BILL ANALYSIS
SENATE JUDICIARY COMMITTEE
Senator Ellen M. Corbett, Chair
2009-2010 Regular Session
SB 1281 (Padilla)
As Introduced
Hearing Date: May 4, 2010
Fiscal: No
Urgency: No
SK:jd
SUBJECT
Automatic External Defibrillators (AEDs): Immunity
DESCRIPTION
Under existing law, a person or entity that acquires an AED for
emergency use is not liable for any civil damages resulting from
any acts or omissions when the AED is used to render emergency
care as long as the person or entity has complied with specified
maintenance, training, and notice requirements. This bill would
repeal those maintenance, training, and notice requirements.
BACKGROUND
An AED is a medical device which is used to administer an
electric shock through the chest wall to the heart after someone
suffers cardiac arrest. Built-in computers assess the patient's
heart rhythm, determine whether the person is in cardiac arrest,
and signal whether to administer the shock. Audible cues guide
the user through the process.
In 1999, the Legislature passed and the Governor signed SB 911
(Figueroa, Ch. 163, Stats. 1999) which created a qualified
immunity from civil liability for trained persons who use AEDs
in good faith and without compensation when rendering emergency
care or treatment at the scene of an emergency. The bill also
provided qualified immunity from liability for building owners
who installed AEDs as long as they ensured that expected AED
users completed a training course. AB 2041 (Vargas, Ch. 718,
Stats. 2002) expanded this immunity by repealing the training
requirements for good faith users and also relaxing the
requirement that building owners must ensure that expected users
(more)
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complete training as a condition of immunity. AB 2041 was
enacted with a five-year sunset which was extended another five
years to January 1, 2013 by AB 2083 (Vargas, Ch. 85, Stats.
2006). This bill would further expand the immunity for those
who acquire an AED by removing the specified maintenance,
training, and notice requirements under existing law.
CHANGES TO EXISTING LAW
1.Existing law provides for immunity from liability for any
person who, in good faith and not for compensation, renders
emergency care using an AED at the scene of an emergency.
(Civ. Code Sec. 1714.21(b).)
Existing law provides that a person or entity that acquires an
AED for emergency use is not liable for any civil damages
resulting from any acts or omissions when the AED is used to
render emergency care provided that the person or entity has
complied with the maintenance, training, and notice
requirements described in more detail below (See item 2).
(Civ. Code Sec. 1714.21(d).)
Existing law provides that a physician who is involved with the
placement of an AED and any person or entity responsible for
the site where the AED is located, is not liable for any civil
damages resulting from any acts or omissions by the person who
uses the AED to render emergency care provided that the
physician, person, or entity has complied with applicable
requirements of Health and Safety Code Section 1797.196.
(Civ. Code Sec. 1714.21(e).)
Existing law provides that the qualified immunity described
above does not apply in the case of personal injury or
wrongful death that results from the gross negligence or
willful or wanton misconduct of the person who uses the AED to
render emergency care. (Civ. Code Sec. 1714.21(f).)
This bill would provide immunity but would no longer require the
training, maintenance, and notification provisions described
in 2, below.
2.Existing law provides that any person or entity that acquires
an AED is not liable for any civil damages resulting from any
acts or omissions in the rendering of the emergency care if
that person or entity does all of the following:
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a. Complies with all regulations governing the placement of
an AED;
b. Ensures all of the following:
i. the AED is maintained and regularly tested;
ii. the AED is checked for readiness after each
use and at least once every 30 days if it has not been
used in the preceding 30 days. Records of these checks
must be maintained;
iii. that any person who renders emergency care
using the AED activates the emergency medical services
system as soon as possible, and reports any use of the
AED to the local EMS agency;
iv. for every AED unit acquired up to five
units, at least one employee per unit must complete a
training course in cardiopulmonary resuscitation and AED
use. After the first five AED units are acquired, for
each additional five units acquired, one employee shall
be trained beginning with the first unit acquired.
