In our October 16, 2026, blog, Key Updates in ANSI/ISEA Standard Z308.1-2026: What You Need to Know About Workplace First Aid Kits, we discussed that the updated standard includes the opioid antagonist naloxone as a supplemental first aid kit supply. OSHA has also issued guidance on preparing for and responding to opioid overdoses, but it does not create a federal requirement to maintain opioid antagonists in the workplace.
In New York State (NYS), a Labor Law will take effect on December 12, 2026, that will require that U.S. Food and Drug Administration (FDA) approved opioid antagonists, such as naloxone or nalmefene, be available in the workplace if the employer is required to have first aid supplies onsite. According to OSHA’s Medical Services and First Aid Standard (29 CFR 1910.151(b)), private employers must have adequate first aid supplies available and one or more employees that are trained to render first aid, when a clinic, infirmary, or hospital is not in near proximity to the workplace. In a letter of interpretation, OSHA clarifies the term near proximity to mean that emergency care generally must be available within no more than three to four minutes.
On September 23, 2026, a proposed rule was published in the NYS Register that outlines requirements related to workplace opioid antagonists, including their quantity and placement and employer training obligations to ensure proper use. The NYS Department of Labor is accepting public comments on the proposed rulemaking until November 22, 2026. They may be submitted by email to [email protected].
Quantity and Placement of Opioid Antagonists
The proposed rule states that a sufficient quantity of opioid antagonists must be available in the workplace. A fixed minimum quantity is not established because factors including the number of employees, the presence of workers considered to have an elevated risk, and the size and physical layout of the facility must be considered. Opioid antagonists must be in easily accessible areas, and employees generally should not have to travel through several doorways, hallways, or stairways to access them. In addition, the proposed rule generally advises against locating the primary opioid antagonist supply in a locked room or restricted-access area. An employer may use such a location when there is a reasonable security concern, but it must take measures to ensure the medication can be accessed quickly. Employees must also be informed of each storage location.
Training Requirements
The proposed rule states that there must be at least one employee in the workplace during business hours who is trained to administer opioid antagonists, although multiple trained employees are encouraged. Training must address the following topics:
- Recognizing the symptoms of an opioid overdose
- Administering an opioid antagonist
- Taking appropriate emergency response steps, including contacting first responders
- Understanding how New York’s Good Samaritan protections in the Public Health Law apply to opioid antagonist administration
Free and low-cost training options are available from state and local agencies. The NYS Office of Addiction Services and Supports (OASAS) has free online training. New York City’s Department of Health and Mental Hygiene (DOHMH) also has free virtual training sessions. In addition, the NYS Department of Health (NYSDOH) has a list of training events by region.
While the proposed rule does not establish recordkeeping requirements, retaining copies of employee training certificates is recommended as best practice.
Other Requirements
Opioid antagonists must remain sealed in their original packaging and be stored with the manufacturer’s instructions. If those are unavailable, instructions from the NYSDOH or the NYC DOHMH may be used instead. The opioid antagonist supply must be regularly inspected to ensure the medicine has not expired and has not been tampered with, removed, or otherwise missing. Employers must also properly dispose of used or expired opioid antagonists and replace used supplies as soon as possible.
Opioid overdose prevention is critical and should be addressed in workplaces, homes, and communities. For more information and additional resources, please visit the NYSDOH’s Opioid Overdose Prevention Program website.
Safety Partners can help your organization understand the proposed New York requirements for opioid antagonists and assess how they may affect your workplace first aid program, including training, inspection, and maintenance practices. Contact us to learn more.
This blog was written by Rae Moore, Senior Quality, Research, and Training Specialist at Safety Partners.
