed packages and checked before each job and at least weekly to replace expended items. By analogy and best practice, if an employer provides an AED on a construction site, it should be placed so it is quickly reachable, protected from weather and site damage, included in routine inspections, and maintained strictly per the manufacturer's instructions and local/state law. [1] [5]

A useful comparison is Washington State's electrical construction rule, which is not federal OSHA 1926 nationwide law, but illustrates what a more specific AED rule looks like. That rule requires an AED to be available and accessible when two or more employees perform work on or in close proximity to high-voltage lines and equipment, requires regular maintenance under manufacturer instructions and annual inspections, and requires at least two employees proficient in AED use at each such site. This is helpful compliance guidance, but it should not be mistaken for a general federal OSHA construction requirement. [4] [4] [4]

For regulatory compliance guidance, the safest federal OSHA approach is to treat AEDs as part of a broader emergency medical response assessment rather than as a presumed universal mandate. Evaluate response time to EMS and definitive care, site remoteness, workforce size, cardiac-risk factors, strenuous work, electrical hazards, heat stress, and whether crews are mobile or isolated. OSHA interpretation guidance has treated "reasonably accessible" medical care under 1926\.50(c) as generally meaning about 3 to 4 minutes from a medical facility to any portion of the worksite; where that response is not available, on-site trained first-aid capability is required. OSHA's best-practices guide also notes that AED use within 3 to 4 minutes after sudden cardiac arrest can dramatically improve survival, which is why remote or high-risk construction employers often adopt AED programs voluntarily. [8] [8] [9]

Practical compliance recommendations for construction employers:

  • Document your 1926\.50 medical-response assessment before mobilization, including nearest clinic/hospital, EMS response method, travel time, and communication reliability.
  • Ensure required first-aid coverage is present whenever outside medical care is not reasonably accessible; for Subpart V electrical work, meet the additional trained-person requirements.
  • Stock and inspect first-aid kits as required, keep them readily accessible, and protect them from weather.
  • If you provide AEDs, place them where they can be reached rapidly during the work being performed, identify them clearly, protect them from heat, cold, moisture, dust, vibration, and theft, and include them in site emergency planning.
  • Maintain AEDs according to manufacturer instructions, check pad and battery expiration dates, verify readiness indicators, and keep inspection records.
  • Train designated responders in first aid/CPR/AED use and refresh training on a schedule consistent with the training provider and site risk; OSHA guidance recommends annual instructor-led retraining for CPR/AED, although OSHA does not generally mandate a refresher frequency unless a specific standard does.
  • Coordinate the AED program with local EMS and applicable state law, including medical oversight, registration, post-use reporting, and quality assurance where required.
  • For remote, large, high-risk, electrical, or physically demanding construction operations, strongly consider AED deployment even when not expressly mandated by federal OSHA.

[10] [9]

10 source record(s)

Sources used for this answer

[1] WAC 296-45-125 - Medical services and first aid

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- WAC 296-45-125 Medical services and first aid. The employer must provide medical services and first aid as required in WAC [redacted identifier]. The following requirements also apply: (1) Cardiopulmonary resuscitation and first-aid training. When employees are performing work on or associated with exposed lines or equipment energized at 50 volts or more, persons trained in first aid including cardiopulmonary resuscitation (CPR) must be available as follows: (a) For field work involving two or more employees at a work lo- cation, at least two trained persons must be available. However, for line-clearance tree trimming operations performed by line-clearance tree trimmers who are not qualified electrical employees, only one trained person need be available if all new employees are trained in first aid, including CPR, within three months of their hiring dates. (b) For fixed work locations such as generating stations, the number of trained persons available must be sufficient to ensure that each employee exposed to electric shock can be reached within four mi- nutes by a trained person. However, where the existing number of em- ployees is insufficient to meet this requirement (at a remote substa- tion, for example), all employees at the work location will be trained. (2) First-aid supplies. First-aid supplies required by WAC [redacted identifier] must be placed in weatherproof containers if the supplies could be exposed to the weather. (3) First-aid kits. The employer must maintain each first-aid kit, ensure that it is readily available for use, and must inspect it frequently enough to ensure that expended items are replaced. The em- ployer also must inspect each first-aid kit at least once per year. (4) Any employer with employees who operate, maintain, or con- struct high voltage lines and equipment or who conduct line-clearance tree trimming in close proximity to high voltage lines and equipment must: (a) Make an automated external defibrillator available, s…

