ARTICLE
5 October 2026

OSHA Highlights Workplace Opioid Overdose Preparedness

JL
Jackson Lewis P.C.

Contributor

Focused on employment and labor law since 1958, Jackson Lewis P.C.’s 1,100+ attorneys located in major cities nationwide consistently identify and respond to new ways workplace law intersects business. We help employers develop proactive strategies, strong policies and business-oriented solutions to cultivate high-functioning workforces that are engaged, stable and diverse, and share our clients’ goals to emphasize inclusivity and respect for the contribution of every employee.
Federal guidance from OSHA now encourages employers to stock opioid reversal medications like naloxone in the workplace and train employees to recognize and respond to overdose emergencies. While the recommendations don't create new compliance obligations, some states are already mandating these preparations, raising questions about how organizations should adapt their emergency response protocols.
United States Employment and HR

Employers have new federal guidance to help them recognize and respond to opioid overdoses at work. On Sept. 24, 2026, the Occupational Safety and Health Administration (OSHA) released a fact sheet supporting the Trump Administration’s Great American Recovery Initiative.

The fact sheet, “Opioid Overdose Rescue with Reversal Medications,” encourages employers to consider keeping medications such as naloxone or nalmefene available in the workplace. It does not impose new compliance requirements.

Preparing the Workplace

OSHA’s recommendations address both access to medications and employee readiness:

  • Placement and storage: Keep medications in visible, accessible locations, such as alongside automated external defibrillators or first aid kits, and follow product storage instructions.
  • Supply management: Monitor expiration dates, ensure medications are properly stored and replenished, and assign someone to manage the supply.
  • Employee training: Consider creating a voluntary training program on recognizing overdose symptoms, administering the available medication, and safely positioning the individual while waiting for emergency responders.

OSHA indicates that potential overdose symptoms include slow or stopped breathing, blue lips, pinpoint pupils, and unresponsiveness. Responders should call 911 immediately, even if the individual regains consciousness after receiving medication. According to the fact sheet, the medications’ effects are temporary, additional doses may be necessary, and emergency medical care remains essential.

Employer Considerations

Employers may consider using OSHA’s guidance to evaluate their emergency response procedures, medication supplies, and training needs.

State requirements also warrant attention. For example, beginning Dec. 12, 2026, New York law requires private employers subject to federal OSHA first aid supply requirements to have an opioid antagonist available for workplace first aid or emergency treatment. California also enacted two measures addressing opioid antagonists in the workplace. Assembly Bill 1976 directs Cal/OSHA to develop regulations that would require workplace first-aid materials to include naloxone or another FDA-approved opioid antagonist, while Assembly Bill 2150 requires employers that mandate CPR certification for employees to also require those employees, subject to certain exceptions, to complete approved naloxone-use training.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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