Acquirers of AEDs shall have trained employees who should
be available to respond to an emergency that may involve
the use of an AED during normal operating hours;
v. there is a written plan describing the
procedures to be followed in the event of an emergency
that may involve using an AED;
vi. building owners must annually provide
tenants with a brochure describing the proper use of an
AED, and also ensure that similar information is posted
next to any installed AED;
vii. building owners must notify tenants as to
the location of AED units in the building at least once a
year; and
viii. if an AED is placed in a public or private
K-12 school, the principal must annually provide school
administrators and staff with a brochure describing the
proper use of an AED, post similar information next to
the AED, and designate trained employees to be available
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to respond to an emergency that may involve the use of an
AED during normal operating hours; and
c. Any person or entity that supplies an AED shall: (1)
notify an agent of the local EMS agency of the existence,
location, and type of AED acquired; and (2) provide the AED
acquirer with information regarding the AED's use,
installation, operation, training, and maintenance.
(Health & Saf. Code Sec. 1797.196(b).)
Existing law provides that the qualified immunity described
above does not apply in the case of personal injury or
wrongful death that results from the gross negligence or
willful or wanton misconduct of the person who uses the AED to
render emergency care. (Health & Saf. Code Sec. 1797.196(e).)
Existing law specifies that nothing in Health and Safety Code
Section 1797.196 or Civil Code Section 1714.21 may be
construed to require a building owner or a building manager to
acquire and install an AED in any building. (Health & Saf.
Code Sec. 1797.196(f).)
Existing law provides that the above-described provisions
sunset on January 1, 2013 and, after that date, are replaced
by similar provisions requiring maintenance of the unit and
training for expected AED users. (Health & Saf. Code Sec.
1797.196(g).)
This bill would repeal all of the above provisions, thereby
striking the maintenance, training, and notice requirements,
described in 2 above.
This bill contains related legislative findings and
declarations.
COMMENT
1. Stated need for the bill
The author writes:
Each year, approximately 295,000 sudden cardiac arrests (SCA)
occur in the United States that are treated out of hospital
with emergency services. Approximately 20% of these events
occur in the presence of a witness. It's estimated that more
than 95% of SCA victims die before reaching the hospital. In
the event of a SCA every minute counts and the key to survival
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is administration of bystander CPR and the use of an automated
external defibrillator (AED). AEDs are extremely accurate,
user-friendly, computerized devices with audio prompts that
guide the user through the steps to safely deliver both
life-saving shocks and the performance of CPR. Use of an AED
is required to return the heart to a normal rhythm.
Statistics show that survival rates drastically increase up to
50 to 70 percent when a defibrillator is used within 3 to 5
minutes of a sudden cardiac arrest event. For every minute
without a shock to the heart, the chance of survival decreases
by 7 to 10 percent.
Unfortunately in California, many businesses are not
voluntarily installing these life-saving devices due to the
fear of liability and other requirements in the law. Current
law ties immunity to specific requirements placed on the
acquirer of an AED or owner of the premises where an AED is
located. These requirements include training, reporting,
maintenance and development of a written plan to be followed
in case of an emergency. This reasonable public health bill
addresses the problem with current law by providing Good
Samaritan immunity protections for businesses that voluntarily
install AEDS and by removing the requirements placed on
acquirers, which are significantly hindering voluntary
installation.
The sponsor, American Heart Association (AHA), describes
existing law's requirements regarding training, reporting, and
maintenance as "barriers" which, once removed, will result in an
"increased access to AEDs and more opportunities for Good
Samaritan acts and more lives saved."
2. Good Samaritan protection already provided to laypersons; this
bill applies to those who acquire an AED; removal of
safeguards
To be clear, existing law already provides immunity protection
to laypersons who use an AED to render emergency care, provided
that they do not act with gross negligence or willful or wanton
misconduct. When this provision was first enacted, it contained
a training requirement for these laypersons. However, in 2002,
the Legislature passed and the governor signed AB 2041 (Vargas)
which removed this training requirement and substantially
relaxed the training requirement for building owners. It was
thought to be appropriate to treat these two parties differently
with respect to training since it would be difficult to train
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every potential rescuer, but much less difficult to train every
anticipated rescuer (i.e., specified employees). This bill
would remove the requirement for those anticipated rescuers,
thus removing existing incentives for the employer to train
their employees in use of AEDs and maintain those AEDs to ensure
that they are safe for use.