[2] Safety and Health Regulations for Construction (OSHA 29 CFR 1926) - 1926.50 - Medical services and first aid

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# Occupational Safety and Health Administration (cont.) ## 1926.50(d)(2) The contents of the first aid kit shall be placed in a weatherproof container with individual sealed packages for each type of item, and shall be checked by the employer before being sent out on each job and at least weekly on each job to ensure that the expended items are replaced. - 1926.50(e) Proper equipment for prompt transportation of the injured person to a physician or hospital, or a communication system for contacting necessary ambulance service, shall be provided. - 1926.50(f) - 1926.50(f)(1) In areas where 911 emergency dispatch services are not available, the telephone numbers of the physicians, hospitals, or ambulances shall be conspicuously posted. - 1926.50(f)(2) In areas where 911 emergency dispatch services are available and an employer uses a communication system for contacting necessary emergency-medical service, the employer must: - 1926.50(f)(2)(i) Ensure that the communication system is effective in contacting the emergency-medical service; and 1926.50(f)(2)(ii) 1926.50(f)(2)(ii)(A) When using a communication system in an area that does not automatically supply the caller's latitude and longitude information to the 911 emergency dispatcher, the employer must post in a conspicuous location at the worksite either: 1926.50(f)(2)(ii)(A)(1) The latitude and longitude of the worksite; or 1926.50(f)(2)(ii)(A)(2) Other location-identification information that communicates effectively to employees the Submit Feedback

[3] OSHA Letter of Interpretation | Frequency of refresher training for first aid and CPR

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U.S. DEPARTMENT OF LABOR # Occupational Safety and Health Administration • Standard Number: 1910.146(k)(2)(iii), 1910.151, 1910.151(b), 1910.266(i) (7), 1910.269(b)(1), 1910.410(a)(3), 1915.87, 1915.87(c)(5), 1926.50, 1926.50(c), 1926.951, 1926.968 OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov. February 23, 2023 Mr. John A. Contino, MD [redacted street address] Wynnewood, PA [redacted postal code] Dear Dr. Contino: Thank you for your letter to the Occupational Safety and Health Administration (OSHA) expressing support for annual CPR retraining and OSHA's previous guidance stated in CPL 2-2.53. OSHA cancelled CPL 2-2.53 in 2007 (https://www.osha.gov/enforcement/directives/cpl-02-07-04). Your letter cites OSHA's current guidelines for CPR training contained in OSHA 3317-06N 2006, Best Practices Guide: Fundamentals of a Workplace First-Aid Program. Although retraining intervals are not mandated by OSHA, this guidance, at p. 13, recommends that "Instructor-led retraining for life-threatening emergencies[,]" specifically CPR and AED, "should occur at least annually." OSHA has also published Letters of Interpretation (LOIs) that refer to CPR training. These LOIs were published in response to requests for clarification on OSHA Standard 1910.151, Medical Services and First Aid and can be found here: https://www.osha.gov/laws-regs/standardinterpretations/standardnumber/1910/1910.151%20-%20Index/result. Some OSHA standards, for example: Permit-required confined spaces (29…

[4] Program Directive: Standard Interpretation of 1926.5(c); First Aid Training on Construction Sites

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DOLI Virginia Occupational Safety and Health VOSH # VOSH PROGRAM DIRECTIVE: 06-013 (e-version) ISSUED: May 18, 1988 SUBJECT: Standard Interpretation of 1926.5(c); First Aid Training on Construction Sites A. Purpose. - This directive transmits to field personnel an interpretation received from Federal OSHA concerning the meaning of the words "reasonably accessible in terms of time and distance to the worksite.” contained in 1926.50(c). B. Scope. - This directive applies VOSH-wide. - C. - Action. The Assistant Commissioner and VOSH enforcement personnel shall assure that employers comply with the requirements of 1926.50(c) and the Federal OSHA interpretation, which was received by VOSH on April 28, 1988. D. Background. See attached letter dated April 11, 1988 requesting an official standards interpretation of 1926.50(c). E. Enforcement Guidelines. - As noted in the attached interpretation, the words "reasonably accessible in terms of time and distance to the worksite," contained in 1926.50(c), have been interpreted by Federal OSHA to “generally mean 3 to 4 minutes from a medical facility to any portion of the worksite where employees are or may be working." - In the absence of a medical facility within 3 to 4 minutes response time, 1926.50(c) requires that “a person who has a valid certificate in first aid training ... or equivalent training that can be verified by documentary evidence, shall be available at the worksite to render first aid.” ATTACHMENTS: Federal OSHA Interpretation of 1926.50(c). http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIO NS&p_id=[redacted postal code]&p_text_version=FALSE http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIO NS&p_id=[redacted postal code]&p_text_version=FALSE

