Automated External Defibrillator Density in Virginia's Commercial and Residential Buildings (November 2021)
Summary
Report on Automated External Defibrillator Density in Virginia's Commercial and Residential Buildings, dated November 2021. The Executive Summary states that item 116 of the 2020 Budget Bill (HB 30) directed the Department of Housing and Community Development (DHCD) to convene a workgroup to study the ideal AED density in commercial and residential buildings. A survey of building occupants received 184 responses. Within commercial buildings, 77.4% of respondents reported having at least one AED, including 100% of correctional facilities (as required by law) and 88.5% of schools, but only 11.5% of retail, restaurants, and other businesses.
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“Automated External Defibrillator Density in Virginia's Commercial and Residential Buildings (November 2021).”
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REPORT ON AUTOMATED EXTERNAL DEFIBRILLATOR DENSITY IN
VIRGINIA’s COMMERCIAL AND RESIDENTIAL BUILDINGS
November 2021
Executive Summary:
Today’s automated external defibrillators (AEDs) are self-operating, safe, and relatively
easy to use, even by untrained lay rescuers. Because the modern AED can be used by the
untrained public, Virginia deregulated AED use in 2003. In an effort to gather more information
about AED density in buildings across the commonwealth, item 116 of the 2020 Budget Bill (HB
30) directed the Department of Housing and Community Development (DHCD) to convene a
workgroup to study the ideal AED density in commercial and residential buildings. DHCD
convened a workgroup of public and private industry representatives to develop a survey on
current AED density and usage in the commonwealth. The survey was sent to the occupants of
commercial and residential buildings across the commonwealth and received 184 responses.
Within commercial buildings, the vast majority of respondents (77.4%) reported having
at least one AED. These numbers varied widely across industry groups however, with 100% of
correctional facilities (as required by law) and 88.5% of schools having AEDs, but only 11.5% of
retail, restaurants, and other businesses. While it is difficult to draw specific conclusions from
the data, correctional facilities, retail, restaurants, and other businesses tend to have one AED per
building, while schools have one or two per building, with some having an AED on every floor.
Within residential buildings, only half of respondents reported having an AED in their facilities,
and most reported a density of one AED per building. Respondents in both commercial and
residential buildings referenced the American Heart Association’s guidelines of a three minute
response time (90 seconds away from any emergency) when asked what rules, standards, or
policies governed AED density and placement.
The survey suggested at least some perceived need for more AEDs across all industries
and building types. However, many respondents were concerned about the cost of installing and
maintaining AEDs, and there is little to no outside financial support for increasing AED density.
Respondents in retail, restaurants, and other businesses indicated that AED/square foot would be
a useful density measurement for AEDs, while respondents in correctional facilities indicated
AED/inmate, schools indicated AED/floor, and residential buildings indicated AED/number of
rooms.
Background:
Purpose and use of AEDs
An automated external defibrillator (AED) is a lightweight, battery-operated, portable
device used to revive someone from sudden cardiac arrest caused by either ventricular
tachycardia (a dangerously fast heartbeat) or ventricular fibrillation (an irregular heartbeat).1
AEDs treat sudden cardiac arrest by checking the heart’s rhythm and sending an electrical shock
1
Mayo Clinic Staff, Automated External Defibrillators: Do You Need an AED?, MAYO CLINIC (Apr. 16, 2020),
https://www.mayoclinic.org/diseases-conditions/heart-arrhythmia/in-depth/automated-external-defibrillators/art-
20043909.
1
to restore a normal rhythm if needed.2 When combined with CPR, which will keep blood flowing
to the heart and brain for a short time, the shock will help restore a regular heart rhythm until
professional medical help can arrive.3
The potential life-saving effects of applying an AED are well-documented. A large
number of scientific studies have confirmed that survival rates increase by approximately 25% in
those persons who receive a shock from a lay rescuer with an AED before emergency medical
services arrive compared with those victims shocked after their arrival at the scene.4 When
applying an AED, time is of the essence, as survival chances decrease by 7-10% for every
minute that an AED is not applied.5 However, studies have indicated that bystanders rarely use
AEDs, applying them to only approximately 15% of victims who were suffering from sudden
cardiac arrest.6 Furthermore, less than 10% of out-of-hospital sudden cardiac arrests occur within
100 meters of an AED.7
Despite this low application rate, today’s AEDs are self-operating, safe, and relatively
easy to use, even by untrained lay rescuers.8 Lay rescuers are guided by audible prompts from
the AED itself as well as graphical directions on the device.9 Although AED design differs
somewhat by manufacturer, the basic elements of application and use in a case of sudden cardiac
arrest are the same and include the following: 1) the user is instructed to turn the device on and
to bare the patient’s chest; 2) the defibrillator pads must be opened and their protective backing
removed; 3) the pads are then positioned on the patient’s chest according to the graphics shown
on the AED, 4) the AED then analyzes the patient’s cardiac rhythm, and if a shockable rhythm is
detected, the user is instructed to press a button that delivers the defibrillatory shock.10
AED regulation in Virginia
Because the modern AED can be used by the untrained public, Virginia deregulated AED
use in 2003. HB 1860 (2003) repealed Va. Code § 32.1-111-14:1, which eliminated the
requirement that owners register AEDs along with the requirement that Board of Health establish
a registration program with approved training procedures.11 The bill also amended Va. Code §
8.01-225, Virginia’s “Good Samaritan Law,” by removing language requiring registration of
AEDs and training from its immunity provisions.12 The effect of this bill is that AEDs can be
owned and placed in any building without registration, and any person who, acting in good faith,
2
Id.
3
Id.
4
William J. Brady, Lay Responder Use of Automated External Defibrillators, SUDDEN CARDIAC ARREST
FOUNDATION, https://www.sca-aware.org/about-sudden-cardiac-arrest/be-prepared/aed-deployment (last visited
Nov. 1, 2021).
5
AED 101, EMS SAFETY SERVICES, INC., https://www.emssafetyservices.com/how-to/aed-101/ (last visited Nov. 1,
2021).
6
William J. Brady, Lay Responder Use of Automated External Defibrillators, SUDDEN CARDIAC ARREST
FOUNDATION, https://www.sca-aware.org/about-sudden-cardiac-arrest/be-prepared/aed-deployment (last visited
Nov. 1, 2021).
7
Id.
8
Id.
9
Id.
10
Id.
11
2003 Va. Acts, Chapter 978. The text of this Act can be found in Appendix C.
12
Id.
2
uses an AED to render emergency care is shielded from most civil liability under Virginia law
for any resulting injuries.
These registration and training requirements were the main forms of regulation of AEDs
in Virginia when the law was repealed. Currently, there are only a handful of other laws and
regulations that govern AED placement and training requirements. First, only local and regional
jails are required to have an AED by regulation,13 and the density is set to “a minimum of one
AED unit… in the facility.”14 Second, while statute allows each local school board to develop a
plan to allow for the placement of an AED in every school, this plan is not required by the
commonwealth.15 Finally, only teachers,16 bus drivers,17 and security staff at local and regional
jails18 are required to receive training in how to use an AED.
AED regulation in other states and by the federal government
Other states have enacted a patchwork of AED requirements that typically focus on
placing AEDs at schools, dental offices, and, to a lesser extent, health clubs, nursing homes, and
assisted living facilities.19 Regardless of whether other states require AEDs in certain buildings,
many, like Virginia, have also chosen to provide immunity from civil liability for lay rescuers
who use AEDs, though these provisions are by no means uniform.20 As in Virginia, density
requirements are typically set at a minimum of one per facility or building.21 Even in states
where the size of the building is taken into account, such as Oregon (which requires AEDs in any
“place of public assembly” larger than 50,000 square feet), the statute only requires “at least
one” AED in these places.22 At the federal level, the Food and Drug Administration regulates
13
It appears that the Board of Dentistry does not require dentists who administer deep sedation, moderate sedation,
and general anesthesia to have an AED in their offices, but instead gives dentists the option to have either a manual
defibrillator or an AED. 18 VA. ADMIN. CODE § 60-21-301 (2021) requires an “external defibrillator (manual or
automatic)” when administering deep sedation or general anesthesia, and 18 VA. ADMIN. CODE § 60-21-291 (2021)
simply requires a “defibrillator”, which can presumably be either manual or automatic, when administering
moderate sedation. Given these specific language differences and the fact that defibrillators in dentists’ offices are
intended for use by the dentists themselves, not the lay public, we do not consider these regulations to require AEDs
in dentists’ offices, though the effect may well be that all dentist offices have an AED.
14
6 VA. ADMIN. CODE § 15-40-405 (2021); 6 VA. ADMIN. CODE § 15-40-10 (2021) defines “Facility” broadly as
“the actual physical setting in which a program or agency functions.”
15
VA. CODE § 22.1-274.4 (2021).
16
VA. CODE § 22.1-298.1 (2021).
17
VA. CODE § 22.1-178 (2021).
18
6 VA. ADMIN. CODE § 15-40-405 (2021).
19
EHS Daily Advisor Staff, What state Plan States Require AEDs in the Workplace?, EHS DAILY ADVISOR (Mar. 5,
2021), https://ehsdailyadvisor.blr.com/2021/03/what-state-plan-states-require-aeds-in-the-workplace/.
20
AED Laws by State, AED UNIVERSE, https://www.aeduniverse.com/AED_Laws_by_State_s/97.htm (last visited
Nov. 1, 2021); compare Arizona law (protecting a specific subgroup of people from liability), and Arkansas law
(protecting any person who uses an AED “in good faith and without compensation”), with Maine law (protecting
any person or entity that acquires an AED, the owner of the property where the AED is located, any person who
retrieves an AED, and any person who uses, attempts to use, or fails to use an AED in a cardiac arrest emergency).
