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AED Compliance and Inspection: What US Law Actually Requires

AED Compliance and Inspection: What US Law Actually Requires

AED Compliance and Inspection in US Law, an AED guide from AED Brand Review
0Federal laws mandating an AED in a US workplace
14States with a gym or health club AED law
26States with a direct K-12 school AED mandate
46.9%Of AED failures are consumables
The short answer. There is no single federal law requiring an AED in a United States workplace. Compliance is built from four separate obligations that come from different places: acquire and register the device, maintain it on a documented schedule, train designated responders, and write the device into an emergency action plan. Which of the four are legally binding on you depends on your state and your facility type. This page is the map. Verified 12 September 2026.
What a compliant AED programme buys, with today's prices. Philips HeartStart OnSite M5066A: $1,589. Recertified OnSite: $875. Compact cabinet with alarm: $135.15. Wall sign: $44. OnSite pads M5071A: $99. Inspection tags, 5-pack: $29.71. Prices checked 4 Oct 2026 at AED Leader.
OnSite Value Package at AED Leader, $1,581.80

The four obligations, and where each one comes from

Obligation Where it comes from Binding on you? Our page
Acquire and place the device State statute for gyms, schools and some public buildings. Otherwise voluntary. Depends on state and facility type AED laws by state
Register with local EMS State or county requirement in many jurisdictions, so responders know the device exists Depends on jurisdiction AED registration with EMS
Maintain on a documented schedule Manufacturer instructions for use, plus state statute where one exists. OSHA expects a documented program where the hazard is recognised. Yes in practice, everywhere AED inspection checklist
Train designated responders State statute in several states. Illinois 210 ILCS 74/15 and New York GBL 627-a both require trained staff. Depends on state AED training requirements by state
Write it into an emergency action plan OSHA 29 CFR 1910.38 for employers who must have an EAP, and AHA guidance for schools Yes where an EAP is required Workplace emergency action plan

The federal picture, stated plainly

  • OSHA has no AED-specific standard. None of 29 CFR Parts 1910, 1915, 1917, 1918 or 1926 contains one. The enforcement hook is the General Duty Clause, 29 USC 654 5(a)(1), for recognised hazards not covered by a specific standard. Full detail on our OSHA AED requirements page.
  • 29 CFR 1910.151 and 1926.50 require the ready availability of medical personnel, or a person trained to render first aid where no infirmary is near. They do not name an AED.
  • OSHA guidance recommends AEDs for workplaces with 50 or more employees, or where EMS response exceeds five minutes. Recommendation, not regulation.
  • The HEARTS Act, December 2024, is an HHS grant programme for school AEDs. It is funding, not a mandate. Grant routes are on our AED grants page.
  • No FDA or AHA rule mandates replacing expired pads. The obligation comes from the manufacturer instructions for use and from your own documented programme. Anyone citing a federal pad-replacement rule is wrong.
  • AEDs are FDA approved through premarket approval, a PMA number. PMA is the only FDA route for an AED. A seller naming another pathway has it wrong, and that is a reliable signal about the rest of their information.

Where state law actually bites

Gyms and health clubs: 14 states. Arkansas, California, Connecticut, Illinois, Indiana, Louisiana, Massachusetts, Michigan, New Jersey, New York, Oregon, Pennsylvania, Rhode Island and Virginia. Vendor pages commonly claim 16 or 17; we could not verify those counts and do not publish them. Illinois 210 ILCS 74/15 and New York General Business Law 627-a, which applies at 50 or more members, both require trained staff on site, not just a device on a wall.

K-12 schools: 26 states by direct mandate, and 10 more through a required emergency plan, per our October 2026 check of state statutes. Detail by state on our K-12 school requirements page and fitness facility requirements page.

Good Samaritan protection is universal but conditional. All 50 states have a statute, and the conditions differ: acting in good faith, acting within your training, and not accepting payment are the common tests. Our 50-state Good Samaritan guide sets out the per-state wording.

The routine that satisfies almost every requirement

Regulators and plaintiff lawyers ask the same question after an incident: can you produce a record. The record is the programme.

  1. Monthly visual check of the status indicator, recorded and signed. Use our printable maintenance log template.
  2. Track two expiry dates per device, pads and battery, except HeartSine where the Pad-Pak combines both into one. Schedule by model on our pad replacement schedule.
  3. Check the recall status at least annually. Live tracker on our AED recall tracker.
  4. Re-certify responders on the cycle your state or your training provider requires.
  5. Review the plan annually and after any use. Template on our cardiac emergency response plan template.

