Some New York employers will need to add naloxone to their workplace safety preparations. New Labor Law § 27-f, effective December 12, 2026, requires covered employers to have an opioid antagonist available for first aid or emergency treatment in the workplace. The New York State Department of Labor (NYDOL) has proposed regulations explaining how employers must comply.
Which Employers Are Covered?
The law does not apply to every New York employer. It applies only to private employers that federal Occupational Safety and Health (OSHA) standards require to have first-aid supplies readily available for injured employees. The proposed NYDOL regulations tie coverage specifically to workplaces subject to the first-aid requirements of 29 C.F.R. § 1910.151.
Public employers (the State, counties, cities, towns, school districts, etc.) are excluded.
As a practical matter, the law is likely to reach many industrial, manufacturing, construction, warehouse, and other workplaces where federal OSHA standards require first-aid supplies to be readily available. Coverage of ordinary office, retail, and similar workplaces may depend on the employer’s particular obligations under OSHA standards, including whether an infirmary, clinic, hospital, or other emergency medical response is available in sufficiently close proximity to the workplace.
What Will Employers Have to Do?
The proposed regulations would require covered employers to maintain a sufficient number of opioid antagonists to allow a quick response to a suspected overdose.
Rather than establishing a specific number, NYDOL proposes a flexible standard. Employers should consider factors such as:
- the size and layout of the workplace;
- the number of people who work at or access the workplace;
- whether the workplace includes populations at heightened risk of opioid overdose;
- whether the nature of the work creates a greater-than-average risk; and
- whether suspected overdoses have previously occurred at the workplace.
For most employers, the opioid antagonist will likely be naloxone, commonly known by the brand name Narcan.
Naloxone Must Be Easily Accessible
The proposed regulations emphasize that opioid antagonists must be readily accessible in an emergency. Employers generally should not place them in locked rooms or locations that would require a responder to travel through multiple hallways, doorways, or stairways. NYDOL suggests considering placement near AEDs or other first-aid supplies.
Employers must also tell employees where opioid antagonists are located.
At Least One Trained Employee Must Be Present
One of the most significant requirements in the proposed NYDOL regulations concerns training.
As proposed, employers must ensure that at least one employee who has completed training in administering opioid antagonists is present during business hours. Employers are encouraged to recruit employee volunteers for training and may choose to train all employees.
Training should address how to recognize an opioid overdose, how to administer the medication, when to contact emergency responders, and applicable Good Samaritan protections.
Employers Must Monitor Their Supply
Compliance will require more than simply purchasing naloxone and placing it in the workplace.
The regulations require employers to inspect their supply regularly to ensure that opioid antagonists have not expired, been tampered with, removed, or gone missing.
When multiple employers share a workplace, the proposed regulations would allow them to comply jointly, provided they document their shared compliance plan.
What Should Employers Do Now?
The proposed regulations are subject to a 60-day comment period and could change before adoption, but the underlying statute will take effect on December 12, 2026. Thus, employers should begin determining whether Labor Law § 27-f applies to their workplaces.
Covered employers should begin planning to:
- obtain an appropriate supply of naloxone or another approved opioid antagonist;
- select accessible storage locations;
- inform employees where the medication is located;
- arrange employee training sufficient to maintain coverage during business hours; and
- establish a process for regularly inspecting and replacing the supply.
The proposed regulations make clear that New York intends workplace opioid-antagonist availability to be an ongoing safety obligation, not simply another item to add to a first-aid kit.
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