21
See, e.g., FLA. STAT. § 429.255(3)(a) (2021) (certain assisted living facilities must have “on the premises… a
functioning automated external defibrillator”).
22
OR. REV. STAT. § 431A.455(2) (2021).
3
AEDs and any necessary accessories and must approve their safety before they are sold.23 The
agency maintains a list of approved AEDs.24
Workgroup on AED Density:
Enabling legislation
Item 116 of the 2020 Budget Bill (HB 30) directed the Department of Housing and
Community Development (DHCD) to convene a workgroup to study the ideal AED density in
commercial and residential buildings. The provision reads:
“A. The Department of Housing and Community Development shall establish a
workgroup to study the ideal Automated External Defibrillator (AED) density in
commercial and residential buildings. The Department shall report its findings to the
Chairs of the House Appropriations Committee and the Senate Finance and
Appropriations Committee on or before November 1, 2021.”25
When determining the scope of the legislation that called for this report (and thereby who should
be invited to join the workgroup), it was necessary to define “commercial and residential
buildings” because there is no set definition within Virginia’s Uniform Statewide Building Code
or the International Building Code. The closest definition is located in the Virginia Energy
Conservation Code (VECC), which defines “Residential Building” as “detached one- and two-
family dwellings, and multiple single-family dwellings (townhouses), and Group R-2, R-3, and
R-4 buildings three stories or less in height above grade plane,”26 and “Commercial Building” as
“all buildings that are not included in the definition of ‘Residential Building’”.27
By combining the VECC definition with a more common understanding of what
commercial and residential buildings are among those who develop the Virginia and
International Building Codes, the following definitions of commercial and residential buildings
were developed for purposes of this report:
Residential buildings are buildings occupied for sleeping purposes, except institutional
occupancies, one and two-family dwellings, and townhouses. Residential buildings
include but are not limited to the following: multifamily dwellings (three or more
dwellings), apartments, hotels/motels, lodging houses, boarding houses, and dormitories.
Commercial buildings are buildings that are not included in the definition of “Residential
building”, except one and two-family dwellings and townhouses. Commercial buildings
include but are not limited to the following: institutional, business, mercantile, storage,
factory, educational, assembly, and utility buildings.
Composition of the workgroup and development of the survey
DHCD convened a workgroup of stakeholders, developed a survey that asked about
current and potential AED density, requirements, and usage, and sent the survey to potentially
23
21 C.F.R. § 870.5310 (2021).
24
Automated External Defibrillators (AEDs), FOOD AND DRUG ADMINISTRATION (Apr. 7, 2021),
https://www.fda.gov/medical-devices/cardiovascular-devices/automated-external-defibrillators-aeds.
25
For the full text of the provision, see Appendix B.
26
VA. ENERGY CONSERVATION CODE § C202 (2015).
27
Id.
4
affected groups.28 This report summarizes the results of that survey.29 In soliciting members for
the workgroup, DHCD sought to include those who occupy commercial and residential
buildings, those in the health profession who provide training for and regularly use AEDs, and
those who represent employee interests generally. Invitations were extended to a mixture of
representatives from the private and public sectors. The final workgroup was comprised of the
following individuals:
Beverly Rebar from the State Council on Higher Education for Virginia
Robert Melvin of the Virginia Restaurant, Lodging, and Travel Association
Marsha Stanford of the Virginia Department of Corrections
Jen Armstrong of the Virginia High School League
The workgroup’s initial meeting was held on September 24, 2021, to discuss issues
surrounding AED density standards and develop survey questions. The survey was completed on
September 29, 2021, and broadly disseminated to all of the representatives who were invited to
join the workgroup, regardless of whether they ultimately joined the workgroup. The survey
closed on October 15, 2021.
Survey Results and Findings:
Demographics of survey respondents
There were 184 responses to the survey, with 151 complete responses and 33 partial
responses.30 The largest response group was education, with primary, secondary, and post-
secondary schools making up 56.5% of respondents. Correctional facilities made up 13.6%,
while retail, restaurants, and other businesses made up 14.6%, and travel, lodging, and
campgrounds made up 10.8%. Therefore, 84.7% of respondents occupied commercial buildings
and 10.8% occupied residential buildings. The remaining respondents either chose not to disclose
their industry or represented the interests of an industry in the aggregate.
Current AED density in Virginia: commercial buildings
Within commercial buildings, a significant majority of respondents (77.4%) reported
having at least one AED. These numbers varied widely across industry groups however, with
100% of correctional facilities (as required by law) and 88.5% of schools having AEDs, but only
11.5% of retail, restaurants, and other businesses. The number of AEDs reported ranged from
683 across an entire school district, as many as 15 in other primary or post-secondary school
buildings, between one and twelve in correctional facilities, and one in most commercial spaces
and restaurants.
Generally speaking, respondents in commercial buildings did not know the exact density
of AEDs across their facilities and buildings. Those that did know reported a variety of numbers
and measurements. To the extent that conclusions can be drawn from this data about current
AED density in commercial buildings, correctional facilities, retail, restaurants, and other
28
For the full text of survey questions, see Appendix A.
29
For a report of the full survey responses, see Appendix A.
30
Because there was a high rate of partial responses and some responses, while considered complete by the survey
software, did not adequately answer the question asked, reported numbers may not add to 184 responses or 100%.
5
businesses tend to have one AED per building, while schools have one or two per building, with
some having an AED on every floor, and a few having time or people-based density
requirements such as “enough to satisfy the 3-5 min response time,” or “2 per 450 people.” Other
respondents indicated having a certain number of units, often portable, designated for outdoor
use. Two respondents reported using a square footage density requirement of one AED for every
21,000 square feet and one for every 25,000 square feet, respectively.
The survey also asked respondents what rules, standards, and policies govern the
placement of their AEDs in an effort to determine whether there are standards outside of laws
and regulations that govern AED placement. Within commercial buildings, correctional facilities
reported having internal policies governing the placement and accessibility of AEDs.31 Several
schools referred to the American Heart Associations’ (AHA) standards, which recommend a
three minute response time (90 seconds away from any emergency),32 school board policies, or
to the National Athletic Trainer’s Association guidelines for AEDs at athletic events. Many also
expressed a desire to adhere to specific response times when placing AEDs. Suggested times
included less than two minutes, less than 90 seconds, or three to five minutes from any location,
though respondents did not always reference where those standards came from. One secondary
education respondent reported using “density of people on our campus and the likelihood of
choking and other secondary causes of cardiac arrest to inform our placement,” and another also
cited “strategic placing based on risk and possible need”. There were no responses to this
question from retail, restaurants, and other businesses.
Current AED density in Virginia: residential buildings
Within residential buildings, only half of respondents (10 out of 20) reported having an
AED. Within those, 80% reported having only one or two AEDs in their facilities, with one
convention center/hotel having 12 and one lodging facility reporting 15. Respondents in
residential buildings also generally did not know the exact density of AEDs in their facilities,
with only one respondent reporting that they have an AED every “1000 feet”. Four respondents
entered a density value of “1”, which could be interpreted as one AED per building since
residential operations, unlike schools and correctional facilities, are generally located within the
same building on a given property. In residential buildings, respondents also referenced the AHA
as well as corporate brand policies when asked about other rules, standards, or policies that
govern the placement of their AEDs.
Suggested density requirements: survey responses
At the end of the survey, respondents were asked whether there is a perceived need for a
larger, smaller, or similar number of AEDs in their industry, and then asked to provide what they
31
It is unclear whether these policies are required by the Department of Corrections, as some respondents referenced
“DOC Policy” and others referenced their own operating procedures or guidelines.
32
Implementing an AED Program, AMERICAN HEART ASSOCIATION (May, 2018), https://cpr.heart.org/-/media/CPR-
Files/Training-Programs/AED-Implementation/Implementing-an-AED-Program-ucm_501521.pdf (“Effective AED
programs are designed to deliver a shock to a victim within three to five minutes after the person collapses. Use a
three-minute response time as a guideline to help you determine how many AEDs you need and where to place
them. AEDs can be placed near elevators, cafeterias, main reception areas, in secured or restricted access areas and
on walls in main corridors”).
6
believe would be a useful density measurement for their industry. Responses to these questions
varied widely by industry within commercial and residential buildings, and there does not appear
to be a generally agreed upon density measurement in buildings where AEDs are not required.
Therefore, this section provides a broad summary of those qualitative responses by industry.33
Within retail, restaurants, and other businesses, seven out of fifteen respondents indicated
a need for more AEDs, while three indicated fewer are needed, and two stated they have not seen
a need for AEDs within their industry at all. Three respondents indicated that they have “no
idea” or that the need for AEDs is “unknown”. Suggestions for density measurements within
retail, restaurants, and other businesses from most suggested to least included square footage,
occupancy (with one suggestion of one AED per 5,000 people), and number of floors. Further
suggestions included requiring AEDs in certain amenity areas, such as the gym within an office
building.
Within correctional facilities, an almost even number of respondents indicated that more
AEDs are needed (10 out of 23) and a similar number are needed (9 out of 23). One respondent
indicated fewer AEDs are needed, while three indicated that the need is unknown. Suggestions
for density measurements within correctional facilities from most suggested to least included
number of inmates, one per building, one per dormitory, and number of rooms in the facility.