As noted earlier (see Background), the existing qualified
immunity for persons or entities that acquire an AED included
safeguards to ensure that the AED was successfully placed and
thus effective in saving lives. This bill would delete those
safeguards of training, maintenance, and notification. Opponent
Consumer Attorneys of California (CAOC), argues that these
provisions provide "an important balance that both encourages
premises owners to install AEDs ensuring that safeguards are in
place that warrant relieving an owner of liability if one is
injured. Extending immunity for negligence removes incentives
to act responsibly and has the harsh impact of eliminating a
person's recovery against a negligent actor. Such immunity
should be granted in the rarest of circumstances and only when
precautions are in place, which limit the chance that someone
will be injured."
Without these safeguards in place, CAOC worries the bill might
unintentionally create prolific grounds for negligence. The
public policy question thus raised by this bill is whether it is
appropriate to remove these safeguards which incentivize
responsible businesses that install AEDs to provide AED training
to their employees, maintain AEDs on their premises, and notify
the local EMS authority.
3. Training, maintenance, and notification requirements
repealed
This bill would repeal existing law's requirements that
acquirers of AEDs train their employees, as specified, maintain
the AED, and notify the local EMS authority in order to claim
immunity from liability.
Training
Under existing law, a person or entity that acquires an AED for
emergency use has a qualified immunity provided that the person
or entity ensures training for at least one employee per unit
for the first five units and one for each five units thereafter.
This bill would repeal this training requirement and instead
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provide immunity from liability to the person or entity that
acquired the AED.
a. Importance of training
In the past, the AHA and other proponents have emphasized the
importance of training. For example, the AHA notes the
following about training in its "AED Programs Q & A":
If AEDs are so easy to use, why do people need formal
training in how to use them? An AED operator must know how
to recognize the signs of a sudden cardiac arrest, when to
activate the EMS system, and how to do CPR. It's also
important for operators to receive formal training on the
AED model they will use so that they become familiar with
the device and are able to successfully operate it in an
emergency. Training also teaches the operator how to avoid
potentially hazardous situations.
The Sudden Cardiac Arrest Association (SCAA), a supporter of
the measure, has asserted that simply installing AEDs is not
enough, stating "[i]t is important to identify a medical
director, develop an on-site AED response plan, train
designated responders and conduct periodic AED response
drills." On its Web site, SCAA also notes that "[w]hile AEDs
are now very simple to use and many untrained laypersons have
used them successfully, it is best to assure that trained
personnel are always on site (at locations where this is
feasible). A trained user does not necessarily mean trained
medical personnel but also refers to laypersons with AED
training."
And, as noted by CAOC, a report released by the AHA affirmed
the need for training and included it as one of four
"essential elements of AED programs," stating:
This element does not require training of every potential
rescuer but does require the training of anticipated
rescuers. Thus, rescuers who are likely to be present
should be trained, but the site should not be expected to
train every person who could possibly be present. The goal
is to ensure that a trained rescuer is present at all times
(e.g., during business hours). In training, high priority
should be placed on recognizing the emergency; phoning
9-1-1; providing CPR and early defibrillation; and using an
AED in a safe, appropriate, and effective manner. . . .
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Although AEDs are user friendly and the steps in their
operation are often intuitively obvious, the effectiveness
of an AED for cardiac arrest requires more than simple
operation. The rescuer must know when to use an AED (i.e.,
recognize cardiac arrest), how to operate it, how to
troubleshoot it (e.g., a hairy or sweaty chest may prevent
good contact between the skin and electrode pads), and how
to combine AED use with CPR. . . . For all of these
reasons, anticipated rescuers should be trained in a course
that integrates CPR and use of the AED. It is important to
include the recommendation for training and frequent
retraining of anticipated rescuers in community lay rescuer
legislation. ("Community Lay Rescuer Automated External
Defibrillation Programs: Key State Legislative Components
and Implementation Strategies . . . ," Circulation: Journal
of the American Heart Association, 2006.)
The report also contains recommended state AED legislation
that includes "CPR and AED training for anticipated rescuers"
in order to ensure "the training of anticipated rescuers in
CPR and use of AEDs."
b. Simple operation may not be enough for success
Under existing law, the Emergency Medical Services Authority
(EMSA) is authorized to establish minimum standards for the
training and use of AEDs. (Health & Saf. Code Sec. 1797.190.)
In accordance with this authority, EMSA has promulgated "Lay
Rescuer Automated External Defibrillator Regulations." (Title
22, Cal. Code Reg. Div. 9, Chap. 1.8.) Those regulations
provide for "AED Training Program Requirements," which specify
the topics and skills that must be included in the program.
