Ontario is introducing a significant update to the Construction Projects Regulation (O. Reg. 213/91) under the Occupational Health and Safety Act (OHSA).

The amendment, section 27.1 (Defibrillators), makes it mandatory for constructors on projects where 20 or more workers are regularly employed to install and maintain a Health Canada–licensed Automated External Defibrillator (AED) on site.

This update reflects Ontario’s continued effort to improve emergency medical response and worker safety in construction — one of the highest-risk sectors for sudden cardiac arrest (SCA).

1. Applicability and Responsibility

The requirement applies to any construction project with 20 or more regular workers. “Regularly employed” refers to a consistent workforce, not short-term peaks.

The constructor — the party responsible for overall project management and coordination — must ensure compliance.

Projects expected to last less than three months are exempt, recognizing that small or short-term jobs may not have the capacity for full AED setup. However, voluntary compliance remains encouraged as a best practice.

2. AED and Associated Equipment Requirements

Health Canada Licensing

Every AED on a construction project must be licensed as a medical device by Health Canada. This guarantees that only approved and safe equipment is used.

Mandatory Accompanying Items

Each AED must be stored with the following support materials, which must be maintained and replenished as needed:

  1. One CPR mask
  2. One pair of scissors
  3. Two pairs of disposable medical-grade gloves
  4. One disposable razor
  5. One garbage bag
  6. Four absorbent towels

These supplies ensure responders can safely and effectively assist a worker suffering cardiac arrest.

3. Storage and Accessibility Requirements

AEDs and the accompanying items must be stored together in a suitable location that meets specific safety and accessibility conditions:

  • Protected from dust, moisture, and substances that could affect function
  • Clearly labelled with compliant signage (see below)
  • Easily accessible and unobstructed
  • If outdoors, shielded from extreme temperatures, moisture, and sunlight

The intent is to ensure AEDs are protected from jobsite conditions but always quickly reachable in an emergency.

4. Signage Requirements

AED visibility is vital.

Constructors must post clear signs at and near the AED, as well as throughout the project indicating where the AED is located.

Each sign must include:

  • A heart symbol with a lightning bolt; and
  • The text:
    • “Automated External Defibrillator” or “AED” (in English), or
    • “Défibrillateur externe automatisé” or “DEA” (in French).

The signs must be durable, easy to read, and placed where workers can readily identify the AED location, even under stress or poor lighting.

5. Maintenance, Inspection, and Recordkeeping

AEDs must be:

  • Maintained and tested according to manufacturer instructions
  • Inspected quarterly (every three months) by a competent worker

A “competent worker” under OHSA is someone qualified through knowledge, training, and experience and familiar with potential hazards.

Inspection Records

A record must be kept with the AED showing:

  1. Date of inspection
  2. Name and signature of the competent worker who performed it

These inspection records serve as proof of compliance and ensure readiness in case of Ministry inspections or emergencies.

6. Worker Training Requirements

At all times when work is in progress, there must be at least one worker on site who is trained in both cardiopulmonary resuscitation (CPR) and AED operation.

While the regulation does not specify the training level, Standard First Aid with CPR/AED (Level C) from an accredited provider (e.g., Red Cross or St. John Ambulance) is recommended.

For larger or multi-crew projects, constructors should train several workers per shift and work area to ensure full coverage.

7. Documentation and Safety Program Integration

This new requirement should be integrated into the project’s Health and Safety Plan and Emergency Response Plan.

Key steps for constructors to ensure compliance:

  1. Procure a Health Canada–approved AED and the required kit.
  2. Install it in a compliant, accessible, protected location.
  3. Post signage at the AED and across the site.
  4. Train workers in CPR/AED use and document their training.
  5. Schedule quarterly inspections and keep signed records.
  6. Include AED procedures in site orientations, emergency drills, and toolbox talks.

Having a documented AED program demonstrates due diligence and can help mitigate liability in the event of a workplace emergency.

8. Short-Duration Project Exemption

Projects expected to last less than three months are exempt.

This exception acknowledges that some smaller construction operations (e.g., residential remodels, short-term maintenance, or mobile jobs) may lack the infrastructure to store and monitor an AED.

However, given that AEDs are portable, affordable, and highly effective, many smaller contractors may still choose to adopt AEDs voluntarily as part of their corporate social responsibility and worker protection strategy.

9. Why This Matters: The Health and Safety Context

Cardiac arrest can strike suddenly and without warning. Construction workers are at elevated risk because of:

  • Heavy physical labour
  • Electrical hazards
  • Heat stress and dehydration
  • Long hours and environmental strain

Survival rates from cardiac arrest drop 10% for every minute without defibrillation. Rapid AED use can increase survival to 70–90% if applied within the first few minutes.

The amendment ensures that life-saving technology is available where it is most needed — large, busy, and potentially hazardous worksites.

10. Impact on the Construction Industry

This amendment represents a proactive step toward safer workplaces.

By January 1, 2026, constructors will need to:

  • Budget for AED procurement and maintenance
  • Train designated responders
  • Update safety documentation
  • Ensure continuous coverage during work hours

It’s expected that AED implementation will become a standard safety feature, similar to first aid kits, fire extinguishers, and emergency eyewash stations.