Several respondents stressed that the density should also take into account the configuration of
the facility and the distance someone must travel with the AED. One respondent cautioned that
any density measurement should also include an assessment of “how quickly [an area] could be
accessed through Security.”
Within educational facilities, 44 out of 79 respondents indicated a need for more AEDs,
while 25 indicated a similar number are needed, and five indicated fewer AEDs are needed. Five
respondents also indicated that the need is unknown. Suggestions for density measurements
within educational facilities from most suggested to least included number of floors (almost
twice as popular as the next suggestion), occupancy limits/building capacity, square footage
(often combined with number of floors for a measurement that would lead to more than one AED
per floor), and a time-based requirement ranging from a 90 second to five minute response time.
Many respondents noted that the density should be different based on building usage and
function, with several indicating that the number should be different for indoor and outdoor
facilities, namely classrooms versus athletic facilities.
One respondent stated that AEDs should be required in schools, while another noted that
a requirement would be cost-prohibitive. For educational facilities, there was also a significant
number of respondents who seemed to be frustrated by the fact that there is not a standard
density for AEDs in schools. These respondents indicated that having a standard would be
welcomed by school administrators, with one stating “if there were a standard like fire
extinguishers, it would help.”
Within residential buildings, five out of thirteen respondents indicated a need for more
AEDs, while three indicated that the current number is sufficient, and four indicated fewer AEDs
are needed. One respondent indicated that the need is unknown. Of the five respondents who
suggested that more AEDs are needed, there was a general consensus that each building needs at
33
For the full text of these responses, see questions 13 and 14 in Appendix A.
7
least one AED. Suggestions for density measurements within residential buildings from most
suggested to least included number of rooms (with suggestions for one AED per 300 rooms and
one per 150 rooms), one per building, square footage, and occupancy. One respondent
representing a hotel pointed out that the measurement should be based on number of rooms per
floor, not per building, as every hotel has a different floor plan.
Suggested density requirements: medical associations
Even though there does not appear to be a generally agreed upon density measurement in
commercial and residential buildings, many respondents mentioned the AHA in their responses.
As mentioned above, the AHA has stated that AEDs need to be applied within three to five
minutes after a person collapses.34 Therefore, the AHA recommends building owners use a three-
minute response time (90 seconds away from any emergency) when determining how many
AEDs to purchase and where to place them.35 EMS Safety Services Inc, a leading provider of
emergency response training courses and supplies, also recommends that an AED be applied
within three minutes of cardiac arrest.36 This time-based requirement could be a useful
measurement when combined with another measurement based on the physical characteristics of
the building, especially since many respondents are already aware of the AHA’s guidelines.
Both the AHA and the Sudden Cardiac Arrest Foundation (SCAF) also emphasize that
AEDs are only useful when placed in public places that are accessible during all hours and where
there is a reasonable probability of a witnessed cardiac arrest.37 Other best practices
recommended by the SCAF include placing AEDs in locations such as airports, rail terminals,
casinos, sports arenas, and buildings in which larger number of persons at risk for cardiac arrest
frequent, and in locations in which there is at least one cardiac arrest event every five years.38
Barriers to increasing AED density
While developing the survey, members of the workgroup expressed concern over a
potential increase in costs for both installation and maintenance if AED density were to be
increased. Therefore, the survey asked several questions about the cost of AEDs, including how
respondents paid for any AEDs they currently have, how much money respondents spend on
maintenance, and any barriers that would prohibit them from installing more AEDs.39 A brief
accounting of AEDs show their cost being between $1000 and $2000 per unit. This cost varies
by model and optional add ons. The mounting of a semi-permanent AED unit would add
additional cost. Relevant procurement policies and other institutional requirements may also
impact cost.
34
Id.
35
Id.
36
Sudden Cardiac Awareness Month 2018, EMS SAFETY SERVICES, INC. (Oct. 9, 2018),
https://www.emssafetyservices.com/2018/10/09/cardiac-arrest-awareness-month/.
37
William J. Brady, Lay Responder Use of Automated External Defibrillators, SUDDEN CARDIAC ARREST
FOUNDATION, https://www.sca-aware.org/about-sudden-cardiac-arrest/be-prepared/aed-deployment (last visited
Nov. 1, 2021).
38
Id.
39
For the full text of questions and responses about AED cost, see questions 6 and 9-12 in Appendix A.
8
While 64% of respondents either did not know or preferred not to disclose how they paid
for their AEDs, only 8% of respondents reported utilizing grant money, and 28% knew that they
used private money to install their AEDs. Furthermore, the vast majority (95%) of respondents
were unaware of any funds, grants, or other programs that would help them install AEDs in their
facilities. Many respondents also reported spending a significant amount of money maintaining
their AEDs, with the most respondents (29%) spending $101-$500 each year, and 13% spending
more than $1,000. However, 21% spent $0-$100 and 23% did not know how much money was
spent. A smaller percentage of respondents (14%) reported spending $501-$1000. The most
significant maintenance expense is changing pads and batteries.
Respondents who identified barriers overwhelmingly reported that the cost of installing
and maintaining additional AED units is the main barrier to installing more of them. However,
other barriers besides cost include concerns over liability if units do not work; lack of authority
to place AEDs due to intergovernmental relations, administrative approval requirements, or
landlord/tenant contracts; lack of personnel to oversee maintenance; keeping the AEDs in a
secure location/away from inmates; various issues related to training, such as adding AED usage
and training to emergency response manuals and proper training of staff; theft; space for storage
and charging; and aesthetic concerns.
9
Appendix A: Standard Survey Summary from Alchemer Survey Tool
10
Report for AED Study Survey
Response Counts
Co mplet io n Rat e: 82.1%
Complete 151
Partial 33
T o t als: 184
11
1. What industry do you represent?
9% Other
16% Education: K -12
10% Restaurant
9% Lodging
1% Travel
1% Commercial - Other
1% Commercial - Retail
40% Education: Secondary
14% Corrections
Value Percent Responses
Education: K -12 15.9% 28
Education: Secondary 39.8% 70
Corrections 13.6% 24
Commercial - Retail 0.6% 1
Commercial - Other 1.1% 2
T ravel 1.1% 2
Lodging 9.1% 16
Restaurant 10.2% 18
Other 8.5% 15
T o t als: 176
12
2. If "other" please describe.
Response
Public College
Accounting
Arena
Campground
Chamber of Commerce
College
Convention Center
Higher education
Non Prof it Botanical Garden
Of f ice
One Stop Location
Post secondary education
We house both a secondary education and a commercial business
amusement's
higher education
non-prof it
13
3. Do you have AEDs at the facilities you represent/own?
27% No
73% Yes
Value Percent Responses
Yes 73.2% 131
No 26.8% 48
T o t als: 179
14
4. How many total AEDs do you have across your facilities?
Response
2
3
1
6
4
5
7
12
15
24
10
11
14
16
9
1 in each building, 1 in gym, 1 f or AT
100s
13
17
181
20
225
23
15
Response
27
33
38
4-5
40
45
67
680
683
72
8
T hree
one
three that I know of
16
5. What is the approximate density of the AEDs across your facilities?
Please average over all of your properties. If unknown, please write
“unknown”
Response
unknown
Unknown
1
1 per building
3
4
.826
1 per 25000 sf
1 per building with exception of 2 larger academic f acilities
1 per major use building
1 per occupied building
1,000 f eet
1/HU and operational area
175 acres - 3 located near public gathering sites
2
2 AEDs f or 2 main buildings
2 Per building
2 per 450 people
2 per building
2-8
21,000 sqf t
17
Response
3 per building
4 AEDs per building; range is 2-9.
5
80
9.3% of our buildings have units and our 2 campus saf ety vehicles also have them.
A minimum of one AED in each building
At least one per building, some buildings that have multi-assembly events will have two
AEDs located on separate f loors. Our campus student centers have two AEDs, one on the
f irst f loor, one on the same f loor as out f itness centers.
One in building, one designated f or outside activities (athletics)
One per athletic f ield grouping
One per f loor
Unkonwn
We generally have one per housing unit, each unit averages 200 people
We have enough to satisf y the 3-5min response time.
all sports and some academic
multiple per building
n/a
school nurse, gym, baseball/sof tball f ield, portable f or f ootball f ield
unknow
18
6. How much money, on average, do you spend each year maintaining
your AEDs?
21% $0- $100
23% Unknown
13% More than $1000
29% $101 - $500
14% $501 -$1000
Value Percent Responses
$0- $100 20.6% 26
$101 - $500 29.4% 37
$501 -$1000 14.3% 18
More than $1000 12.7% 16
Unknown 23.0% 29
T o t als: 126
19
7. What actions, such as changing pads and batteries or replacing
broken or missing units, do you or your employees take to maintain
your AEDs?
Count Response
4 Employees monitor battery levels, battery and pad expiration dates, as well as
perf orm periodic self -test of the units.
3 All of the above
1 AED's and supplies maintained by school health services. As the school nurse, I do
the monthly checks and alert my supervisor to any needs, who then supplies them.
1 AEDs are maintained by an outside individual/party
1 All are monitored via internet connection - the provider lets us know if and when
there is a problem
1 All listed along with weekly checks of f unction.
1 All of the above in addition to daily maintenance checks.
1 All of the above is done monthly.
1 Annual inspections. Batteries and Pads replaced when use, expired, or missing.
1 Batteries are checked and pads are replaced if the AED is used.
1 Change Pads & Batteries T raining
1 Change pads & batteries as needed (expired).
1 Change pads and batteries when they expire
1 Change pads when used or expired and change batteries yearly.
1 Change pads, batteries, replace units as needed
1 Changing batteries when needed and pads when expired
1 Changing batteries, and pads when needed, and inspected yearly.
1 Changing batteries.
1 Changing pads replacing batteries Monthly checks
1 Changing pads & batteries when expired and as needed. Weekly check of machines
power, f unction, saf ety, and supply inventory.
