OSHA does not have a rule that names automated external defibrillators or orders employers to buy them, but that isn’t the end of the OSHA AED requirements for workplaces. Two broader standards, the General Duty Clause and the first-aid rule at 29 CFR 1910.151, can require an AED in practice whenever sudden cardiac arrest is a foreseeable risk and a hospital isn’t close by. And once an employer installs one, federal and state obligations kick in around where it sits, how it’s maintained, and who is trained to use it.
The Two Standards That Do the Work
The General Duty Clause, Section 5(a)(1) of the OSH Act, requires every employer to keep the workplace “free from recognized hazards that are causing or are likely to cause death or serious physical harm.”1Occupational Safety and Health Administration. 29 U.S.C. 654 – Duties If cardiac arrest is a foreseeable risk given the work, and an AED is a feasible fix, failure to provide one can support a citation.2Occupational Safety and Health Administration. Elements Necessary for a Violation of the General Duty Clause
The first-aid standard, 29 CFR 1910.151, requires that “adequate first aid supplies shall be readily available” when no clinic or hospital is in near proximity to the workplace.3Occupational Safety and Health Administration. 29 CFR 1910.151 – Medical Services and First Aid The standard doesn’t list AEDs by name. The phrase “readily available” is where the pressure lives. OSHA has stated that for serious injuries like cardiac arrest, first-aid treatment must be provided within the first few minutes to prevent death.4Occupational Safety and Health Administration. OSHA Requirements for Providing Training for First Aid, CPR, and BBP for Prompt Treatment of Injured Employees at Various Workplaces Bandages and an ice pack don’t clear that bar when the nearest hospital is 20 minutes out.
OSHA also publishes Publication 3185, which actively encourages AED programs and provides setup resources.5Occupational Safety and Health Administration. Automated External Defibrillators (AEDs) – Overview Guidance isn’t a regulation, but it signals what the agency treats as a reasonable safety practice when it later judges whether an employer took reasonable steps.
Industries Where the Expectation Tightens
Several standards push specific industries closer to AED adoption without ever using the word.
The electric power standard, 29 CFR 1910.269, requires first-aid-trained personnel whenever employees work on or near equipment energized at 50 volts or more. At fixed locations like substations, a trained person must be able to reach any exposed employee within four minutes.6eCFR. 29 CFR 1910.269 – Electric Power Generation, Transmission, and Distribution “First-aid training” under the rule includes CPR and other heart and lung resuscitation techniques.
Logging operations under 29 CFR 1910.266 follow the same pattern. The mandatory training appendix requires instruction in cardiac arrest assessment and CPR for all logging employees.7Occupational Safety and Health Administration. 29 CFR 1910.266 – Logging Operations Logging sites are usually remote, which stretches the case for an on-site AED.
Construction sits under 29 CFR 1926.50, which requires “prompt medical attention” and stocked first-aid kits. OSHA has clarified that employers aren’t required to provide medical equipment beyond basic first-aid supplies, even if a worker on site has advanced medical training.8Occupational Safety and Health Administration. Emergency Medical Services on Construction Sites Whether attention counts as “prompt” turns on remoteness, crew size, and expected EMS travel time. A crew 30 minutes from the nearest hospital faces a very different calculation than a downtown site.
Why Response Time Drives Placement
Survival from sudden cardiac arrest drops 7 to 10 percent for every minute without CPR or defibrillation, and after roughly 10 minutes resuscitation rarely succeeds.5Occupational Safety and Health Administration. Automated External Defibrillators (AEDs) – Overview Average EMS response runs well past that first critical window. The American Heart Association recommends that any occupant be able to reach an AED on a three-minute round trip. That benchmark, not a formal OSHA rule, is what most safety planners use.
Three minutes gets tight fast in large or multi-story buildings. Elevator waits, locked stairwell doors, and long corridors all eat into it. High-rise buildings usually need units on multiple floors, near elevators, fitness rooms, large conference rooms, and front desks. A campus with several buildings should treat each building as its own response zone.
Where to Mount It
The device belongs in plain view, unobstructed by furniture, inventory, or decor. Hiding it in a supply closet or behind a reception counter defeats the purpose. High-traffic areas work best: cafeterias, main lobbies, break rooms, hallways near elevator banks. Locating AEDs near other emergency equipment like fire extinguishers builds predictable safety zones people find instinctively under stress.
Mounting height matters. Under ADA standards, wall-mounted operable equipment must sit within an unobstructed forward reach range of 15 to 48 inches from the floor so someone in a wheelchair can reach it.9United States Access Board. Chapter 3: Operable Parts If a counter or shelf creates a reach obstruction deeper than 20 inches, the maximum height drops to 44 inches. Cabinets in hallways also need to avoid becoming a protruding hazard for foot traffic.
