The short answer: OSHA recommends AEDs but does not require them
Are AEDs required in the workplace? Not by OSHA. No OSHA standard tells employers to buy or place an AED; OSHA’s own AED page says its standards “do not specifically address automated external defibrillators (AEDs).”
What OSHA does require is first aid. Under 29 CFR 1910.151, employers must make medical personnel available for advice and, when there’s no clinic or hospital “in near proximity to the workplace,” have one or more people “adequately trained to render first aid,” with “adequate first aid supplies.” OSHA has read near proximity to mean care within three to four minutes where serious injuries such as cardiac arrest could happen.
An AED isn’t part of that duty. Asked directly in 2004, OSHA answered that the standard “does not specifically require that AEDs be included in first aid supplies.” So an AED is a choice for most employers, and one OSHA actively encourages: its publication 3185 urges employers to install them, and OSHA’s AED page notes that the chance of surviving sudden cardiac arrest drops 7 to 10 percent for every minute without CPR or defibrillation.
A few federal rules outside OSHA do name AEDs. Airlines must carry one on airplanes that need a flight attendant and can carry more than 7,500 pounds of payload (14 CFR 121.803). Federal buildings follow GSA and HHS guidelines for public access defibrillation, which are voluntary. Most AED requirements come from the states.
When state law does require an AED at work
When your state’s law names your kind of workplace. Health clubs are the most common: 15 states require AEDs in gyms or fitness facilities, and other laws name places such as nursing homes, public pools, large venues and certain worksites.
These are the places outside schools where a state law in our data requires an AED, with the conditions the law sets:
| State | Where an AED is required |
|---|---|
| Alabama | Dialysis and transplant centers; Birthing centers; Dental offices that give oral conscious sedation |
| Arizona | State buildings that are new or get a major renovation (renovations of $250,000 or more) |
| Arkansas | Health spas, including gyms, YMCA-type groups, martial arts schools and country clubs (with a trained employee on duty during staffed hours); County and city jails (under the state’s detention facility standards) |
| California | Health studios (membership gyms) (hotel gyms for guests are exempt); Occupied buildings built or renovated since 2017 above set occupancy levels (300+ for assembly, 200+ for business, school, factory, store and other uses); Public swimming pools that charge a fee and must have lifeguards; Commuter rail trains (intercity, light rail and rapid transit trains are excluded); Electric utility work sites on lines of 601 volts or more (with two or more line workers; since January 1, 2026) |
| Connecticut | Public golf courses (nine holes or more); Licensed health clubs (since October 1, 2022); Nursing homes and managed residential communities (by January 1, 2026) |
| District of Columbia | Each Department of Parks and Recreation facility regularly staffed by a paid District employee (At least one AED on site, with a trained person present during operating hours; new facilities are added within 45 days of opening.); All public and semi-public swimming pools (The AED must be on the deck near the pool's edge or inside the facility in a room that cannot be locked.) |
| Florida | Assisted living facilities licensed for 17 or more beds |
| Illinois | Physical fitness facilities, such as health clubs and gyms (serving 100 or more people; hospital and hotel gyms and some park sites are exempt); County sheriff's offices (with enough staff trained to use it); Municipal police departments with 100 or more officers (departments with 100 or more officers); Horse racing facilities (organization licensees) (at least two while backstretch workers are present); Nursing homes licensed under the Nursing Home Care Act (by January 1, 2030); Dental offices that give anesthesia or sedation (offices that give anesthesia or sedation) |
| Indiana | Health clubs, including gyms in schools and colleges (with 50 or more paying users or 30 or more motorized machines); Juvenile detention facilities (in areas the facility designates, inspected monthly) |
| Iowa | Dental offices that give moderate or deep sedation or general anesthesia (the rule calls for a defibrillator) |
| Louisiana | Physical fitness facilities, including clubs, studios, health spas, YMCAs and YWCAs (with more than 50 members) |
| Maryland | County and city swimming pools (with an AED-certified person on site while open); Large grocery stores (over $10 million a year in sales and other size tests; since January 1, 2025); Restaurants with 100 or more seats (and over $1 million a year in sales; since January 1, 2025); County public library branches (since January 1, 2026) |
| Massachusetts | Every health club, including gyms, spas and studios (with a trained AED provider on hand during staffed hours) |