20
Count Response
1 Changing pads and batteries
1 Changing pads and batteries and replacing broken units
1 Changing pads and replacing batteries. Just replaced and added new aeds this year
f or AT Cs and around the school
1 Changing pads.
1 Check and replace batteries monthly
1 Check them monthly, change pad/battery back every 4 years, replace AEDs when
they expire at the 8 year mark
1 Checked several times a year, replace pads, replace batteries, replace units as
necessary
1 Checked weekly by nursing staf f to ensure all parts are present and f unctional and
to verif y expiration date of pads and batteries. Batteries and pads are replaced as
needed.
1 Checking pads and batteries every other month. Making sure they turn on and work
correctly every other month
1 Checking the batteries each month and changing the pads when they are expired.
Also keeping the supply kit up to date.
1 Contract f or maintenance services through an outside vendor.
1 Contracted
1 Documented preventative maintenance system which is checked monthly by one
employee and an alternate.
1 Each AED and its supplies are checked weekly f or proper operations, damages, and
expired supplies. All f indings are reported, addressed and/ or replaced as
appropriate.
1 Expiration and af ter each use. Order as needed
1 I'm the athletic trainer in my building. We have 4, 2 f or athletics and one on each of
our f loors. I order new pads and batteries f or all of our units. I am not certain of
the other buildings We have 9 elementary schools, 4 middles schools, 3 high schools
and then county buildings
1 Just routinely check to make sure we have a green light, replace pads and batteries
on rotation as needed
21
Count Response
1 Monthly check Order new pads, batteries when needed Stock CPR mask, guaze,
scissors, with each AED
1 Monthly check and replace as needed
1 Monthly check of the unit.
1 Monthly check of units.
1 Monthly checks
1 Monthly checks and replacing batteries when applicable.
1 Monthly checks are conducted that requires a checklist to be completed. T he
checklist has 6 line items f or pass or f ail. T hose line items include; Check the
status indicator window is showing a green check mark indication the unit is ready to
use, verif y electrodes pads are within their expiration date, verif y batteries are
within their expiration date, verif y electrodes are pre-connected to the input
connector, verif y that supplies are available f or use (razor, mask, gloves), and verif y
the cabinet tamper alarm is activated and working. Inventory list identif ies each
AED unit with pad expiration date and battery install date, which is also labeled on
each AED unit. Our program replaces all pads and batteries 5 years f rom
installation, or sooner if pads have expired bef ore then. Monthly checks are to also
ensure AED units are not broken or missing and can be replaced if that is f ound to
be the case.
1 Monthly checks on batter and pad lif e
1 Monthly checks, pad and battery replacements
1 Monthly inspection to ensure battery is good, equipment is in good condition.
1 Monthly inspections and replacing batteries and pads as needed.
1 Monthly inspections of all 67 AED's. Pads are changed every two years.
1 New FOOBAGS.
1 None, our host does as part of our lease agreement
1 Not allowing student to accidentally discharge them.
1 Only maintenance so f ar is battery replacement and pad replace due to expiration
date on units
1 Our AED's are checked monthly to ensure that the battery is good and they are in
working condition. T he pads are replaced upon expiration and the batteries upon
end of lif e or expiration.
22
Count Response
1 Our Campus Saf ety Dept changes pads and batteries as needed. T hey check units
once a month f or proper operation.
1 Our School nurse checks our units regularly and makes sure they are working
properly.
1 Our health services dept. is in charge of replacing batteries/pads and overall
maintenance.
1 Pad and battery changes are the most f requent actions at my f acility.
1 Periodic checks, change pads and batteries.
1 Primarily checking and replacing any items close to being out of date
1 Regular testing and maintenance
1 Replace batteries and pads
1 Replace batteries, Replace pads, Replace AED's
1 Replace batteries, changing pads, routine checks
1 Replace batteries, pads & conducts routine inspection test.
1 Replace once used. Yearly check on battery
1 Replacing batteries and pads if used.
1 Replacing expired pads, replacing expired batteries
1 Replacing the batteries is the only thing that has been done to the AEDs since the
school received them.
1 School Nurse and Nurse coordinator, maintains all aspects of the AED
1 School nurse maintains
1 T he cost identif ied is to change the pads and batteries annually because the
consumables expire.
1 T he machine is checked weekly to ensure that the dates are current f or the
batteries , pads etc.
1 T he police department conducts monthly checks on AED's. Equipment is changed as
needed, used or when expired.
23
Count Response
1 T hose actions are under a maintenance contract with Cintas
1 Visual inspection once a year, or af ter usage. Replace parts when necessary.
1 We check monthly f or when pads,batteries expire.
1 We check units every six months
1 We do the above, but also determine if a unit needs to be upgraded or replaced.
1 We exchange batteries and other components as dates expire.
1 We have Philips Healthcare HeartStart OnSite (HS1) Automated External
Def ibrillators (AEDs) and the replacement of cartridge pads as well as the
batteries are based upon the manuf acturer's recommendations. T he cartridge pads
are replaced approximately every two years. Each AED has a cartridge pad in the
unit and a spare cartridge pad in the case. T he cartridge pads have an expiration
date, so replacement pads are reordered based upon that date. T he batteries are
replaced based upon their installation date, because of the automatic self -test
operation that occurs within each unit. T he batteries typically last three years and
replacement batteries are reordered based upon the installation date, plus three
years. Replacement cartridge pads and batteries are purchased f rom State f unds
allocated f or Administrative Services within the Facilities Department budget.
1 We have a company (Cintas) that comes in and maintains the AED when they
maintain our f irst aid boxes.
1 We have a contract in place f or this to be done f or us annually.
1 We have a regular inspection and replacement cycle f or batteries and pad
replacements. Occasionally, we must replace a unit because of temperatures at
outdoor locations.
1 We inspect AEDs weekly. We look f or missing parts, damage, low battery, etc.
1 We perf orm semi-annual inspections of our AED's, change pads, batteries and
replace broken or missing units as necessary.
1 We purchase parts online.
1 We replace pads and batteries as needed
1 We used to do it all; we now contact with a vendor to provide annual inspections
and maintenance to include pads and batteries.
1 Weekly AED checks are done on the AEDs located in the medical department
1 Weekly Check
24
Count Response
1 Weekly checks on f unction, batteries, and pads.
1 Weekly checks to include checking expiration dates on pads, battery and ensure it is
f unctioning properly.
1 Weekly checks to verif y expiration dates/damage.
1 Weekly inspections, repairs as needed, changing pads, batteries as needed
1 Yearly inventory, battery and pad changes.
1 all upkeep
1 annual training and updating of machine and accessories.
1 change batteries
1 change expired pads, change batteries, weekly checks on the units
1 change pads, batteries and maintain/ replace broken and missing parts
1 changing expired pads and batteries
1 changing expired pads, replacing batteries
1 changing pads and batteries
1 changing pads and batteries and yearly checks.
1 changing pads and batteries, testing and replacing broken units
1 changing pads and batteries. Replacing expired units.
1 check all pads, batteries, cords weekly
1 check batteries
1 check yearly replace as needed
1 checking batteries and expiration dates then report the inf o to maintance f or
replacement
1 just bought a brand new one
1 monthly checks of AED's and notif y the building contact when pads/batteries need
replacing. When the replacements arrive they are replaced by Fire Saf ety
25
Count Response
1 monthly maintenance check that AED is operating properly, changing pads, changing
batteries
1 perf orm weekly inspection of aed and exchange anything that needs corrected with
the aed
1 report issues to be replaced
1 they are checked weekly, Batteries replaced af ter every use and every 3 years and
pads replaced af ter use and per expiration dates
1 we do weekly checks f or operation and expiration, if needed we order replacement
1 weekly checks replace batteries and pads as needed
1 weekly checks are perf ormed by nurse
26
8. What rules, standards, or polices governed the placement of your
AEDs?
Count Response
4 When our AED's were placed, locations were determined through a regional
collaboration that included healthcare, local government, our business community,
as well as a public-private public access def ibrillator program.
4 unknown
3 Unknown
2 N/A
2 None
2 Unknown
1 ACA standards and DOC standards
1 ADA Compliance
1 AED is placed in every building that houses inmates as well as work locations.
Common employee areas have an AED.
1 AED placed near interior callbox locations and close proximity to entrances or
security desks.
1 AED required in medical and at f ront entry.
1 AED's available in each building of the institution.
1 AHA
1 AHA standards, I believe.
1 Accessible on each f loor of each campus building
1 All employees must take AED training. Units are checked each month by
engineering department.
1 All sports/f itness locations. T ry to locate the AED's in the same location in
academic buildings (Elevator Lobby/under cameras near the exit)
1 All staf f are AED trained. Yearly review with crisis team.
1 At least one per building.
27
Count Response
1 Central location f or easy access in an emergency
1 Checked weekly
1 Collaborative ef f ort between school division, county government and the original
AED vendor.
1 DOC policy
1 Departments request and pay f or the AED. T hey are installed by the Facilities
Dept. T he Rescue Squad maintains the unit once installed.