Signage should carry the internationally recognized AED symbol, a green square with a white heart and lightning bolt drawn to ISO 7010. Size it to be readable from a distance in the actual lighting. Spelling out the full word “defibrillator” tends to reduce readability from far away; the letters “AED” or an arrow toward the device work better.
Maintenance Is Part of the Obligation
An AED that doesn’t work when someone needs it is worse than no AED at all, because it burns the minutes that matter. “Readily available” under 1910.151 covers function, not just presence.3Occupational Safety and Health Administration. 29 CFR 1910.151 – Medical Services and First Aid
A basic inspection routine covers three things. Check the status indicator, the light or display showing the device is ready, at least monthly. Track battery life; lithium batteries in most units last two to five years, but they can fail earlier if the device runs frequent self-tests or sits in extreme temperatures. Replace electrode pads on their printed expiration schedule, roughly every two years, and treat pediatric pads the same way.
Replacement batteries and electrode pads typically run between $89 and $624 depending on the model. Keeping spares on hand prevents coverage gaps during the replacement cycle.
Construction employers face a sharper cadence. Under 29 CFR 1926.50, first-aid kit contents must be checked before each job and at least weekly to replace expired or used items.10Occupational Safety and Health Administration. 29 CFR 1926.50 – Medical Services and First Aid Any AED folded into a construction first-aid program should ride the same weekly-check discipline.
An inspector who finds a non-functional or expired unit can cite under the General Duty Clause for failing to maintain a safety measure the employer voluntarily adopted. Dead batteries in the cabinet tell the inspector that the employer recognized the cardiac hazard, bought the device, and then didn’t follow through.
Training That Has to Travel With the Device
OSHA recommends but does not require that every workplace have one or more employees certified in first aid and CPR.4Occupational Safety and Health Administration. OSHA Requirements for Providing Training for First Aid, CPR, and BBP for Prompt Treatment of Injured Employees at Various Workplaces The recommendation becomes a mandate in two situations: when no hospital or clinic is close enough for prompt treatment, and when an industry-specific standard like 1910.269 or 1910.266 requires trained responders on site.
Employees designated as first-aid responders also need training under the Bloodborne Pathogens standard, 29 CFR 1910.1030, because responding to medical emergencies can involve exposure to blood and other infectious materials. Employers who buy an AED and assign someone to use it frequently miss this piece.
CPR and AED certification through the American Heart Association, American Red Cross, and similar organizations is valid for two years. Schedule renewals 60 to 90 days before expiration to avoid coverage gaps, especially when only a few employees hold the certification.
State Laws and Good Samaritan Protection
Federal OSHA sets a floor, not a ceiling. As of the most recent CDC survey, at least 37 states had laws requiring or authorizing AED placement in specific locations. Schools are the most common target, with 25 states mandating AEDs in educational settings. Health and fitness facilities follow, with 15 states. About 10 states require AEDs in state-owned or state-occupied buildings.11Centers for Disease Control and Prevention. Public Access Defibrillation (PAD) State Law Fact Sheet Some state laws also add registration, maintenance, and training obligations that go beyond anything federal OSHA demands. A few states require registration with local EMS. Others require a licensed physician to serve as medical director for the AED program.
On liability, most states and federal law provide Good Samaritan protection for a person who uses an AED in good faith on a cardiac arrest victim, generally shielding the rescuer from civil liability absent gross negligence or willful misconduct. For the employer who owns the device, the shield typically holds only if the AED was maintained according to the manufacturer’s guidelines. Letting batteries expire or ignoring a recall can void it.
Penalties for Falling Short
OSHA’s penalty structure applies to AED-related failures the same way it applies to any safety deficiency. For 2026, the maximum penalties remain at 2025 levels because the Department of Labor did not adjust civil money penalties under the Inflation Adjustment Act this year.12Federal Register. Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2026
- Serious violation: up to $16,550 per violation, where the employer knew or should have known about a hazard that could cause death or serious harm.
- Willful violation: up to $165,514 per violation, where the employer intentionally disregarded a known obligation or showed plain indifference to employee safety.
- Failure to abate: up to $16,550 per day beyond the deadline OSHA set for fixing a previously cited hazard.
The gap between a serious and a willful citation usually comes down to what the employer knew. An employer who never considered AEDs in a low-risk office faces a different enforcement posture than one who bought AEDs, let them all expire, and ignored complaints about it. The second scenario looks intentional, and OSHA prices it accordingly.