Scenario: You are the safety manager at a heavy equipment manufacturing operation. Your facility has an Emergency Response Team (ERT) that responds to emergencies and provides onsite first aid treatment as well as acts as the rescue team for your Permit Required Confined Space Entry Program. You are in the process of upgrading the ERT equipment for your facility and want to acquire an Automatic External Defibrillator (AED) for the site. In justifying your purchase with management, you rationalize that since first aid and cardiopulmonary resuscitation training providers (i.e., American Red Cross, American Heart Association, etc.) are now including AED training as a component in their programs for emergency responders, then OSHA would require an AED be available due to the fact that responders have been trained and are qualified to use the equipment. Furthermore, the confined space standard identifies that one of the responders to a confined space rescue must be CPR qualified. Based on this, you feel there is now an implied requirement that the responder also be skilled at the higher level of CPR training that includes the use of an AED.
Question: Are you correct in your thought process?
Answer: In a letter of interpretation by OSHA on June 17, 2004 to Alfred W. Keiss, MS, CFPS, CHST, Operations Manager for Med-Tex Services, Inc., OSHA states:
“You requested clarification of OSHA’s position on the use of Automated External Defibrillators (AEDs) . . . although some institutions providing CPR training are including the skill of utilizing an AED as part of their program 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.
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.
A better approach with management may be to utilize the information supplied on the OSHA website that discusses AEDs in the Workplace. While OSHA doesn’t require them, they do highly recommend them to be available and employees be trained to utilize them during cardiac-related events.
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