1 Distance, time, accessibility
1 Easy access across all buildings.
1 Emergency euipment
1 Followed recommendations re mounting of units; no locality "standards or policies"
were available related to placement
1 General rule was we placed them outside of our main of f ices in each school so it
was easy f or everyone to know the location as well as easy to notif y staf f of an
emegency
1 Having AED's f or f aculty, staf f , students, student-athletes, spectators, and visitors
in various locations to meet 2-3 minute response time
1 Highly visible locations
1 Hilton Brand Standards
1 I am the athletic trainer at a high school. We have 4 f or athletics. One stays with
me, the others go with of f campus teams or teams that are traveling. Our other 4
are located around the school.
1 I have created an emergency action plan f or each sport venue we have. In each it
discusses where the AEDs are and when to use them. I also have my EAP signs
posted at each Venue. We also have AED signage all over to show where they are.
We have boxes that hold the AEDs that have an alarm when they're opened to
alert everyone. I also carry an AED with me at all times. Practice or competition
1 If it is determined AED may be needed, security of f icer brings it to area.
1 If used or out of date, replace
1 In development.
28
Count Response
1 Industry standards, 90 sec retrieval I.e.
1 It is in a see thru cabinet at the f ront gate, easily accessible by all staf f .
1 Largest gathering areas.
1 Lease agreement leaves this up to the host.
1 Less than 2 min. f rom any location. High traf f ic areas, with medical provider.
1 Local school board and state agencies
1 Located near public gathering sites, especially since we have multiple wedding sites
that are being used.
1 Medical and Operational policy.
1 Medical guidelines
1 NAT A we wanted them in each school and our county did it by numbers in each
school and then athletics got their own to be able to take of f site f or game
1 Need within the building given the size
1 None particularly. Placed at least one in each building where they would be easily
accessible.
1 None. We have them in several buildings, Gym, and police vehicles
1 One AED is placed on a wall outside the main of f ice complex and the other on a
wall outside the gym. All prof essional staf f and the school nurse is trained in
operating the AEDs.
1 One stays in school T hree athletic aeds placed at f ield houses outside
1 One with the athletic trainer and one located in the building near athletic f acilities
and accessible to all.
1 Only rule is one per f loor on out main campus in locations open to anyone, sub
campus same and also located where employees only have access
1 Only used by prof essional staf f
1 Operating Procedure 720.7
1 Operating procedure 720.7 def ines emergency medical equipment and care
29
Count Response
1 Our AED's are placed in easily accessible areas and the locations of each are
published each year in our continuity plan.
1 Our nurses help implement the placement within the school. T he NAT A position
statement of prevention of sudden deaths allow AT C to always carry AED with us
or have it be within 3 minutes of us, to allow f or immediate access to prevent any
delay of care
1 Ownership initiative
1 Part of a comprehensive Emergency Management Plan.
1 Place in the main of f ice and the gym
1 Placed in most academic buildings and staged during athletic events. University
Police patrol vehicles have an AED in the trunk.
1 Policy states that I will have a minimum of 1 AED in the same building occupied by
inmates.
1 Recommendation of contractor.
1 Required trained staf f training
1 Sports Medicine Policies and Procedures Manual
1 Standard T reatment Guidelines
1 Strategic placing based on risk and possible need.
1 Strive to have an EAD 3 mins away f rom anywhere on campus
1 T he AED is in a case in the Middle area of the school
1 T he AED's are placed in areas within close proximity to our contract security
of f ices (although not designated as f irst responders, T CC's security of f icers have
cardiopulmonary resuscitation (CPR), f irst aid, and AED training), and in the Student
Centers, near the f itness areas. T here are no f ederal and/or state saf ety and
health regulations that govern the placement of AED units. T CC's determination
f or the placement of the AEDs was based upon activities within the buildings.
1 T he institution had them placed in the areas of highest f oot traf f ic.
1 T here are manuf acturer's recommendations f or monthly inspections, but our
f acility has a guideline of weekly inspection by a nurse.
1 T hese AED's were placed prior to the current team being here so this is unknown.
30
Count Response
1 T hey are checked weekly. Kept in all buildings, medical, warehouse, and f ront search
1 T hey are with student health, campus security, and in the student center.
1 T hey have to be in a highly visible location and persons using them must be trained.
1 T ime and distance required to access f rom any given point/location in the building
when needed
1 Unknown; AEDs have been in place f or 15+ years.
1 VADOC policy
1 VDOE
1 We are a Medical College and have many physicians trained to use AED's
1 We f eel it is best practice to have at least one AED in each building. Some larger
buildings have one AED per f loor.
1 We have AED guideline
1 We have enough in the building so the response time is within 3-5 minutes as
suggested by the NAT A. We also have one that is on the stadium f ield with the AT
during all contests.
1 We have recently upgraded our AED to a newer model. I'm not sure what the rules
are f or replacing them?
1 We have units placed in two vehicles so when Campus Saf ety responses to an
emergency they have it with them. T he other units are placed strategically in
higher risk buildings such as our Health Clinic, Fitness and Athletic f acility, one that
goes to our athletic competitions, Riding Center etc.
1 We place these in proximity to most classrooms as well as athletic f ields.
1 We placed onse on each f loor with response time to be less then 2 minutes to
activate.
1 We used density of people on our campus and the likelihood of choking and other
secondary causes of cardiac arrest to inf orm our placement. Our Emergency
Manager is an EMT .
1 Weekly checks, 720.7 policy
1 Worked with American Heart Association to help determine placement.
1 accessibility and need
31
Count Response
1 must be trained to use
1 none.
1 ref er to Risk Management with Prince William County Public Schools
1 unsure
1 we carry the AED to all medical emergency's
1 weekly checks.
32
9. If known and you are comfortable providing this information, what
funding source(s) were utilized to pay for and install your AEDs?
4% Prefer not to answer
28% Private funds
5% Private grants
60% Unknown 3% Public grants
Value Percent Responses
Private f unds 27.7% 33
Private grants 5.0% 6
Public grants 3.4% 4
Unknown 59.7% 71
Pref er not to answer 4.2% 5
T o t als: 119
33
10. Are you aware of any funds, grants, or other programs that
would help you pay for or install AEDs?
5% Yes
95% No
Value Percent Responses
Yes 5.3% 8
No 94.7% 142
T o t als: 150
34
11. Please elaborate is "Yes".
Response
AEDGrant.com
Byrne grants and such
I see that some are available but it is usually just a small amount taken of f . Nothing f ree.
Many hospitals have grants
T here are various charitable organizations that provide grants or AEDs to schools.
We are working with the system's of f ice to purchase additional AEDs
Williamsburg Health Foundation - f or the Historic T riangle of Virignia
35
12. What barriers besides cost would prohibit you from installing
more AEDs in your facility?
Count Response
29 None
19 none
5 unknown
2 Funding
2 Just cost
2 N/A
2 None
2 T raining
2 liability
1 None
1 .
1 Aesthetics
1 All areas are covered.
1 Approval by PWCPS administrators
1 As mentioned purchase expense as well as maintenance expense and labor
resources impact our ability to purchase more units.
1 Being able to have a f ew practice units to ensure my staf f is properly trained.
1 Cost
1 Cost and liability
1 Cost of units and replacement equipment
1 Cost only and maintenance cost
1 Costs
1 Costs f or replacements upon expiration.
36
Count Response
1 Decisions are made by the county and not the individual schools
1 Facility approval main barrier is cost.
1 Fear of liability
1 Financial.
1 Funding f rom our school board.
1 Have no other barriers besides cost
1 Having staf f f who are able to use the equipment correctly and calmly in an
emergency. Also storage and charging of the unit, which would require dedicated
spaces and power supply.
1 Having to get approval f rom admin.
1 I believe that our f acilities are optimally covered; however, if additional grant f unds
were available, we could equipment each of our police vehicles with an AED.
1 I don't believe we need more
1 Inmate population and secure location
1 Just cost.
1 Lawsuits. We had them but took out due to to many companies being sued over
f aulty systems, miss use, and other reasons.
1 Liability and on-going checks/verif ications on the units and actual knowledge if one
was going to use the unit in a real world emergency.
1 N/a
1 NA
1 No additional needed.
1 No barriers other than having the f inancial resources to do it; need about 4 more
f or our f acility
1 No barriers, we have added several AED's and replaced several as well with our own
f unds.
1 No other barriers
37
Count Response
1 None known
1 None, as this is a requirement.
1 None, the school has had AEDs f or f ive years.
1 None.
1 None. Have f ull support f rom Superintendent.
1 None. If cost was covered to purchase additional AEDs in our f acilities, we would do
so. Also on question 8, AED units are purchased through public f unds, which was not
an option in the drop down selection.
1 None. We maintain our inventory using allotted f unds.
1 Not really a need based on size of operation
1 Nothing
1 Nothing else. But like previously mentioned, with the help of public grants, we were
able to add more in the school to helo
1 On a military base
1 Only cost and the actual need f or more.
1 Our lease may require landlord to do this
1 Personnel to oversee maintenance
1 Saf ety
1 Security of the devices
1 Space
1 T he individual departments purchase the equipment.
1 T here are no barriers that I am aware of that would prevent installing more AEDs
38
Count Response
1 T idewater Community College's AED Program is maintained by the Saf ety Program
Coordinator; and having more AEDs would place an even greater responsibility f or
that one person to maintain. Unless an employee is 'designated' as a f irst
responder, and is f ully trained to operate an AED during a lif e threatening medical
emergency, and their position description includes that responsibility, there is the
possibility that the AED, although available f or use, would NOT be used. Having
more AEDs does not guarantee people/employees will use one during a sudden
cardiac arrest (SCA) medical emergency.