| Michigan | Health clubs (fitness centers, studios and clubs) (hotel gyms, single-sport training sites and weight-loss centers are exempt) |
| Mississippi | Licensed casinos (gaming establishments) (each casino decides how many AEDs and where) |
| Missouri | Basic life support ambulances and stretcher vans (staffed by at least one person trained to use the AED) |
| Nevada | The largest airport in Washoe County, through the Reno-Tahoe Airport Authority (at least three AEDs); The largest airport in each county of 700,000 or more people (at least seven AEDs) (Duty of the board of county commissioners; applies in counties of 700,000 or more.); The Capitol Building and Legislative Building in Carson City and the Grant Sawyer Building in Las Vegas (at least one AED each) (Duty of the Division of Public and Behavioral Health.); Five high-traffic county buildings or offices chosen by each county of 100,000 or more people (at least one AED each) (Applies in counties of 100,000 or more; the county commission picks the five buildings.); Every freestanding birthing center |
| New Jersey | Health clubs registered with the Division of Consumer Affairs; Licensed nursing homes; Licensed assisted living facilities; Swimming pools at public recreational bathing facilities (Only pools that have a lifeguard.); Public bathing beaches (Beaches that can hold 500 swimmers and bathers, or any beach with a lifeguard present.) |
| New York | Health clubs (with 50 or more members); Places of public assembly such as stadiums, arenas, theaters and concert halls (holding 1,000 or more people; religious groups and free libraries are exempt); State public buildings (on the state’s phase-in schedule); Trampoline parks (during all open hours); Ocean surf beaches (with an AED-certified staff member present) |
| Oregon | Health clubs with 50 or more people on a typical day (hotel-owned facilities are exempt); Buildings of 50,000 square feet or more where the public gathers or business is done (with 50 or more people there on a normal business day); Resident camps (overnight camps; day camps are not included); Public pools (all general-use pools, and health club pools with 100 or more patrons a day) |
| Pennsylvania | Health clubs that open without staff (in the member-access area); Assisted living residences (each building on the premises) (One AED in each building. An AED in residence vehicles is optional.); Underground coal mines (at the entry and in each working section) |
| Rhode Island | Public places that hold 300 or more people, such as stores, restaurants, banks, arenas and transit facilities (with at least one trained person); Licensed healthcare facilities such as hospitals, clinics, surgery centers and hospices (since September 1, 2024, with a trained person); Nursing facilities (since September 1, 2024, with a trained person); Physician, dentist and other practitioner offices (since September 1, 2024, with a trained person); Health clubs registered with the Attorney General (with a trained employee on each shift) |
| South Dakota | Dental offices that give moderate sedation (an AED or full defibrillator within reach); Dental offices that give deep sedation or general anesthesia (an AED or full defibrillator within reach) |
| Tennessee | Dental offices that give conscious or deep sedation or general anesthesia (an AED or other defibrillator) |
| Texas | Convalescent and nursing facilities licensed under Health & Safety Code ch. 242; Public swimming pools (where lifeguards are required or provided); Artificial swimming lagoons (where lifeguards are required) |
| Utah | Trampoline parks, during all hours of operation |
| Virginia | Every health club location (nonprofits such as the YMCA, member-owned clubs and some others are exempt); Assisted living facilities (with staff trained to use it); Nursing homes and certified nursing facilities (with staff trained to use it); Local government sports facilities (from July 1, 2028, with more AEDs for larger sites); Sporting events a locality organizes or sponsors (from July 1, 2028); Dental offices that give moderate or deep sedation or general anesthesia (a defibrillator is required) |
| Washington | Fitness centers that sell memberships (since June 6, 2024; schools, colleges and some nonprofits are exempt); High-voltage line work sites (when two or more employees work on or near the lines; since January 1, 2025); Dental offices that give any anesthetic (an AED or manual defibrillator within reach in 60 seconds) |
| West Virginia | Underground coal mines (one AED with each required first aid station); Surface mining operations (stored in a climate-controlled place, with personnel trained); Quarries (with the required first aid equipment); Dental offices that give class 2, 3 or 4 sedation |
Even where no law requires an AED, your state’s AED law usually applies once you own one: 34 states require AEDs to be kept inspected and maintained, 27 require you to tell an agency such as local EMS that you have one, and nine require medical direction. See AED laws by state for yours, and AEDs in schools by state for school rules.
