The hardest part of AED compliance isn’t installing the device — it’s maintaining the documentation that proves the device was installed and maintained properly. State auditors, OSHA compliance officers, insurance underwriters, and plaintiffs’ attorneys all ask the same question after a workplace cardiac event: Where are the records? Without a written program and a paper trail of inspections, training, and consumable replacement, even a perfectly maintained AED can fail the legal “documented” standard.
This checklist solves that. It’s a 47-point framework covering everything from initial device placement to annual program review — organized by cadence (monthly, quarterly, annual) so it integrates cleanly with existing facilities and HR workflows. A printable PDF version is available for download below.
The five domains of workplace AED compliance
Every documented AED program covers five distinct domains. The 47 tasks below are organized across these.
| Domain | Tasks | Typical responsible role |
|---|---|---|
| 1. Device placement | 8 tasks | Facilities manager + EHS |
| 2. Training | 10 tasks | HR + safety officer |
| 3. Maintenance | 14 tasks | Facilities maintenance |
| 4. Registration & legal | 7 tasks | Risk/compliance/counsel |
| 5. Documentation & review | 8 tasks | EHS + HR |
The 47-point compliance checklist
Domain 1 — Device Placement (8 tasks)
- ☐ Workplace EMS response time documented (verify under or over 5 minutes)
- ☐ Device count determined via 3-minute rule modeling (use Quantity Calculator)
- ☐ AED purchased with a manufacturer-issued physician prescription
- ☐ Pediatric pads stocked if the facility serves children, families, or visitors with children
- ☐ Wall cabinet mounted with handle 48–54″ above finished floor (ADA-compliant)
- ☐ ISO 7010 E010 signage installed directly above the cabinet
- ☐ Perpendicular “flag” sign visible from down the corridor
- ☐ Wayfinding signs placed at decision points within 50 ft of the cabinet
Domain 2 — Training (10 tasks)
- ☐ At least 2 staff CPR/AED-certified per shift
- ☐ Initial training documented (course, provider, date, certification number)
- ☐ Annual recertification scheduled on shared calendar
- ☐ Training provider is AHA Heartsaver, Red Cross, ASHI, NSC, or equivalent
- ☐ Training records retained for a minimum of 3 years
- ☐ New-employee training built into onboarding for designated responder roles
- ☐ Annual table-top emergency drill conducted
- ☐ Written Cardiac Emergency Response Plan (CERP) on file
- ☐ CERP includes responder names, AED locations, and 911 protocol
- ☐ CERP is reviewed and updated annually
Domain 3 — Maintenance (14 tasks)
- ☐ Daily self-test indicator visible from passing traffic (green = ready)
- ☐ Designated person walks past the AED daily for a visual readiness check
- ☐ Monthly written inspection log signed by designated maintainer
- ☐ Inspection log includes: status indicator color, pad expiration, battery indicator, cabinet integrity
- ☐ Pads replaced on or before manufacturer’s expiration date
- ☐ Battery replaced on or before the manufacturer’s install-by date
- ☐ Pad/battery replacement dates calendared 90 days in advance
- ☐ Replacement pads sourced from manufacturer-authorized reseller only
- ☐ Replacement battery sourced from manufacturer-authorized reseller only
- ☐ Cabinet alarm battery (9V) replaced annually
- ☐ Signage replaced if faded or damaged (every 5–7 years)
- ☐ Heated outdoor cabinet (where applicable) verified operational each winter
- ☐ Used pads and battery disposed of via EPA-compliant recycling channel
- ☐ Used AED (if deployed in an event), re-inspected, and pads replaced before re-mounting
Domain 4 — Registration & Legal (7 tasks)
- ☐ AED registered with the state Department of Health or local EMS
- ☐ Registration confirmation email retained in program file
- ☐ State renewal calendared (annual/biennial per state)
- ☐ AED registered on PulsePoint AED Registry
- ☐ State law requirements verified for facility type (use AED Laws by State)
- ☐ Insurance broker notified; premium credit applied where available
- ☐ Facility floor plan with AED locations on file for inspections
Domain 5 — Documentation & Review (8 tasks)
- ☐ Written AED program included in safety/HR manual
- ☐ Designated AED program owner identified by name and role