1 T ime f or training
1 Upkeep and maintenance to keep units working and up to date.
1 We are currently in the process of adding more AED's Post-wide.
1 We are good with f our
1 We would need the necessary training to properly operate the device
1 We would question the need f or more.
1 actual need
1 adding it to the already established EAP/ PP manual
1 approval f rom HR
1 cost only
1 just cost
1 n/a
1 none
1 only cost
1 permits
1 suitability
1 suitable locations
1 the numbers of clients in our population
1 thef t
39
40
13. In your opinion, is there a need for a larger, smaller, or similar
number of AEDs in your industry? If there is not a need for AEDs,
please note this as well.
Count Response
6 Larger
6 Similar
4 larger
4 similar
3 No
2 Similar
2 no need
2 unknown
2 yes
1 A f ew additional AEDs could be placed in other locations
1 A larger number of AED's are needed.
1 A larger number so there is more coverage
1 Additional AED's are always needed
1 Additional AEDs so there would be one in each building would be helpf ul.
1 An institution of our size should have at least one.
1 Current number is suf f icient
1 Def initely need them in our f acility - need about 4 more
1 Don't know
1 Each school should have the appropriate number needed
1 Every location should have them - it makes sense given their importance and ease
of use.
1 Have not seen the need
41
Count Response
1 I am sure across the VADOC there is an increased need with growing elderly
population and acuity.
1 I believe all hotels should have at least one.
1 I believe our approach of one per f loor per building is adequate
1 I don't believe that there is a need.
1 I f eel one per 300 rooms in a hotel is suf f icient
1 I think all buildings and businesses should have an AED.
1 I think due to the number of f loors in each building on our campus, one unit per
building would provide the coverage needed, currently we have one per f loor
1 I think that each dorm should have a AED, so if an emergency arise it is there
1 I think we need at least two more the way our school is designed but our AED style
is just f ine we all have Phillips
1 I would like to see an AED in every single building and dorm area.
1 Ideally all residence and academic/administration buildings would have a AED unit.
1 In massage therapy, there is a growing client population of elderly clients. Also,
clients with other health issues as well. I believe the industry as a whole would
benef it f rom AED's. Knowing that time is always of the essence we would love to
have an AED here.
1 In my opinion, I believe there should be more AED's available.
1 In my opinion, I would advocate f or additional AEDs in all public buildings and
outdoor recreation f acilities.
1 In my opinion, having one AED per building, and two in buildings having events or
group gatherings is more than adequate. In the nineteen years T CC has had an AED
program, there has not been a single use of an AED during a sudden cardiac arrest
event. We have AED's available as a best practice f or our campuses and our saf ety
and health program f or students, f aculty, staf f and visitors.
1 In my opinion, one AED on each f loor is suf f icient.
1 In our school specif ically, there's a need f or an additional AED on the second f loor -
but overall, our county provides the necessary number of AEDs
1 It varies f rom school district
42
Count Response
1 It would be benef icial to have updated technology when available.
1 Larger
1 Larger 1 AED minimal in each building.
1 Larger need
1 Larger need f or accessibility in times of need.
1 Larger need, due to cosmetology service to general public and post secondary
vocational students.
1 Larger number
1 Larger number of units.
1 Larger number.
1 Larger. Every f acility in my industry should have at a minimum 1 AED located in it.
1 Luckily we haven't had to use ours yet, and it is extremely unlikely that we would
need more than 2 at one time. We believe two is the perf ect number.
1 More AEDs.
1 More would be better in a perf ect world, one per building
1 Most hotels have one located near the f ront desk. Generally I see that as
suf f icient. Larger hotels with meeting space should also have one near the meeting
space.
1 My high school of 2100 students has the most AEDs in the county. T he majority of
the schools have 2, 1 by the main of f ice and 1 with the AT . T he need f or more units
per school is def initely needed.
1 N/A
1 No additional ones needed at this time.
1 No idea
1 No idea.
1 No longer a need as we have added more
43
Count Response
1 No. T he emergency response to a medical event is f ast—within 3 minutes of a 911
call, It would take al test that long to get the equiopment out and in use by
someone who is trained to use it correctly.
1 No. I believe we have an adequate amount.
1 Not a need
1 Not a need at this time.
1 One AED per building would be ideal. T hat would mean an increase of 4 more
1 Penal institutions have a variety of conf igurations. Our f acility with roughly 200 per
housing unit means it makes sense (in my opinion) to have one AED available. On the
other hand a "high rise" jail may want to have an AED on every f loor. I do not know if
the "industry" has enough AEDs overall.
1 Probably 5 or more in each school. You never know when you'll need them and it's
better to have more and need them, than less and not have enough
1 Same
1 Similar number of AEDs
1 Smaller
1 T he campus could always use more AED's throughout
1 T he same or larger
1 T here is a need f or more aeds
1 T here is a request f or larger number--f or example, our "admissions of f ice" has
requested a unit f or their building rather than rely on access to the mobile unit our
campus saf ety staf f have.
1 T here is no need f or AEDs
1 T here is not a need.
1 T here should be an AED in every hotel and restaurant nationwide.
1 T his school could use more.
1 T wo AEDs adequately serve the school that I am the principal at. I f eel some of the
larger school could use more than two.
44
Count Response
1 Unknown
1 Unsure
1 We are happy with the number of AEDs we have f or our campuses.
1 We could always use more AEDS in the f acility
1 We could possibly use one or two more in our bigger f acilities
1 We could use more
1 We have 20 classrooms, we could use a couple of more in the admin building.
1 We have a suf f icient amount
1 We have an adequate amount of AEDs
1 We have enough AED's
1 We have good coverage with their location now
1 We have had our AEDS f or over ten years an4 have never had a medical issue that
required their use. We are a convention center that hosts approximately 400,000
people a year.
1 We have installed additional AEDs as needed and at this time, f eel our locations
are covered.
1 We have not had any tenant press f or these units in our of f ice buildings recently.
1 We have the adequate amount at this time
1 We need a larger number
1 We need more AEDs
1 We would like to have them at our outdoor athletic f ields
1 Would like to have the potential f or more f or bus travels f or athletics.
1 Yes
1 Yes, I f eel there is a need f or a slightly larger number of AED's due to the size of
our school campus.
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Count Response
1 Yes. T here is a larger need because our campuses serve more than just our
immediate community. We host many public events on our campus.
1 larger amount
1 larger need as we have no AEDs located at our outdoor f acilities (athletic f ields). 5
of our 6 AEDs are mounted inside the main school building and 1 is portable and
gets taken to outdoor events.
1 larger number
1 larger, by the f ields
1 maybe 1 more
1 na
1 no additional need f or more aeds at this time
1 no opinion
1 none
1 same
1 similar need
1 smaller
1 we need at least 2 more AED's in building: 1 on second f loor of building, 1 in West
end of building by ROT C, T ech Ed hallway
1 we service a very large school system, so I would assume a larger number of AED's
throughout the county would be warranted.
1 we would need more
1 yes more needed close to all spaces
1 yes, anywhere you have the public and staf f , they are good to have
46
14. For your industry, what do you think would be the most useful
density measurement for AEDs? For example, AED density can be
measured based on occupancy limits, capacity limits, square footage,
number of floors in a building, or number of rooms in a building, and
may differ between indoor and outdoor spaces. Why would this
measurement be helpful for your industry?
Count Response
3 unknown
2 Unknown
1 1 AED per 100 student athletes or max number of spectators per f acility.
1 1 f or each building that has rentable rooms. Nothing f or a parking structure.
1 1 f or each f loor
1 1 f or each on campus athletic f acility, as well as any team that travels. Current
believe we have enough in the high school building.
1 AED density should be measured based on number of occupancy and number of
rooms in a building
1 AED should be within 2 or 3 mins of any location in the school. Near main of f ices &
gyms On Fields On EVERY f loor
1 Access distance in likely usage areas.
1 All needs to be taken into consideration. One could have a large warehouse, sf wise,
with only a couple of occupants so sf would not be a usef ul density measure.
1 Amount of people that attend events or f estivals that we hold. How many AEDs
should be available per events?
1 An AED per building and on our f arm that has the majority of our inmates working
on a daily basis
1 An available AED based on time no f urther away than 1 1/2 minutes would be the
most usef ul measurement f or our f acility.
1 Any of the above would work. I think it would help to have an industry standard
based on any or all of these measurements.
1 Based on a combo of population and per building. If there were a standard like f ire
extinguishers it would help .
47
Count Response
1 Because there are many variables, I do not have an opinion, our college is one per
f loor which to me is to many units f or the square f ootage and number of people on
campus of which are younger and have f ewer health issues
1 Building usage and or f unction (i.e. athletic f acility, dining hall , etc.)
1 By f loor (or space f or outdoors) And one per 5,000 occupancy f or large venues
1 Combination of number of hotel rooms and square f ootage of meeting space. For
example 1 per 150 rooms and 1 per 10,000 square f eet of meeting space.
1 Density of incidences where an AED would have been usef ul seems to be the most
logical.
1 Depending on the location of the business, if there is not an AED in close proximity
it could be benef icial to have one on site
1 Distance and time f or f oot travel should be the measurement.
1 Don't know
1 Due to high volume in our school, with overcrowding as an issue, it is helpf ul f or
these numbers to convey the usef ul help of adding AEDs to our overcrowding
trailers and any more additional space needed.