What OSHA expects if you have an AED
OSHA has no AED-specific rules, but its guidance points one way: put AEDs where they can be reached in three to five minutes, keep them maintained, train the people expected to use them, and plan the response.
OSHA’s best-practices guide for first-aid programs (publication 3317) says all worksites are potential candidates for an AED program and lists what a good one includes: physician oversight, compliance with local, state and federal rules, coordination with local EMS, quality assurance and regular review. OSHA 3185 gives placement examples: crowded work areas, confined spaces, electrical work, outdoor sites with lightning risk, fitness areas and cafeterias, and remote sites.
The one place OSHA’s regulations describe an AED program is a non-mandatory appendix to its shipyard first-aid standard (Appendix A to 29 CFR 1915.87). It suggests placing AEDs so they can be used within three to five minutes, inspecting, testing and maintaining them to the manufacturer’s instructions, and designating and training the people who will use them. It isn’t binding, but it’s a fair summary of what an inspector or insurer would expect to see.
OSHA doesn’t set how often first-aid training must be refreshed. Most CPR and AED cards are valid for two years, so plan renewals before they lapse. See how long CPR and AED certification lasts and where to place AEDs.
Where an OSHA standard requires an emergency action plan (29 CFR 1910.38), that plan must cover the employees who have rescue and medical duties, which is a natural place to list your trained AED responders and where the AEDs are. Our free emergency action plan template follows the standard’s required elements.
Keeping AED inspection records
Keep a dated record of every inspection, every pad and battery change, every responder’s training and every use. Many state laws require the inspection and maintenance behind those records, and the federal immunity for AED owners depends on it.
The federal Cardiac Arrest Survival Act (42 U.S.C. 238q) protects someone who uses an AED on a person in an apparent cardiac emergency from civil liability, unless the harm came from gross negligence or willful misconduct, where state law gives no protection of its own. It protects the AED’s owner only if a harm wasn’t caused by a failure to tell local emergency responders where the AED is, to properly maintain and test it, or to train an employee who was expected to use it. A dated log is how you show you did those things.
A useful record answers who checked which AED, when, what they found and what they did about it: the status indicator, the pads’ and battery’s expiration dates, the cabinet and any alarm, the rescue kit and the sign. Our free AED inspection checklist and AED inspection log sheet are printable versions, and the AED inspection requirements guide explains what each manufacturer asks for.
AED Log keeps the record for you: each inspection is done on a phone and saved with the date and inspector, pads and batteries warn you before they expire, responders’ cards are tracked, and every use gets an incident report. See AED programs for workplaces and manufacturing and construction.
OSHA AED requirements FAQ
Does OSHA require AEDs in the workplace?
No. OSHA standards don't specifically address AEDs, but OSHA encourages employers to install them, and some states require AEDs in certain workplaces. See our OSHA AED requirements page.
What does 29 CFR 1910.151 require?
It requires employers to have medical personnel available for advice and, when no clinic or hospital is close by, people trained in first aid and adequate first aid supplies. OSHA has said it doesn’t require an AED among those supplies.
Which workplaces must have an AED?
Only the ones your state’s law names. The AED law data in AED Log lists 15 states that require AEDs in health clubs, and some laws name places such as nursing homes, pools or large venues. OSHA itself requires none.
Is there a federal Good Samaritan law for AEDs?
Yes. The Cardiac Arrest Survival Act (42 U.S.C. 238q) protects people who use an AED, and owners that maintained it, told local responders where it is and trained expected users, but only where a state has no AED immunity law of its own.
Is AED Log approved by OSHA?
No. OSHA doesn't approve or certify software. AED Log keeps the dated inspection, maintenance and training records that a safety auditor or insurer asks to see.