Several of these items are not necessarily intuitive and would
suggest that having trained employees on hand could
significantly increase the likelihood that use of the AED
would have a successful outcome.
For example, the program must cover "assessment of an
unconscious patient, to include evaluation of airway and
breathing to determine appropriateness of applying and
activating an AED" as well as "information relating to
defibrillator safety precautions to enable the individual to
administer shock without jeopardizing the safety of the
patient or the Lay Rescuer or other nearby persons." The
program also must cover how to deal with situations where a
victim is in or near water or liquid. This is important for
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the safety of both the victim and the rescuer because the AED
delivers an electrical shock, and water conducts electricity.
A victim also should be wiped dry before the pads are placed
on his or her chest.
Although, with this bill, the AHA and others have seemed to
move away from the importance of training, it would appear
that this is contrary to the direction in which the EMSA and
others have moved.
c. Training requirements arguably protect the person or entity
that acquires the AED
Existing law's qualified immunity does not apply in the case
of personal injury or wrongful death that results from the
gross negligence or willful or wanton misconduct of the person
who uses the AED to render emergency care. In other words, a
business owner could be sued-and would not be immune from
liability-if the person using the AED did so with gross
negligence or willful or wanton misconduct.
In either case, it would appear to be in the interest of the
person or entity who acquired the AED to make sure that
employees are trained in the use of the AED to ensure that
they do not act in a manner (i.e., with gross negligence or
willful or wanton misconduct) that would result in the
acquirer losing the immunity from liability.
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d. Training increases the likelihood of success
In the case of sudden cardiac arrest (SCA), every second
counts: there is a ten percent reduction in survival for every
minute delay in response. It has been said "few life
threatening emergencies are as time sensitive as SCA," and the
American Heart Association recommends that the optimal
response time from collapse of the victim to on-scene arrival
of the AED with a trained rescuer is three minutes.
Although proponents assert that anyone can use an AED, it is
important to note that training familiarizes the user with the
device, thereby increasing his or her confidence and comfort
level during the stress and confusion of an emergency
situation. As a result, training can increase the likelihood
that, not only will someone use the AED when needed, but will
do so in a timely, efficient, and calm way.
e. Training key to avoiding errors
A study performed in 2004 considered the use of AEDs by
untrained bystanders and attempted to determine "whether
untrained laypersons could accurately follow the visual and
voice prompt instructions of an AED." ("Automated External
Defibrillator Use by Untrained Bystanders," Andre, et al.,
Prehospital Emergency Care, July/September 2004.) Three of
the authors of the study were employees of Philips Medical
Systems, which manufactured one of the AEDs studied. The
study noted:
In this study of simulated cardiac arrest, we observed
several important mistakes made by untrained volunteers
when attempting to follow the voice and visual AED prompts.
A specific focus of this study was the ability of
participants to correctly position pads on the manikin.
Obvious errors that would affect debrillation success
included failure to remove the pads from the packages or to
remove the pad backings, or placing the pads on top of the
clothes. . . .
One concern that has been raised regarding layperson usage
of an AED is whether the rescuer might inadvertently
receive a shock by touching the victim. We observed only
three instances of participants' contacting the manikin
during the simulated shock; none of these instances would
likely cause serious harm. In each case, the volunteer's
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knee or hand made a single point of contact with the
victim's clothes during shock delivery.
The study concluded that "clear, comprehensive, and explicit"
instructions were needed to enable untrained laypersons to
safely and effectively use an AED. The sponsors and
supporters have noted that all AEDs now use audio prompts to
walk a user through the steps necessary to administer the
electrical shock. They have also noted that AEDs are becoming
more widely available. For example, the Philips HeartStart
Home Defibrillator, the only defibrillator that has been
approved for sale without a prescription, is available at
Costco.
Given the study's conclusion that clear, comprehensive, and
explicit instructions are needed and the reality that
participants were evaluated in a simulation of a cardiac arrest
rather than an actual emergency situation which would increase
the stress and confusion faced by an untrained rescuer, the
study results combined with the increased availability of AEDs
are arguably quite worrisome. Training, as required under
existing law, would certainly address the errors made by many of
the participants and would familiarize them with the AED that
they would be using in an emergency situation.
Given these important rationales for training, the Committee
SHOULD consider whether training is in fact an essential element
of a successful AED program such that it is a necessary
component of the qualified immunity?