1 Floors + sq. f ootage + other buildings on campus..
1 Floors and rooms in buildings
1 Floors in a building.
1 For hotels, number of rooms should determine number of AEDs.
1 For our industry, the most usef ul density measurement f or AEDs is based on
square f ootage.
1 Helpf ul inf ormation as this would increase the deployment of AEDs on campus.
1 I believe 3 would be the best density f or our area due to the size of our campus and
locations f or athletics. We would like to have an AED within less than 5 minutes of
all student, f aculty, and staf f . It would help us get our administration on board f or
distributing the f unds.
1 I believe it would be a wonderf ul asset to have at our f acility. Not just f or our
business, but I don't believe some of the surrounding businesses have them either.
Our hours of operations are typically 9am-9pm M-F and we are open on Saturdays
and Sundays as well. We our very f ortunate to also have staf f that are First Aid
and CPR certif ied, including an instructor of First Aid and CPR.
48
Count Response
1 I believe that each f acility, outdoor area, etc. should use multiple variables when
determining their AED needs; however, one of the most important is the assigned
use group, occupancy loads, f acility uses (i.e. classrooms, productions, athletic
events, etc.), as well as coordination with local emergency services to determine
average response time, response capabilities, etc.
1 I believe there should be a policy stating, f or example, An AED should be located on
each f loor of a building and accessible within 1 min.
1 I do not know
1 I don't know
1 I f eel square f ootage and the number of f loors in a school building should be the
determining f actor in the number of AEDs needed.
1 I operate hotels and I have 1 per hotel. Our ability to use elevators to respond to an
emergency make response to an emergency relatively quick in my opinion.
1 I see it being very arbitrary. T hey are only usef ul if someone is available to use it.
With campus security, athletic training, and student health having access to them, I
believe the coverage is already ample.
1 I think AEDs per building is the best measurement
1 I think a density of one unit per 50 people.
1 I think i depends upon the f loor space. Can you quickly reach one located in a central
area, or is it a hike? If the latter, than two or more units make more sense.
1 I think it's at least 1 per building, and if multiple f loors one per f loor as well.
Quicker and easier access the better chance of saving someone
1 I think one has to consider both the population and conf iguration of a jail/prison.
Some f acilities are "sprawling" and even though the population may be low, having
an AED in each housing unit is likely a wise choice. I think a f ormula that took into
account proximity and population may work best.
1 I would do it based on number of f loors and rooms per f loor. You could not do just
one or the other, mostly because every hotel has a dif f erent number of rooms per
f loor. You also wouldn't want to take one up or down more than 5 f lights.
1 I would like to see an AED in every building and dorm area.
1 I would suggest 3-4 per f loor in common areas
1 Inmates are in dif f erent classrooms.
49
Count Response
1 It may help f or Security to have access to the AED in the dormitories. T hey are
of ten onsite and are the reporting staf f when an emergency occurs.
1 It would not
1 Measurements might be helpf ul, but we would hate to see mandates to cover
certain density measures. We cannot invest every year in new units. Upkeep is a
f actor as well as each unit requires $250-$800 of maintenance every 4 years.
1 Minimum of 1 AED on every f loor
1 Not helpf ul f or us. I am at a school
1 Not sure
1 Number of AEDs compared to the number of patients, staf f , and visitors present
1 Number of f loors and occupancy
1 Number of f loors. You should not have to run up or down stairs looking f or an AED.
1 Number of inmates per AED.
1 Number of rooms
1 Number of rooms in a f acility, and how quickly those areas (inside and out) could be
accessed through Security. Data collected would include the timeliness of reaching
an individual f rom the f irst notif ication, route taken, barrier identif ication, trained
staf f availability and patient outcome, to name a f ew necessary f or proper review
of quality of care and necessity of equipment.
1 Number of rooms or inmates, some areas are more populated than others.
1 Number of rooms would be the best measure f or the number of units.
1 Occupancy Amount of use of the f acility Population density Population age and
health Intended use of the building (gym, etc)
1 Occupancy Limits
1 Occupancy limits
1 Occupancy limits - we have a large campus but small number of students
1 Occupancy limits/capacity limits would be usef ul as we have f acilities of various
sizes
50
Count Response
1 One in each building f or quicker retrieval when needed.
1 One on each f loor
1 One per building would be ideal, so if an emergency happens the AED would be
available f aster.
1 One per f loor works best of our density
1 Placement is important so that everyone practicing has close access
1 Population density
1 Pref er to have one on each f loor.
1 Probably it would be usef ul.
1 Several measurements should be taken into consideration. Occupancy limits can
play a role, not just f or classroom space, but also with event space (i.e.
auditoriums). Square f ootage and number of f loors in a building may also play a
role f or quick access to an AED. T he f arther you have to go to retrieve an AED, the
higher risk of the patient not making it. T his isn't necessarily just measurements
f or higher education, but f or any f acility.
1 Square Footage
1 Square f ootage
1 Square f ootage and capacity. Our AEDs are primarily located in schools and their
locations are based on relative time required to travel f rom a given point in the
building to the nearest AED and back.
1 Square f ootage and number of athletic venues
1 Square f ootage and number of f loors, also amenity areas in the property (f itness)
1 Square f ootage and occupancy limit
1 Square f ootage and usage of building
1 Square f ootage, f loors, and rooms. Helpf ul to determine need of AEDs.
1 Square f ootage. T his would help in making sure the building is covered f or access to
AED
1 Square f ootage/ size. Number of f loors. You don't need them of ten, but when you
do it needs to be handy—nearby
51
Count Response
1 T he number of AED's provided in any industry should be based on the statistics
maintained by the American Heart Association f or the number of sudden cardiac
arrest (SCA) events that occur within a specif ic North American Industry
Classif ication System (NAICS) code. Building occupancy rates, number of f loors,
rooms etc., in my opinion, would result in an overabundance of AED's, and theref ore,
a higher f inancial burden on a state institution of higher education where f unding is
already limited based upon student enrollment which has declined since 2012.
1 T he number of f loors and square f ootage all contribute to the response time.
Distance f rom outdoor venues is also a f actor.
1 T he number of f loors in a building is a usef ul measurement f or AEDs.
1 T his measurement should be based on the number of inmates/staf f and the
physical set up of the f acility. T his measurement would help standardize our AED
processes across the VADOC.
1 T ime to retrieve AED f rom each location, less than 2 min.
1 T o make sure each housing area has an AED on site
1 Unknown
1 Use of a measurement f ormula would be extremely usef ul f or our secondary
education f acilities
1 We have several hallways that act as wings f or subject areas. It would help to have
one on each major hallway.
1 Would need guidance f rom medical community in regard to the timing of using the
device on someone to f igure out f rom every location in the f acility where one was
needed to meet that timeline.
1 Would suggest having at least one per building
1 Yes, I think it would be benef icial to determine a number of AED's needed based on
square f ootage, number of f loors and the number/ratio of AED's between our
indoor and outdoor activities.
1 Yes, to set a standard of number and locations
1 capacity
1 capacity limits, square f ootage
1 density of the number of athletes to number of AEDs would be very telling
1 distance and not density
52
Count Response
1 distance/time to go get AED and return to area where it's needed.
1 na
1 no clue
1 no opinion
1 not sure
1 number of f loors in a building
1 number of f loors, occupancy limits, and square f ootage
1 number of people in the building
1 number of rooms in a building
1 occupancy
1 occupancy limits
1 occupancy limits per f loor
1 occupancy type and f loors
1 occupancy. should be placed where highest traf f ic is
1 occupancy/capacity limits
1 should be occupancy?
1 sq f t and indoor and outdoor venues/ accessibility
1 square f ootage, due to the amount of time it takes to get to one area to another
1 square f ootage... need to have enough of them to be in places that are easy to get
to. Not enough in a large space could lead to not being to get proper help on time
1 two per f loor
1 unsure
1 would allow us to provide administrators the inf ormation to f ight f or more AED's
53
Appendix B: Item 116 of HB 30 (2020)
54
VIRGINIA STATE BUDGET
2020 Session
Budget Bill - HB30 (Chapter 1289)
Bill Order » Office of Commerce and Trade » Item 116
Department of Housing and Community Development
Item 116 First Year - FY2021 Second Year - FY2022
Regulation of Structure Safety (56200) $2,981,943 $2,981,943
State Building Code Administration (56202) $2,981,943 $2,981,943
Fund Sources:
General $517,160 $517,160
Special $2,164,783 $2,164,783
Dedicated Special Revenue $300,000 $300,000
Authority: Title 15.2, Chapter 9; Title 27, Chapters 1, 6, and 9; Title 36, Chapters 4, 4.1, 4.2, 6, and 8; Title 58.1,
Chapter 36, Article 5; and Title 63.2, Chapter 17, Code of Virginia.
A. The Department of Housing and Community Development shall establish a workgroup to study the ideal
Automated External Defibrillator (AED) density in commercial and residential buildings. The Department shall
report its findings to the Chairs of the House Appropriations Committee and the Senate Finance and
Appropriations Committee on or before November 1, 2021.
55
Appendix C: Chapter 978 of the 2003 Virginia Acts of Assembly
56
VIRGINIA ACTS OF ASSEMBLY -- 2003 RECONVENED SESSION
CHAPTER 978
An Act to amend and reenact § 8.01-225 of the Code of Virginia, and to repeal § 32.1-111.14:1 of the
Code of Virginia, relating to eliminating the requirement for registration of automated external
defibrillators; public-access defibrillation.
[H 1860]
Approved April 2, 2003
Be it enacted by the General Assembly of Virginia:
1. That § 8.01-225 of the Code of Virginia is amended and reenacted as follows:
§ 8.01-225. Persons rendering emergency care, obstetrical services exempt from liability.