[5] Safety and Health Regulations for Construction (OSHA 29 CFR 1926) - 1926.23 - First aid and medical attention

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U.S. DEPARTMENT OF LABOR # Occupational Safety and Health Administration - Part Number: 1926 - Part Number - Title: Safety and Health Regulations for Construction - Subpart: 1926 Subpart C - Subpart Title: General Safety and Health Provisions Standard - Number: - 1926.23 - Title: - First aid and medical attention. - GPO Source: e-CFR First aid services and provisions for medical care shall be made available by the employer for every employee covered by these regulations. Regulations prescribing specific requirements for first aid, medical attention, and emergency facilities are contained in Subpart D of this part. OSHA Standards Enforcement Topics Media Center Contact Us OF LABOR UNITED STATES OF MEDICAL # U.S. DEPARTMENT OF LABOR Occupational Safety and Health Administration [redacted street address] NW Washington, DC [redacted postal code] 1-800-321-OSHA 1-[redacted phone] www.osha.gov Submit Feedback

[6] Best Practices Guide: Fundamentals of a Workplace First-Aid Program

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# Introduction and Purpose (cont.) ## OSHA Requirements (cont.) OSHA www.osha.gov 1910.410 Qualifications of Dive Team 1926.950 Construction Subpart V, Power Transmission and Distribution If an employee is expected to render first aid as part of his or her job duties, the employee is covered by the requirements of the Occupational Exposure to Bloodborne Pathogens standard (29 CFR 1910.1030). This standard includes specific training requirements. A few of the medical emergency procedures mentioned in this guide as first aid may be considered medical treatment for OSHA recordkeeping purposes. The OSHA Recording and Reporting Occupational Injuries and Illnesses regulation (29 CFR 1904) provides specific definitions of first aid and medical treatment. If a medical emergency procedure which is considered by 29 CFR 1904 to be medical treatment is performed on an employee with an occupational injury or illness, then the injury or illness will be regarded as recordable on the OSHA 300 Log. ## First-Aid Supplies It is advisable for the employer to give a specific person the respon- sibility for choosing the types and amounts of first-aid supplies and for maintaining these supplies. The supplies must be adequate, should reflect the kinds of injuries that occur, and must be stored in an area where they are readily available for emergency access. An automated external defibrillator (AED) should be considered when selecting first-aid supplies and equipment. A specific example of the minimal contents of a workplace first- aid kit is described in American National Standards Institute ANSI Z308.1 - 2003, Minimum Requirements for Workplace First Aid Kits. The kits described are suitable for small businesses. For large operations, employers should determine how many first-aid kits are needed, and if it is appropriate to augment the kits with additional first-aid equipment and supplies. Employers who have unique or changing first-aid needs should consider upgrading their fir…

[7] Safety and Health Regulations for Construction (OSHA 29 CFR 1926) - 1926.1211 - Rescue and emergency services

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# Occupational Safety and Health Administration (cont.) ## 1926.1211(a)(2) (cont.) Has the capability to reach the victim(s) within a time frame that is appropriate for the permit space hazard(s) identified; - 1926.1211(a)(3)(ii) - Is equipped for, and proficient in, performing the needed rescue services; - 1926.1211(a)(3)(iii) - Agrees to notify the employer immediately in the event that the rescue service becomes unavailable; - 1926.1211(a)(4) - Inform each rescue team or service of the hazards they may confront when called on to perform rescue at the site; and - 1926.1211(a)(5) Provide the rescue team or service selected with access to all permit spaces from which rescue may be necessary so that the rescue team or service can develop appropriate rescue plans and practice rescue operations. - 1926.1211(b) An employer whose employees have been designated to provide permit space rescue and/or emergency services must take the following measures and provide all equipment and training at no cost to those employees: - 1926.1211(b)(1) Provide each affected employee with the personal protective equipment (PPE) needed to conduct permit space rescues safely and train each affected employee so the employee is proficient in the use of that PPE; - 1926.1211(b)(2) - Train each affected employee to perform assigned rescue duties. The employer must ensure that such employees successfully complete the training required and establish proficiency as authorized entrants, as provided by §§ 1926.1207 and 1926.1208; - 1926.1211(b)(3) Train each affected employee in basic first aid and cardiopulmonary resuscitation (CPR). The employer must ensure that at least one member of the rescue team or service holding a current certification in basic first aid and CPR is available; and Submit Feedback

