Pennsylvania Utility Worksite AED Law: What Act 111 Requires Of Utilities And Electrical Contractors

Most AED laws are written for buildings. This one is written for crews. That difference is what makes it harder to comply with than it first looks, and it is why the six months before the effective date are worth using well.

Where The Law Stands

Senate Bill 1328 passed the Pennsylvania Senate 47 to 2 on October 5, 2026. The House amended it and passed it 197 to 6 on October 21. The Senate concurred in the House amendments 48 to 2 the same day, and the Governor approved it on October 22 as Act 111 of 2026. The enacted text sets the effective date at 180 days, and it assigns enforcement to the Pennsylvania Department of Labor and Industry, which may also issue regulations to implement it.

The bill's sponsors and the lineworker unions that pushed for it framed the reason plainly: lineworkers work in all weather on energized systems, often far from the nearest ambulance, and electrical shock is one of the recognized causes of sudden cardiac arrest.

Who The Act Covers

The act applies to a "utility," and the definition is broader than the word suggests. It includes public utilities, municipal electric systems, and any other entity engaged in the generation, transmission or distribution of electric power in Pennsylvania. Critically, it also includes contractors and subcontractors performing linework or electrical work on behalf of those entities.

A "worksite" is any location, fixed or in the field, where that work is performed: a substation, a pole or line location, a construction or maintenance site, or any other location the utility designates.

One exemption matters in storm season. Utility personnel and contractors working in Pennsylvania in response to a mutual assistance event, such as out-of-state crews brought in for storm restoration through an established mutual assistance network, are not subject to the AED placement requirement. Pennsylvania-based crews doing their normal work remain covered.

The Device Requirement

The core duty is simple to state: at least one AED must be readily available and operable at each worksite. Three details make it demanding in practice.

• Field sites mean the truck. For temporary, mobile or field worksites, including pole work, underground work and storm restoration, the AED must be located on a vehicle, trailer or other mobile unit that remains on the worksite, and it must be reasonably accessible to lineworkers and crew leaders during working hours.
• Every crew location counts separately. If a utility sends multiple crews to distinct locations, each location is its own worksite. Coverage is counted by crew, not by company or yard.
• Utilities must confirm contractor compliance. Before work starts, a utility that engages a contractor or subcontractor must confirm that the contractor has represented its compliance. The act states this confirmation does not by itself make the utility liable for a contractor's failure.

Notice, Training And Records

The act adds three program duties beyond the device itself.

Notice. The location of each AED must be communicated to crew leaders, lineworkers and other employees at the worksite, and included either in the job safety briefing held before work starts or posted in a conspicuous location on a vehicle used at the site.

Training. Utilities must provide CPR and AED training and certification at no cost to employees, through the American Red Cross, the American Heart Association, the National Safety Council, an instructor certified by one of those organizations, or another certifying agency approved by the Pennsylvania Department of Health. At least two trained employees or lineworkers must be reasonably present at each worksite during working hours. Training must cover recognition of sudden cardiac arrest, prompt activation of emergency medical services, proper operation of an AED, and basic CPR. Training records must be kept and made available to the Department of Labor and Industry on request.

Maintenance and inspection. Each AED must be tested and maintained according to the manufacturer's guidelines, with batteries, pads and accessories kept within the manufacturer's recommended service life, and stored so it is protected from damage and environmental conditions likely to impair it. Utilities must set up inspection procedures confirming each AED is present, showing readiness through its self-test or status indicator, and not visibly damaged, and they must keep that inspection documentation for at least two years.

Liability Protection And Penalties

Pennsylvania's existing Good Samaritan protection for AED use applies to anyone who renders care with an AED under the act. Utilities and worksite owners or operators that acquire, provide, maintain or make an AED available in compliance with the act are immune from civil liability for its use or attempted use, except for gross negligence or willful or wanton misconduct.

