Audit Report On The Placement Of Automated External Defibrillators By The Department Of Parks And Recreation

In March 2005, the New York City Council enacted Local Law 20, which addressed the incidence of sudden cardiac arrest outside medical settings. One requirement of the law was the placement of automated external defibrillators (AEDs) in public places where they would be accessible and available for use when needed. The law specifically required that the Department of Parks and Recreation (Parks) place AEDs in selected City-operated parks throughout the five boroughs.

When properly used, an AED performs an analysis of the heart rhythm, determines if defibrillation is required, and delivers an electrical shock if needed. AEDs make possible the use of defibrillators in the community by non-medical personnel. The New York City Department of Health and Mental Hygiene (DOHMH) issued rules to implement Local Law 20 in November 2005. Local Law 20 and the DOHMH rules require that AEDs be acquired and operated in accordance with New York State Public Health Law §3000-b, that personnel be trained in their use, and that the devices be registered with the Regional Emergency Medical Services Council of New York City, Inc. (REMSCO) before use by non-health care professionals.

The audit determined whether Parks is in compliance with Local Law 20 and other State laws and regulations regarding the placement of AEDs in specific parks.

Audit Findings and Conclusions

Parks was not in full compliance with Local Law 20. Although Parks complied with the law regarding the placement of AEDs in its facilities, it did not comply with certain other key aspects of the law.

As required by the law, Parks established rules identifying at least six sites under its jurisdiction within each of the five boroughs that was designated a public place in which to place an AED. Parks not only reported placing AEDs at the identified sites in accordance with the law, but placed additional AEDs in other parks and recreational facilities. Also, Parks correctly filed with the Regional Emergency Medical Services Council of New York City, Inc. (REMSCO) its notice of intent to provide public access defibrillation and its collaborative agreement.

However, Parks did not comply with certain aspects of Local Law 20, including preparing Site-Specific Response Plans with all required information for each AED site, maintaining and testing the AEDs in accordance with manufacturer standards, and adequate placement of the required signage. In addition, Parks did not always ensure that the required AED supplies were available and not expired and that a trained first responder was present during operating hours. We believe these deficiencies existed due in large part to inadequacies of the AED oversight inspections that are performed by the AED Program Coordinator and Operations and Management Planning (OMP) unit. The oversight inspections were not always performed as required by Parks, and those that were performed were not always completed accurately nor did they cover all of the law’s key requirements. Further, there does not appear to be any follow-up of noncompliant conditions identified during these AED oversight inspections. Moreover, Parks did not register all of its AEDs with REMSCO as required.

Audit Recommendations

Based on our findings, we make 15 recommendations, including that Parks should:

• Ensure that the Site-Specific Response Plans are prepared for all its facilities that have AEDs and that all the required information and details are included in each plan.
• Ensure the each facility maintains its AEDs in accordance with the manufacturer’s recommended maintenance procedures and that the maintenance steps taken are documented, including any problems encountered and the corrective actions taken. The maintenance procedures should include daily inspections of the AED status indicator to verify that the units are operational.
• Ensure that each facility inspects the AED supplies on a monthly basis, including the expiration dating of the batteries and defibrillation pads, and order any needed supplies in a timely fashion in order to receive them prior to the expiration of the existing ones.
• Ensure that all required AED signage is placed in its facilities and that all of the required information is included on the signs, such as the telephone number to contact a trained first responder on the signs placed on all publicly accessible floors.
• Ensure that a trained first responder is on site at each of its facilities during all hours of operation.
• Ensure that AED oversight inspections of all its AED facilities are performed by both the AED Program Coordinator and by OMP unit personnel, as required by Parks procedures and that the AED Audit Datasheets are completed properly.
• Follow up and document the follow-up of any noncompliant conditions identified during the AED oversight inspections.
• Ensure that it registers all of its AEDs with REMSCO prior to installing them in its facilities.