What actually fails, and it is not the device

In the largest published analysis of FDA-reported AED events, 40,787 cases, batteries accounted for 23.2 per cent of failures and pads and connectors for 23.7 per cent. 46.9 per cent of all AED failures are consumables (DeLuca et al., Annals of Emergency Medicine, 2012, PMID 21872969). A compliance programme that tracks paperwork but not part expiry dates is protecting the wrong thing. Current part numbers and prices are on our pads and batteries page.

The timing argument is the reason any of this exists: sudden cardiac arrest kills more than 356,000 people a year outside hospital in the United States, and survival falls roughly 10 per cent for every minute without defibrillation (American Heart Association). The AHA standard for schools is a three minute retrieve-and-deliver round trip, and survival is 74 per cent when the shock lands inside three minutes.

Your compliance stack

If you need to Read this
Know what your state requires AED laws by state
Run the monthly check AED inspection checklist
Document it AED maintenance log template
Satisfy an employer audit Workplace AED compliance checklist
Understand OSHA exposure OSHA AED requirements
Register the device AED registration with EMS
Train your responders AED training requirements by state
Mount it legally Mounting heights, cabinets and signage
Place it correctly in a school AED placement for schools
Run more than one site Multi-site AED fleet management
Build the annual programme AED program management
Set up a public access programme Public access defibrillation programme
Understand your liability Good Samaritan laws and AED use
Budget the running cost Battery replacement cost by brand
Dispose of an old battery AED battery disposal
Buy the right device in the first place Every AED brand ranked by price and ten year cost

Every statute count on this page is one we verified against the statute or a named review. Where a figure is commonly published but we could not verify it, we say so rather than repeating it. Last verified 12 September 2026.

Is an AED legally required in a US workplace?

No federal law requires one. There is no OSHA standard naming AEDs. Requirements come from state law, and they attach to facility types rather than to employers generally: 14 states regulate gyms and health clubs, and 26 states require AEDs in K-12 schools by direct mandate, with 10 more requiring them through an emergency response plan. OSHA guidance recommends an AED where there are 50 or more employees or EMS response exceeds five minutes, which is a recommendation, not a regulation.

How often does an AED need to be inspected?

Monthly visual inspection of the status indicator is the standard expectation, recorded and signed. The legal source is the manufacturer instructions for use plus state statute where one exists, not a single federal rule. The record matters as much as the check, because after an incident the question is whether you can produce one.

Do I have to replace AED pads when they expire?

No FDA or American Heart Association rule mandates it. The obligation comes from the manufacturer instructions for use and from your own documented maintenance programme. It is also the practical answer: 46.9 per cent of reported AED failures are consumables, batteries at 23.2 per cent and pads and connectors at 23.7 per cent, across 40,787 FDA-reported events.

Which states require AEDs in gyms?

Fourteen: Arkansas, California, Connecticut, Illinois, Indiana, Louisiana, Massachusetts, Michigan, New Jersey, New York, Oregon, Pennsylvania, Rhode Island and Virginia. Illinois and New York also require trained staff on site. Counts of 16 or 17 circulate on vendor sites and we could not verify them.

Does the HEARTS Act require schools to have AEDs?

No. The HEARTS Act, passed December 2024, is a Health and Human Services grant programme for school AEDs. It is funding, not a mandate.

Are AEDs FDA approved or FDA approved?

Approved. Every AED sold in the United States goes through premarket approval and carries a PMA number, for example P160029 for the Philips HeartStart OnSite and P160015 for ZOLL. PMA is the only FDA route for an AED. A seller naming another pathway has the regulatory basis wrong.

This page is a plain-language summary of published law and guidance, not legal advice. Verify your own obligations against your state statute.

Picture of ayaan
ayaan
In the last 27 years, I have worked as a first responder. For 20 of those years, I focused on instruction and training. I’ve collaborated with teams in nonprofits, businesses, government, healthcare, and aquatic fields. I help them improve their readiness for many emergency situations. I have helped organizations adopt effective emergency response strategies. I’ve combined hands-on experience with practical education. This lets me use lifesaving tools, such as automated defibrillators, in daily operations.
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Philips HeartStart FRx AED 861304
Philips HeartStart FRx Review: Specs, Pediatric Key and Price
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Replacing your AED pads or battery

AED pads and batteries expire on a fixed schedule whether the device is ever used or not, and they are the single most common reason an AED fails when it is needed. In the largest published analysis of FDA-reported AED events, 40,787 cases, batteries accounted for 23.2 per cent of failures and pads and connectors for 23.7 per cent, so 46.9 per cent of all AED failures are consumables (DeLuca et al., Annals of Emergency Medicine, 2012, PMID 21872969). Below is every current replacement part with its price and service life, verified against seller product data on 12 September 2026.