- ☐ Backup program owner identified
- ☐ Annual program review meeting scheduled (EHS + HR + facilities)
- ☐ Post-deployment incident report template on file
- ☐ Maintenance log retained for a minimum of 3 years (longer in some states)
- ☐ Training records retained for a minimum of 3 years
- ☐ Annual self-audit performed using this checklist
Recommended cadence
| Cadence | Tasks |
|---|---|
| Daily | Visual status check (1 minute) |
| Monthly | Written inspection log signed |
| Quarterly | Verify upcoming pad/battery expirations; check signage integrity |
| Annual | Staff recertification · CERP review · program self-audit · insurance broker review |
| Per-event | Post-deployment report; pad replacement before re-mounting |
What auditors look for first
Whether the inspector is a state DPH auditor, OSHA compliance officer, insurance underwriter, or plaintiff’s expert witness, they all start with the same documents:
- Written AED program/policy
- Inspection log (most recent 12 months)
- Training records (current certifications)
- Registration confirmation
- Pad/battery replacement receipts
- Post-deployment incident reports (if any)
Make these six documents quickly accessible — in a labeled binder or a single shared-drive folder. A program that exists but isn’t documented is a program that fails inspection.
Common audit findings
✓ Strong programs typically show
- Up-to-date monthly inspection log
- Current CPR/AED certifications on file
- Registration confirmation with annual renewal
- Pre-purchased replacement pads/battery before expiration
- Documented annual program review
✗ Weak programs typically show
- No written program at all
- Inspection log “started 3 months ago” or sporadic
- Expired certifications or no training records
- Registration lapsed or was never completed
- Pads expired; no replacement scheduled
- No designated program owner
The 5-minute weekly habit that keeps you compliant
Every Friday: designated AED program owner walks past each AED, photographs the status indicator, and texts the photo to a shared channel. Photo timestamps create a defensible visual log. Combine with a monthly written inspection, and you have layered, audit-grade documentation.
Frequently Asked Questions
What documents do I need for an AED compliance audit?
Six core documents: written AED program, inspection log (most recent 12 months), training records, registration confirmation, pad/battery replacement receipts, and post-deployment incident reports (if any).
How often should I inspect my AED?
Daily visual status check (1 minute), monthly written inspection log, quarterly review of upcoming expirations, and annual full program audit. Documented inspection is the single most-cited audit finding.
How long do I need to keep AED records?
Most states require a minimum of 3-year retention of inspection logs and training records. Some states require 5–7 years for incident reports. Best practice: retain indefinitely in a shared-drive folder.
Who should own the AED program in my workplace?
A designated EHS, safety officer, HR manager, or facilities manager — by name, with a documented backup. Programs without a named owner consistently fail audits and lapse on consumable replacement.
What’s the most common AED compliance gap?
Expired pads and/or batteries — typically because no one calendared replacement 90 days in advance. The fix: at install, set a recurring reminder for 60 days before each expiration.
Do I need to keep records for AEDs I no longer use?
Yes — retain decommissioned-AED records for the standard retention period (3+ years in most states). Document the decommission date, disposal method (return-to-manufacturer or certified e-waste), and any deployment that occurred during service.
Can I just use my AED manufacturer’s maintenance reminder system?
Manufacturer reminders cover pads and battery replacement, but don’t address training records, registration renewals, CERP updates, or audit-ready documentation. Use manufacturer reminders as one layer; this checklist as the program layer.
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Sources & References
Disclaimer: This checklist is a general framework. State and industry-specific requirements vary. Consult your safety counsel and the state Department of Health for jurisdiction-specific compliance certification.
