AED requirements from OSHA 1926

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]