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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 http://www.osha.gov.
June 17, 2004
Alfred W. Keiss, MS, CFPS, CHST
Med-Tex Services, Inc.
Post Office Box 240
Penns Park, Pennsylvania 18943
Dear Mr. Keiss:
Thank you for your April 30, 2002 letter to the Occupational Safety and Health Administration's (OSHA's) Directorate of Enforcement Programs (DEP). This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any situation not delineated within your original correspondence. You requested clarification of OSHA's position on the use of Automated External Defibrillators (AEDs). We apologize for the delay in responding to your request.
Background: Institutions providing cardiopulmonary resuscitation (CPR) training (American Red Cross, American Heart Association, etc.) have now included the skill of utilizing an AED as part of their programs for emergency responders.
Question 1: The confined space standard identifies that one of the responders to a confined space rescue must be CPR qualified. Is there now an implied requirement that the responder also be skilled at the higher level of CPR training that includes the use of an AED?
Reply: Although some institutions providing CPR training are including the skill of utilizing an AED as part of their programs for emergency responders, the Permit-Required Confined Space standard (29 CFR 1910.146) is worded in terms of "basic first aid and CPR" training and does not include specific mention of AEDs. At the current time, the terms are not commonly understood to include training in the use of AEDs.
Question 2: Would this AED skill requirement also extend to the medical qualification identified in the medical and first aid skill requirements when onsite care providers are necessary? Would this also require that an AED be a part of the adequate first aid supplies that need to be readily available?
Reply: The Medical Services and First Aid Standard, 29 CFR 1910.151, requires that a person or persons should be adequately trained to render first aid. Adequate first aid supplies shall be readily available. The standard does not specifically require that AEDs be included in first aid supplies. The adequacy of first aid supplies and training can vary widely, depending on the type of employment and workplace conditions. It is the responsibility of the employer to make an assessment of the workplace and all first aid needs for expected injuries and illnesses.
In light of the increased availability of AEDs for use in public and private facilities, workplaces, and homes, OSHA plans to add AED training in the near future in the form of a "best-practices guideline." For further information, refer to OSHA's Technical Information Bulletin, "Cardiac Arrest and Automated External Defibrillators (AEDs)".
Thank you for your interest in occupational safety and health. We hope you find this information helpful. 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. To keep apprised of such developments, you can 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.
Richard E. Fairfax, Director
Directorate of Enforcement Programs