Narcan in the Workplace: Is It Required, Who Needs It and What Training Do Employers Need?

Author: Tara Crisp

For decades, workplace first-aid planning has centered on injuries traditionally associated with work: cuts, burns, falls, electrical injuries, cardiac events and trauma. Employers increasingly need to add another potential emergency to that planning: opioid overdose.

In September 2026, the Occupational Safety and Health Administration released guidance titled Opioid Overdose Rescue with Reversal Medications. OSHA encourages employers to consider keeping opioid overdose reversal medications, including naloxone, commonly known by the brand name Narcan, readily available and training employees to recognize and respond to an overdose.^{1, 2}

That raises an important question: Is Narcan now required at every workplace? The short answer is no under the current federal OSHA framework. The longer answer is more important for multistate employers and industries such as trucking, construction, oil and gas, manufacturing and field services.

OSHA guidance is not the same as an OSHA standard

OSHA's September 2026 publication is guidance rather than a new federal standard. The publication expressly states that it doesn't impose new compliance requirements. Employers should not interpret the guidance to mean that federal OSHA suddenly requires Narcan in every first-aid kit.

OSHA is, however, elevating opioid-overdose preparedness as a workplace safety issue. The agency recommends keeping FDA-approved opioid reversal medications, such as naloxone or nalmefene, accessible; placing them in visible locations near first-aid kits or AEDs; and educating employees about overdose recognition and response.

What about state requirements?

There is no single uniform nationwide workplace Narcan requirement. Employers must evaluate the laws and regulations in each jurisdiction where they operate because availability laws, Good Samaritan protection, employer mandates and training obligations aren't the same thing.

New York

New York Labor Law § 27-f takes effect December 12, 2026. It requires certain private employers that must maintain first-aid supplies under federal occupational-safety requirements to have an opioid antagonist available at the workplace. The law also calls for implementing regulations addressing matters such as quantities, training and use. Employers should confirm how the statute and any implementing guidance apply to each location.

California

California has directed its occupational-safety authorities to develop standards addressing naloxone or another FDA-approved opioid antagonist in workplace first-aid materials. Employers should monitor Cal/OSHA rulemaking and confirm when any final requirements become effective.^5,6

What about trucking companies?

For a trucking company, asking whether Narcan belongs at "the workplace" misses part of the exposure. The workplace may include:

• Terminals and dispatch locations
• Maintenance shops and warehouses
• Commercial motor vehicles
• Customer facilities and loading docks
• Remote roadside locations

A long-haul driver may be hundreds of miles from the company's physical facility. A multistate motor carrier may also cross jurisdictions daily. For that reason, the company's review should address not only the law of its headquarters state, but also fixed facilities, recurring operations and applicable requirements in other states.

A practical fleet assessment should consider where naloxone would be accessible, how temperature and storage requirements would be managed in vehicles, who would be trained, how expiration dates would be monitored, and how the response protocol would remain separate from DOT drug-and-alcohol testing obligations.

What about oilfield and energy operations?

For oil and gas companies, emergency-response planning can present an even stronger operational case. Relevant locations may include:

• Drilling and well-servicing locations
• Production sites and tank batteries
• Compressor stations and pipeline operations
• Fabrication yards and maintenance facilities
• Remote construction and field-service locations

The critical operational question isn't simply whether a regulation uses the word "Narcan." Employers should also evaluate how quickly emergency medical services can reach the site, whether crews work alone or remotely, what medical-response resources already exist, and how naloxone would integrate with first aid, AEDs, rescue planning and emergency communications.

What training should a workplace program include?

If an employer elects or is required to provide an opioid overdose reversal medication, placing medication in a cabinet isn't a complete emergency-response program. OSHA's 2026 guidance identifies training topics employers should consider:

• Recognizing signs of a possible opioid overdose, including slow or stopped breathing, unresponsiveness, pinpoint pupils, blue lips, gurgling or snoring sounds, and cold or clammy skin
• Calling 911 and activating the site's emergency-response process. Emergency services should be called whenever an opioid overdose is suspected, even if naloxone has been administered and the person appears to improve
• Understanding the specific reversal medication available at the workplace
• Knowing how to administer that product correctly
• Understanding that an additional dose may be necessary
• Recognizing that withdrawal symptoms may occur after administration
• Following the product instructions and emergency-dispatch guidance while waiting for emergency medical services
• Understanding applicable state Good Samaritan and naloxone-access protections
• Treating the affected person respectfully and protecting medical privacy
• Following the company's post-incident reporting, replacement, and review process

OSHA presents this training as recommended preparedness, not a new universal federal curriculum. If state or local law requires an opioid-reversal medication, the employer should confirm whether the statute or implementing regulation establishes specific training, written-plan, placement, inspection or documentation requirements. Beyond OSHA's recommendations, employers may also consider assigning program ownership, maintaining training records and periodically reviewing the program as risk-management practices.^3,4

Who should be trained?

For a voluntary workplace program, employers should use a risk-based approach rather than relying only on job titles. At minimum, evaluate employees already expected to respond to medical emergencies, including designated first-aid responders and emergency-response team members. Trucking and energy employers may also consider supervisors, field leadership, dispatch or terminal personnel, shop personnel and employees assigned to remote sites.

The goal is simple: if naloxone is available, personnel must be able to recognize the emergency, call for help, locate the medication and use the specific product provided.

Where should naloxone be kept?

OSHA recommends visible, readily accessible locations and suggests integrating opioid-reversal medication with items such as AEDs and first-aid kits. Employers should follow manufacturer storage instructions, inspect the supply, monitor expiration dates, replace used or expired doses and assign responsibility for program maintenance.

Field-oriented employers should evaluate whether storage only at headquarters adequately serves the actual workforce. Fleet vehicles, terminals, rigs, yards and remote sites may require a separate access analysis. Vehicle storage also requires attention to the product's labeled temperature and storage limits.

Keep emergency response separate from drug testing

Administering naloxone is an emergency medical response. It doesn't by itself establish what substance caused the emergency or determine whether post-incident testing is required. For DOT-regulated motor carriers and safety-sensitive energy operations, employers should address testing, reporting, medical privacy and employment actions under separate policies and applicable law. The emergency-response protocol should focus on preserving life, calling EMS, administering the available product and documenting the medical response appropriately.

The bigger risk-management question

Compliance establishes the minimum an employer must do. Risk management asks whether that minimum adequately protects employees, contractors, visitors and the organization. A small office near emergency medical services may reach a different conclusion than a motor carrier with drivers across several states or an oilfield contractor operating at remote locations.

Employers may benefit from documenting a location- and operations-specific assessment, particularly when they operate across multiple states or at remote worksites.

Workplace requirements and response needs can vary by location and operation. Contact your Gallagher representative to discuss your organization's risks and how your emergency-response plans can support a safer, more prepared workplace.