A. Any person who:
1. In good faith, renders emergency care or assistance, without compensation, to any ill or injured
person at the scene of an accident, fire, or any life-threatening emergency, or en route therefrom to any
hospital, medical clinic or doctor's office, shall not be liable for any civil damages for acts or omissions
resulting from the rendering of such care or assistance.
2. In the absence of gross negligence, renders emergency obstetrical care or assistance to a female in
active labor who has not previously been cared for in connection with the pregnancy by such person or
by another professionally associated with such person and whose medical records are not reasonably
available to such person shall not be liable for any civil damages for acts or omissions resulting from
the rendering of such emergency care or assistance. The immunity herein granted shall apply only to the
emergency medical care provided.
3. In good faith and without compensation, administers epinephrine to an individual for whom an
insect sting treatment kit has been prescribed shall not be liable for any civil damages for ordinary
negligence in acts or omissions resulting from the rendering of such treatment if he has reason to
believe that the individual receiving the injection is suffering or is about to suffer a life-threatening
anaphylactic reaction.
4. Provides assistance upon request of any police agency, fire department, rescue or emergency
squad, or any governmental agency in the event of an accident or other emergency involving the use,
handling, transportation, transmission or storage of liquefied petroleum gas, liquefied natural gas,
hazardous material or hazardous waste as defined in § 18.2-278.1 or regulations of the Virginia Waste
Management Board shall not be liable for any civil damages resulting from any act of commission or
omission on his part in the course of his rendering such assistance in good faith.
5. Is an emergency medical care attendant or technician possessing a valid certificate issued by
authority of the State Board of Health who in good faith renders emergency care or assistance whether
in person or by telephone or other means of communication, without compensation, to any injured or ill
person, whether at the scene of an accident, fire or any other place, or while transporting such injured or
ill person to, from or between any hospital, medical facility, medical clinic, doctor's office or other
similar or related medical facility, shall not be liable for any civil damages for acts or omissions
resulting from the rendering of such emergency care, treatment or assistance, including but in no way
limited to acts or omissions which involve violations of State Department of Health regulations or any
other state regulations in the rendering of such emergency care or assistance.
6. Has attended and successfully completed a course in cardiopulmonary resuscitation which has been
approved by the State Board of Health Who, In good faith and without compensation, renders or
administers emergency cardiopulmonary resuscitation, cardiac defibrillation, including, but not limited to,
the use of an automated external defibrillator, or other emergency life-sustaining or resuscitative
treatments or procedures which have been approved by the State Board of Health to any sick or injured
person, whether at the scene of a fire, an accident or any other place, or while transporting such person
to or from any hospital, clinic, doctor's office or other medical facility, shall be deemed qualified to
administer such emergency treatments and procedures and shall not be liable for acts or omissions
resulting from the rendering of such emergency resuscitative treatments or procedures.
7. In compliance with § 32.1-111.14:1 registers an automated external defibrillator for use at the
scene of an emergency, Operates a registered an automated external defibrillator at the scene of an
emergency, trains individuals to be operators of registered automated external defibrillators, or orders
automated external defibrillators which are subsequently registered, shall be immune from civil liability
for any personal injury that results from any act or omission in the use of a registered an automated
external defibrillator in an emergency where the person performing the defibrillation acts as an ordinary,
reasonably prudent person would have acted under the same or similar circumstances, unless such
personal injury results from gross negligence or willful or wanton misconduct of the person rendering
such emergency care.
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8. Is a volunteer in good standing and certified to render emergency care by the National Ski Patrol
System, Inc., who, in good faith and without compensation, renders emergency care or assistance to any
injured or ill person, whether at the scene of a ski resort rescue, outdoor emergency rescue or any other
place or while transporting such injured or ill person to a place accessible for transfer to any available
emergency medical system unit, or any resort owner voluntarily providing a ski patroller employed by
him to engage in rescue or recovery work at a resort not owned or operated by him, shall not be liable
for any civil damages for acts or omissions resulting from the rendering of such emergency care,
treatment or assistance, including but not limited to acts or omissions which involve violations of any
state regulation or any standard of the National Ski Patrol System, Inc., in the rendering of such
emergency care or assistance, unless such act or omission was the result of gross negligence or willful
misconduct.
9. Is an employee of a school board, authorized by a prescriber and trained in the administration of
insulin and glucagon, who, upon the written request of the parents as defined in § 22.1-1, assists with
the administration of insulin or administers glucagon to a student diagnosed as having diabetes who
requires insulin injections during the school day or for whom glucagon has been prescribed for the
emergency treatment of hypoglycemia shall not be liable for any civil damages for ordinary negligence
in acts or omissions resulting from the rendering of such treatment if the insulin is administered
according to the child's medication schedule or such employee has reason to believe that the individual
receiving the glucagon is suffering or is about to suffer life-threatening hypoglycemia. Whenever any
employee of a school board is covered by the immunity granted herein, the school board employing him
shall not be liable for any civil damages for ordinary negligence in acts or omissions resulting from the
rendering of such insulin or glucagon treatment.
B. Any licensed physician serving without compensation as the operational medical director for a
licensed emergency medical services agency in this Commonwealth shall not be liable for any civil
damages for any act or omission resulting from the rendering of emergency medical services in good
faith by the personnel of such licensed agency unless such act or omission was the result of such
physician's gross negligence or willful misconduct.
Any person serving without compensation as a dispatcher for any licensed public or nonprofit
emergency services agency in this Commonwealth shall not be liable for any civil damages for any act
or omission resulting from the rendering of emergency services in good faith by the personnel of such
licensed agency unless such act or omission was the result of such dispatcher's gross negligence or
willful misconduct.
Any individual, certified by the State Office of Emergency Medical Services as an emergency
medical services instructor and pursuant to a written agreement with such office, who, in good faith and
in the performance of his duties, provides instruction to persons for certification or recertification as a
certified basic life support or advanced life support emergency medical services technician shall not be
liable for any civil damages for acts or omissions on his part directly relating to his activities on behalf
of such office unless such act or omission was the result of such emergency medical services instructor's
gross negligence or willful misconduct.
Any licensed physician serving without compensation as a medical advisor to an E-911 system in
this Commonwealth shall not be liable for any civil damages for any act or omission resulting from
rendering medical advice in good faith to establish protocols to be used by the personnel of the E-911
service, as defined in § 58.1-3813.1, when answering emergency calls unless such act or omission was
the result of such physician's gross negligence or willful misconduct.
Any licensed physician who directs the provision of emergency medical services, as authorized by
the State Board of Health, through a communications device shall not be liable for any civil damages
for any act or omission resulting from the rendering of such emergency medical services unless such act
or omission was the result of such physician's gross negligence or willful misconduct.
Any licensed physician serving without compensation as a supervisor of a registered an automated
external defibrillator in this Commonwealth shall not be liable for any civil damages for any act or
omission resulting from rendering medical advice in good faith to the registrant owner of the automated
external defibrillator relating to personnel training, local emergency medical services coordination,
protocol approval, automated external defibrillator deployment strategies, and equipment maintenance
plans and records unless such act or omission was the result of such physician's gross negligence or
willful misconduct.
C. Any provider of telecommunication service, as defined in § 58.1-3812, including mobile service,
in this Commonwealth shall not be liable for any civil damages for any act or omission resulting from
rendering such service with or without charge related to emergency calls unless such act or omission
was the result of such service provider's gross negligence or willful misconduct.
Any volunteer engaging in rescue or recovery work at a mine or any mine operator voluntarily
providing personnel to engage in rescue or recovery work at a mine not owned or operated by such
operator, shall not be liable for civil damages for acts or omissions resulting from the rendering of such
rescue or recovery work in good faith unless such act or omission was the result of gross negligence or
willful misconduct.
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D. Nothing contained in this section shall be construed to provide immunity from liability arising out
of the operation of a motor vehicle.
For the purposes of this section, the term "compensation" shall not be construed to include (i) the
salaries of police, fire or other public officials or personnel who render such emergency assistance, (ii)
the salaries or wages of employees of a coal producer engaging in emergency medical technician service
or first aid service pursuant to the provisions of §§ 45.1-161.38, 45.1-161.101, 45.1-161.199 or
§ 45.1-161.263, (iii) complimentary lift tickets, food, lodging or other gifts provided as a gratuity to
volunteer members of the National Ski Patrol System, Inc., by any resort, group or agency, or (iv) the
salary of any person who, in compliance with § 32.1-111.14:1, (a) registers owns an automated external
defibrillator for the use at the scene of an emergency, (b) trains individuals, in courses approved by the
Board of Health, to operate registered automated external defibrillators at the scene of emergencies, (c)
orders automated external defibrillators for subsequent registration and use at the scene of emergencies,
or (d) operates, in accordance with the training required by § 32.1-111.14:1, a registered an automated
external defibrillator at the scene of an emergency.
For the purposes of this section, an emergency medical care attendant or technician shall be deemed
to include a person licensed or certified as such or its equivalent by any other state when he is
performing services which he is licensed or certified to perform by such other state in caring for a
patient in transit in this Commonwealth, which care originated in such other state.
Further, the public shall be urged to receive training on how to use cardiopulmonary resuscitation
(CPR) and an automated external defibrillator (AED) in order to acquire the skills and confidence to
respond to emergencies using both CPR and an AED.
2. That § 32.1-111.14:1 of the Code of Virginia is repealed.
3. That an emergency exists and this act is in force from its passage.
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