Maintenance of the AED unit
Under existing law, a person or entity that acquires an AED for
emergency use has a qualified immunity provided that the person
or entity ensures that the AED is maintained and regularly
tested and checked for readiness after every use or at least
once every 30 days if it has not been used. This bill would
repeal this maintenance requirement and instead provide immunity
from liability to the person or entity that acquired the AED.
a. Importance of maintenance
AEDs are advanced computerized medical devices. They are made
up of a small microprocessor, electrical circuitry, and
adhesive electrode pads. Information about the heart's rhythm
is collected by the electrode pads which is then interpreted
by the microprocessor. The microprocessor delivers a
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defibrillating shock if the heart is in ventricular
fibrillation. ("Fact Sheet: Automated External Defibrillators
(AEDs)," Sudden Cardiac Arrest Association, (available at
www.suddencardiacarrest.org).) AEDs must also be properly
maintained to best ensure the safety of both the victim and
the patient.
The AHA's report, "Community Lay Rescuer Automated External
Defibrillation Programs" also includes "on-site AED
maintenance and readiness-for-use checks" as one of the four
essential elements for a successful AED program that
should-like training-be included in state AED legislation,
noting:
Newer AEDs conduct internal battery and circuitry checks
continuously and visually indicate when service or a
battery change is needed. This "design for dormancy" means
that minimal maintenance is necessary, such as a
"readiness-for-use" visual check for "service needed" or
other status indicator, confirmation of the physical
integrity of the device, and a check of the contents of the
carrier case. ("Community Lay Rescuer Automated External
Defibrillation Programs, supra., Circulation: Journal of
the American Heart Association.)
Given the advanced technology of the units and the potential
for problems (see Comment b, below), it would seem that
regular maintenance and testing would be key to a successful
sudden cardiac arrest outcome using an AED. For example, it
is important to check the AED to make sure that the batteries
and electrode pads have not expired. After all, having the
AED in the building is not helpful if the device is not in
proper working order.
b. AEDs are not foolproof
AEDs are said to be "foolproof," but a recent search of the
U.S. Food and Drug Administration's (FDA) website listing
medical device recalls found 16 AEDs listed over a nearly five
and a half year period. ( http://www.fda.gov/MedicalDevices/
Safety/RecallsCorrectionsRemovals/default.htm ) All 16 recalls
were "Class 1" recalls, the most serious type of recall that
involves situations in which there is a reasonable probability
that use of the product will cause serious injury or death.
Most recently, on April 27, 2010, the FDA issued a warning
about faulty components in 14 different AED models and stated
that the devices might malfunction during attempts to rescue
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victims. In another case, the Associated Press reported that
the Food and Drug Administration had determined that
Medtronic's Life 15 heart defibrillators could cause serious
injury or death and were subject to a Class 1 recall. ("FDA
gives Medtronic recall its most serious score," April 22,
2010, Associated Press.) In April 2009 the maker of the Zoll
AED Plus also issued a Class 1 recall. In that case, at least
two patients died following incidents when the device failed
to deliver a shock. Subsequent tests determined that faulty
battery test software failed to detect defective batteries,
and it was later found that additional malfunctions had
occurred, resulting in one more death.
Over 14,000 AED 10 and MRL Jumpstart defibrillators were
recalled in March 2009 after 39 reports of incidents,
including two deaths. In this case, the company alerted
consumers to the following potential problems with the
defective AED: low-energy shock, electromagnetic noise
interference, unexpected shutdown during use, blown fuse, loss
of voice prompts, and shutdown in cold temperatures. Another
Class 1 recall was issued on September 11, 2008 for LifePak CR
Plus AEDs made by Physio Control, Inc. The AED was determined
to be defective because the shock button was covered and not
visible so that responders were unable to administer the
shock.
Existing law provides that the qualified immunities do not
relieve a manufacturer, designer, developer, distributor,
installer, or supplier of an AED of any liability under any
applicable statute or rule of law. While this bill would not
affect this provision of law, the cases of recalled AEDs
arguably underscore the need for regular maintenance and
testing to ensure that the device is working properly.
c. Regular maintenance program ensures AEDs are in their
proper location
Maintenance of the AED unit is also important for other
reasons. In addition to making sure that an AED unit is in
proper working order, a regular maintenance program will help
to ensure that the unit is actually located in its proper
place and has not been stolen, tampered with, or misused in
some way. Because AEDs are supposed to be placed in a
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location that is easily accessible in an emergency situation,
they may be vulnerable to theft or tampering. Regular
maintenance checks, such as those required under existing law,
would help to avoid this.