Enforcement is graduated. The Department of Labor and Industry may investigate, inspect worksites and records, and subpoena documents. A first violation brings a warning letter and 30 days to correct it. A second or subsequent violation carries an administrative penalty of up to $500 per violation.

The penalty is modest. The liability protection is not. Compliance is what earns the immunity, which is the stronger reason to get the program right.

The Count Is The Hard Part

Most organizations will under-count the first time, because the natural instinct is to count yards, trucks or employees. The act counts distinct worksites, and a worksite can be a single pole on a rural road for two hours.

A more reliable approach is to count the maximum number of distinct crew locations active at the same time on a heavy day, then add devices for service rotation, so a unit pulled for a pad or battery change does not leave a crew uncovered. Storm restoration by your own crews, which is not exempt, is usually the peak to plan around.

Training follows the same logic. Two trained responders per worksite is a per-crew requirement, so the question is whether every crew configuration you actually send out includes two current certifications, including on overtime, split crews and days when a trained crew member is out.

Living On A Truck

An AED stored on a line truck faces conditions a lobby cabinet never sees: summer cab heat, winter cold, vibration and dust. The act already requires storage that protects the device from conditions likely to impair it, and the manufacturer's documentation for the specific model and its pads and batteries is the authority on acceptable operating and storage temperatures. Look those ranges up before choosing a mounting location and a case, rather than assuming them, and plan where the unit lives overnight in extreme weather.

A practical point that helps with the notice requirement: mount the AED in the same place on every vehicle in the fleet, so the location in the job briefing is always the same sentence.

A Readiness Checklist For Safety Managers

• Confirm whether your organization, or any contractor you use, meets the act's definition of a utility.
• Count peak simultaneous crew locations, then add devices for service rotation.
• Choose a standard vehicle mounting location and a protective case suited to the manufacturer's storage ranges.
• Build a training roster that guarantees two current CPR/AED certifications on every crew, with a plan for absences and turnover.
• Add the AED location to your pre-job safety briefing template or vehicle placard.
• Set an inspection routine tied to something crews already do, such as the vehicle pre-trip check, and keep the records for at least two years.
• Track pad and battery expiration dates across the fleet so replacements are ordered before they lapse.
• If you are a utility, add the contractor compliance confirmation to your pre-work paperwork.

A Workable Timeline To April 2027

Six months is enough time to do this properly if the work starts now. A sensible sequence is to finish the crew count and the written program in November and December, procure equipment and schedule training in January and February, and use March and early April to mount units, issue inspection logs, update briefing templates and close any training gaps before the effective date. Programs built in the last few weeks tend to buy the wrong case and miss crews.

Organizations that operate in more than one state may also find it simpler to standardize on one program everywhere rather than run Pennsylvania as an exception, since industry-specific AED requirements are becoming more common.

How We Can Help

AEDs are our only business, and we have helped multi-site employers scope AED programs since 2003. If you want help counting crew locations, choosing equipment and cases for vehicle storage, or setting up expiration tracking across a fleet, call us at 888-541-2337 or browse AEDs for businesses.

Related Reading

• New AED Laws in New York and Pennsylvania: What Your Organization Needs to Know
• AED Training For Employees: What Good Preparedness Actually Looks Like
• Is Your AED On The Map? How AED Registration Connects Your Device To 911

Sources

• Pennsylvania General Assembly, Senate Bill 1328 bill history and enacted text, Printer's No. 2059, Act No. 111 of 2026: palegis.us
• Pennsylvania Senate Republicans, "Utility Worksite AED Safety Act Earns Final Approval," October 21, 2026: pasenategop.com
• Pennsylvania House Democratic Caucus news release, October 21, 2026: pahouse.com

This article summarizes Act 111 of 2026 as enacted and is not legal advice. The Department of Labor and Industry may issue regulations or policy statements that affect how the act applies, including where it interacts with federal OSHA requirements. Confirm your obligations against the statute and with counsel, follow the manufacturer's instructions for your specific AED, and make sure the people expected to use it have current training.