ModelAdult padsBatteryPediatric option10 year consumable cost
Philips HeartStart OnSiteM5071A $99.00, 2 yearsM5070A $249.00, 4 yearsSeparate M5072A cartridge, prescription onlyAbout $894
Philips HeartStart FRxSMART Pads II 989803139261 $89.00, 2 yearsM5070A $249.00, 4 yearsInfant/Child Key $139.00, reusableAbout $854
ZOLL AED PlusCPR-D Padz 8900-0800-01 $230.00, 5 yearsLithium set of 10 $100.00, 5 yearsPedi-padz II $155.00, 2 yearsAbout $330, the lowest we track
ZOLL AED 3CPR Uni-padz 8900-000280-01 $234.00, 5 years8000-000696 $201.00, 5 yearsNone needed, Uni-padz cover childrenAbout $435
Defibtech LifelineDDP-100 $75.15DBP-1400, part DCF-200 $229.10DDP-200P $130.25About $530
Defibtech Lifeline VIEWDDP-2001 $83.05DCF-2003 $240.45DDP-2002 $136.40About $813
HeartSine Samaritan PADPad-Pak-01 $236.00, pads and battery in one cartridgeIncluded in the Pad-Pak, there is no separate batteryPediatric Pad-Pak PAD-PAK-02 $279.00About $472
Cardiac Science Powerheart G5XELAED001C $88.00XBTAED001A $495.00, 4 yearsXELAED003C $127.00About $1,342, the highest we track
Physio-Control LIFEPAK CR2Quik-Step 11101-000021 $196.00, adult and child in one setLIFEPAK CR2 lithium battery $341.00, about 4 yearsNone needed, the Quik-Step set covers childrenNot published per part

Prices verified against the public product data of AED Leader on 30 September 2026. Service life is the manufacturer figure where one is published; where it is not, check the expiry date printed on the part itself. Ten year consumable cost is our own calculation from those part prices and service lives.

Three things owners get wrong

  • Buying the wrong Philips pad. The FRx uses SMART Pads II, part 989803139261. SMART Pads III belong to the FR3, a different device. The OnSite uses M5071A and the two are not interchangeable.
  • Assuming the pediatric part is optional. On a ZOLL AED Plus, Pedi-padz II cost $155.00 and last two years, which is about $775 across a ten year life. On a ZOLL AED 3 or a LIFEPAK CR2 the pads already cover children and that cost is zero.
  • Tracking the wrong date. HeartSine combines the pads and battery into one Pad-Pak cartridge, so there is a single expiry to track. Every other model here has two parts on two separate clocks.

Full replacement schedule by model is on our AED pads and batteries page. If you are still choosing a device, the ten year running cost is usually a bigger number than the discount you are negotiating: see every AED brand ranked by price and ten year cost.

Recertified prices across all seven models

Recertified units are the same models under the same FDA premarket approvals, restored, tested and sold with a minimum three year warranty.

ModelNewRecertifiedYou keepBuy
Philips HeartStart OnSite$1,589$875$714 (45%)AED Leader or Response Ready
Philips HeartStart FRx$2,099$875$1,224 (58%)AED Leader or Response Ready
ZOLL AED Plus$2,082$875$1,207 (58%)AED Leader or Response Ready
ZOLL AED 3$2,399$1,150$1,249 (52%)AED Leader or Response Ready
HeartSine Samaritan PAD 350P$1,411$875$536 (38%)AED Leader or Response Ready
HeartSine Samaritan PAD 450P$1,761$875$886 (50%)AED Leader or Response Ready
Cardiac Science Powerheart G5$2,157$1,225$932 (43%)AED Leader or Response Ready

Prices verified 30 September 2026 against the public product data of both stores. Both list identical recertified prices, so buy from whichever fits your order size: AED Leader for one to four units, Response Ready for five or more and for compliance and fleet programmes. New prices are the AED Leader list price on the same date.

The honest risk. A recertified AED is a used device. The three year minimum warranty is what makes the saving worth taking. Read recertified versus new and how to choose a refurbished AED before you decide.

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