[8] Safety and Health Regulations for Construction (OSHA 29 CFR 1926) - 1926.50 - Medical services and first aid

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U.S. DEPARTMENT OF LABOR # Occupational Safety and Health Administration - Part Number: 1926 - Part Number - Title: Safety and Health Regulations for Construction - Subpart: 1926 Subpart D - Subpart Title: Occupational Health and Environmental Controls Standard - Number: - 1926.50 - Title: - Medical services and first aid. - GPO Source: e-CFR ## 1926.50(a) The employer shall insure the availability of medical personnel for advice and consultation on matters of occupational health. ## 1926.50(b) Provisions shall be made prior to commencement of the project for prompt medical attention in case of serious injury. ## 1926.50(c) In the absence of an infirmary, clinic, hospital, or physician, that is reasonably accessible in terms of time and distance to the worksite, which is available for the treatment of injured employees, a person who has a valid certificate in first-aid training from the U.S. Bureau of Mines, the American Red Cross, or equivalent training that can be verified by documentary evidence, shall be available at the worksite to render first aid. 1926.50(d) ## 1926.50(d)(1) First aid supplies shall be easily accessible when required. Submit Feedback

[9] Best Practices Guide: Fundamentals of a Workplace First-Aid Program

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# Introduction and Purpose (cont.) ## First-Aid Supplies (cont.) OSHA www.osha.gov fire and rescue service or emergency medical professionals may be beneficial. By assessing the specific needs of their workplaces, employers can ensure the availability of adequate first-aid supplies. Employers should periodically reassess the demand for these supplies and adjust their inventories. ## Automated External Defibrillators With recent advances in technology, automated external defibrilla- tors (AEDs) are now widely available, safe, effective, portable, and easy to use. They provide the critical and necessary treatment for sudden cardiac arrest (SCA) caused by ventricular fibrillation, the uncoordinated beating of the heart leading to collapse and death. Using AEDs as soon as possible after sudden cardiac arrest, within 3-4 minutes, can lead to a 60% survival rate.³ CPR is of value because it supports the circulation and ventilation of the victim until an electric shock delivered by an AED can restore the fibrillat- ing heart to normal. All worksites are potential candidates for AED programs because of the possibility of SCA and the need for timely defibrilla- tion. Each workplace should assess its own requirements for an AED program as part of its first-aid response. A number of issues should be considered in setting up a worksite AED program: physician oversight; compliance with local, state and federal regulations; coordination with local EMS; a quality assurance program; and a periodic review, among others. The OSHA website at www.osha.gov or the websites of the American College of Occupational and Environmental Medicine at www.acoem.org, the American Heart Association at www.ameri- canheart.org, the American Red Cross at www.redcross.org, Federal Occupational Health at www.foh.dhhs.gov, and the National Center for Early Defibrillation at www.early-defib.org can provide additional information about AED program development. 3 American Heart Association in collabo…

[10] Safety and Health Regulations for Construction (OSHA 29 CFR 1926) - 1926.951 - Medical services and first aid

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U.S. DEPARTMENT OF LABOR # Occupational Safety and Health Administration - Part Number: 1926 - Part Number - Title: Safety and Health Regulations for Construction - Subpart: 1926 Subpart V - Subpart Title: Electric Power Transmission and Distribution Standard - Number: - 1926.951 - Title: - Medical services and first aid. - GPO Source: e-CFR 1926.951(a) General. The employer shall provide medical services and first aid as required in § 1926.50. ## 1926.951(b) First-aid training. In addition to the requirements of $ 1926.50, when employees are performing work on, or associated with, exposed lines or equipment energized at 50 volts or more, persons with first-aid training shall be available as follows: ## 1926.951(b)(1) Field work. For field work involving two or more employees at a work location, at least two trained persons shall be available. ## 1926.951(b)(2) Fixed work locations. For fixed work locations such as substations, the number of trained persons available shall be sufficient to ensure that each employee exposed to electric shock can be reached within 4 minutes by a trained person. However, where the existing number of employees is insufficient to meet this requirement (at a remote substation, for example), each employee at the work location shall be a trained employee. [59 FR [redacted postal code], Aug. 9, 1994; 79 FR [redacted postal code], July 10, 2014] Submit Feedback

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