Given these important rationales for MAINTENANCE, the Committee
SHOULD consider whether MAINTENANCE is in fact an essential
element of a successful AED program such that it is a necessary
component of the qualified immunity?
Notification to local EMS authority
Under existing law, a person or entity that supplies an AED for
emergency must notify the local EMS agency of the existence,
location, and type of AED acquired. This bill would repeal this
notification requirement.
Like training and maintenance, the AHA's report, "Community Lay
Rescuer Automated External Defibrillation Programs" also
includes "Link with the EMS System" as one of the four essential
elements for a successful AED program that should-like training
and maintenance-be included in state AED legislation. In fact,
the AHA report provides that notification to the local EMS
system should be an "expectation," and state AED legislation
should provide that an owner "shall" be required to notify the
local EMS. The report explains the rationale for notification,
stating that "[i]f the dispatcher knows the type and location of
an AED at the site of the emergency, the dispatcher can direct
the rescuer to get the AED and can coach the rescuer in both CPR
and AED use."
Given this important rationale for notification, the Committee
SHOULD consider whether notification is in fact an essential
element of a successful AED program such that it is a necessary
component of the qualified immunity?
4. Federal recognition of training, maintenance, and
notification to local EMS authority
This bill would delete the training, maintenance, and
notification requirements with which acquirers of AEDs must
currently comply. At the federal level, there has been
recognition of the importance of training, maintenance, and
notification. For example, in 2000, the federal Cardiac Arrest
Survival Act (Pub. L. 106-505) was enacted to provide Good
Samaritan protections for use of an AED. That act provided
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immunity from liability for any person who acquired an AED as
long as the harm was not because the acquirer had failed to: (1)
provide appropriate training to an employee; (2) properly
maintain and test the AED; or (3) notify local emergency
response personnel of the placement of the AED.
More recently, the "Josh Miller Helping Everyone Access
Responsive Treatment in Schools Act of 2009" ("Josh Miller
HEARTS Act"), was introduced in the U.S. Congress. (See H.R.
1380 or S. 1197.) That proposed act would create a grant
program for AEDs in elementary and secondary schools. The act
would require each grantee to: (1) have at least five
individuals at the school who have successfully completed
training in the use of AEDs; (2) notify local paramedics and
emergency services personnel where the AEDs are to be located;
and (3) integrate the AED into the school's emergency response
plan or procedures.
The trend at the federal level appears to be towards recognizing
the importance of training, maintenance, and notification. The
Committee may wish to consider whether this bill conflicts with
this recognition.
5. Lawsuits
Proponents of this measure argue that fear of liability is
preventing businesses from installing AEDs on their premises.
Despite this contention, staff conducted a review of litigation
regarding AEDs and was only able to find one case relating to
AEDs.
Opponent CAOC similarly contends that fear of liability is
unfounded and notes that the AHA's own report "Community Lay
Rescuer Automated External Defibrillation Programs" states:
Although premises owners may fear liability resulting from the
use of an AED, such liability is likely to be very limited.
We are aware of no lawsuits filed against lay rescuers or
premises owners related to the attempted use of an AED in a
Good Samaritan effort to save the life of a victim of
prehospital cardiac arrest. The only lawsuits identified
cited failure to have AEDs on the premises.
Support : Building Owners and Managers Association of California;
California Apartment Association; California Business Properties
Association; California Chamber of Commerce; California Chronic
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Care Coalition; California Emergency Nurses Association;
California Forestry Association; California Hospital
Association; California Physical Therapy Association; California
Retailers Association; California State Sheriffs' Association;
CDF Firefighters Local 2881; Civil Justice Association of
California (CJAC); EMS Administrators Association of California;
International Council of Shopping Centers; League of California
Cities; National Association of Industrial and Office
Properties; Retail Industry Leaders Association; Sequoia
Healthcare District; Sudden Cardiac Arrest Association; Western
Electrical Contractors Association (WECA-IEC); 33 individuals
Opposition : Consumer Attorneys of California
HISTORY
Source : American Heart Association
Related Pending Legislation : None Known
Prior Legislation : See Background.
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