In 2001, the Department of Health and Human Services (HHS) and the General Services Administration (GSA) of the United States developed guidelines for the design of public access defibrillation programs in federal buildings, based on recommendations from the American Heart Association (AHA) and the American Red Cross (ARC).
While having a PAD program is not mandatory in federal buildings and the cost won’t be covered by the HHS or GSA, AED training and widespread public access to automated external defibrillators are key elements in saving a life in the event of cardiac arrest.
The person responsible for the public access defibrillation program in a federal building is the Designated Official specified in the facility’s Occupant Emergency Plan (see 41 CFR 102-71.20). This person will either be the highest-ranking official of the Federal facility’s primary occupant agency or a designee that occupant agency officials select by mutual agreement.
A public access defibrillation program in a federal building needs ongoing medical oversight from the very beginning of the program to event review and beyond. The physician can be an employee of the facility or can be contracted externally from a federal agency such as Federal Occupational Health.
The supervising physician will:
- Provide the prescription for each AED
- Oversee policy development
- Oversee training courses
- Review the AED’s data after each event
- Review the team’s response after each event
One of the most important AED requirements in federal buildings is regular CPR and AED training, as training in the signs of sudden cardiac arrest helps more employees recognize the signs of sudden cardiac arrest and shortens response times.
Appropriate training courses for federal agencies should:
- Be nationally recognized
- Follow guidelines from the American Heart Association, American Red Cross, and the National Safety Council
- Cover cardiopulmonary resuscitation, AED usage, and ideally, bloodborne pathogens
- Emphasize the importance of activating local emergency medical systems and transferring the patient’s care to emergency medical services (EMS) as soon as possible
In-House AED Training
If the facility is large enough, the HHS and GSA recommend conducting in-house training sessions according to a regular schedule (at least every two years). This training would ideally be conducted in groups to foster a sense of greater responsibility and include specific training on the AED model that the facility owns as well as the facility’s PAD program and policies.
Federal Facilities that Cater to Children
For federal buildings such as daycare centers where children are likely to be present, AED training should cover pediatric CPR as well as adult CPR. The AED model should likewise cater to children—for example, the Philips HeartStart FRx which has an infant/child key, or the HeartSine Samaritan PAD 350P, which can be purchased with separate pediatric pads.
Mock Drills and Refresher Sessions
To make AED training more effective, AED requirements in federal buildings include conducting mock drills at least annually and refresher sessions every six months. The supervising physician should review the results of any mock drills and identify improvements that need to be made.
All automated external defibrillators that are selected for federal buildings must be FDA-compliant and consistent with current AHA Guidelines for CPR and Emergency Cardiac Care in terms of:
- The audio and visual commands of the device
- The electrocardiographic analysis
- The defibrillation algorithms
The AED chosen should be advantageous for the location where it is used. For example, the HeartSine Samaritan PAD 350P, HeartSine Samaritan PAD 360P, and HeartSine Samaritan PAD 450P work well on a military base due to these models’ rugged construction. Using the same brand of AED in each federal facility is recommended to streamline training, AED maintenance, and data management.
AED requirements in federal buildings state that each automated external defibrillator should be placed:
- At a height that can easily be reached by short individuals
- In a location that is unobstructed
- In a secure location that doesn’t make the AED vulnerable to theft or tampering
- In a location that is clearly marked and known by trained staff
- Close to a telephone that can be used to call security, backup, emergency medical services, and/or 9-1-1 to ensure a quick high-level response to cardiac arrest victims
If possible, an automatic notification system should be installed that alerts the building’s security personnel and emergency medical services whenever an AED cabinet is opened or an automated external defibrillator is removed from a cabinet.
AED requirements in federal buildings recommend keeping a small bag of accessories with each automated external defibrillator. This bag should include:
- A simplified set of instructions for CPR and AED use
- Latex-free protective gloves in different sizes
- A CPR face shield with a one-way valve
- A razor for removing excess chest hair
- A sterile gauze for wiping or drying the areas where electrode pads are to be placed
- A pair of medium blunt/end scissors (such as those used to cut bandages)
- A notepad and pen
- Two plastic medical waste or biohazard bags
- A spare AED battery and set of electrode pads
While not listed as a requirement, a pair of pediatric electrode pads should also be kept with the device if the model (such as the HeartSine Samaritan PAD series AEDs) requires these to deliver a pediatric shock.
AED Maintenance and Testing
Automated external defibrillators in federal buildings should be maintained “on a regular basis and after each use.” As AEDs are not considered building equipment, they are not maintained by GSA and AED testing requirements remain the responsibility of each individual facility.
The other AED requirements in federal buildings cover aspects of PAD program design as a whole. The team responsible should:
- Establish partnerships between federal officers and employees, local training providers, and local emergency medical systems.
- Consult with all of the relevant stakeholders (including employees) when developing the Occupancy Emergency Program.
- Develop standard operational protocols (SOPs) for the use of an AED.
- Seek legal advice to make sure the PAD program complies with all local and state laws about AED certification requirements for owners in addition to federal laws such as the Cardiac Arrest Survival Act of 2000 (Subtitle A of Title IV of the Public Health Improvement Act, Public Law 106-505).
- Seek legal advice on the civil liability of federal employees who respond to an emergency in relation to state Good Samaritan laws and the Federal Tort Claims Act. The facility may delegate this responsibility to contractors who are not federal employees if this is preferable from a legal standpoint.
- Integrate the PAD program and external defibrillators with security and EMS for an immediate medical response to cardiac arrests.
- Plan for post-event reviews and psychological support for those who witness and respond to cardiac arrest events.
- Conduct regular protocol reviews and update the protocols and policies to reflect the latest technology, research, and guidelines.
If you are responsible for the PAD program in a federal facility, AED program management can help you ensure that each AED conforms to federal guidelines and that all AED certification requirements are met.
While program management varies across providers, they usually include reminders for batteries and electrode pads that are about to expire, post-event device refurbishing, data management, support, and assistance with arranging in-house CPR and AED training at the required frequency.
AEDs in Federal Buildings Can Save a Life
AED requirements in federal buildings are very involved and take time to review in detail. However, in most cases, they are similar to many state-based AED laws. Following all of the relevant requirements when developing a public access defibrillation program increases the chances that people who experience cardiac arrest can be connected with life-saving medical equipment in three to five minutes or less.
Taking the guidelines provided, each federal government facility will need to translate the guidelines into site-based policies and protocols that meet their facility’s particular needs. Consulting with the designated physician, AED provider, and other local resources will help those responsible to develop the most effective AED program for each facility.