Beginning December 12, 2026, certain New York employers must make opioid antagonists (medications that block the effects of opioids and can reverse opioid overdose), such as naloxone or Narcan, available at their workplaces. The requirement arises from legislation signed by Governor Kathy Hochul in December 2025 and amended in February 2026.
As amended, New York Labor Law § 27-f applies to employers that federal law requires keep first aid supplies readily available to treat injured employees. Under OSHA regulations, an employer generally must maintain readily available first aid supplies when no infirmary, clinic, or hospital is in “near proximity” to the workplace. OSHA has interpreted “near proximity” to mean that emergency medical services generally should be available within three to four minutes.
Section 27-f directs the New York State Department of Labor, in coordination with the Department of Health, to regulate the number, maintenance, training, and use of opioid antagonists in covered workplaces. The Department of Labor published proposed regulations on September 23, 2026. The public comment period closes on November 22, 2026. If adopted, the rules would clarify employers’ obligations concerning the quantity, storage, accessibility, administration, and maintenance of opioid antagonists.
Under the proposed rules, a covered employer would need to maintain a “sufficient number” of opioid antagonists at each workplace. The appropriate supply would depend on the site’s size and layout, the number of workers and other individuals present, access by populations at higher risk of overdose, the nature of the work, and any history of suspected workplace overdoses. Employers would need to store the medication in an easily accessible location, avoid unnecessary access restrictions, and advise employees where it is kept. Each dose would also need to remain sealed in its original packaging with the manufacturer’s instructions.
The proposed rules would also require that at least one trained employee be present at each workplace during business hours. Training would cover recognizing a suspected overdose, administering the medication, contacting emergency medical services, following pre- and post-administration procedures, and understanding applicable Good Samaritan protections. Employers would need to inspect their supplies regularly and promptly replace any medication that is expired, missing, damaged, tampered with, or used.
Before the law takes effect, employers should determine whether Section 27-f applies to each workplace and assess the quantity and placement of opioid antagonists needed at each location. Covered employers should also identify and train employee volunteers, establish procedures for inspecting and replacing supplies, and inform all employees where the medication is stored. Because the regulations remain proposed, employers should monitor the rulemaking process and be prepared to adjust their compliance plans when final regulations are issued.
