New York to Require Naloxone in Most Private Workplaces

Starting December 13, most private employers in New York that are already required to keep a first-aid kit on hand will also have to make an opioid antagonist available for workplace first aid or emergency treatment, under a state labor law that employers and their lawyers are only now preparing to follow.

The requirement is New York Labor Law § 27-f, and it applies to private employers covered by the federal first-aid supply rules that the Occupational Safety and Health Administration already enforces. Naloxone — sold under the brand name Narcan and typically given as a nasal spray — is the medication most employers are expected to stock. The law does not require the medication to sit inside the first-aid kit itself, only that it be kept at accessible points around the workplace.

What the proposed rules say

The New York State Department of Labor released proposed regulations explaining the law on September 23, publishing them at pages 9 through 11 of the New York State Register. Under the proposal, employers would decide for themselves how many doses are sufficient, weighing the size and layout of the workplace and whether overdoses have occurred there before. Each workplace would be expected to train at least one employee who is present during working hours to administer the medication.

The proposal also puts a rough price on compliance: two-dose kits generally cost less than $50, according to the rules, and a two-count box of naloxone nasal spray retails for between $27 and $35 at local Walgreens and CVS stores. The statute appropriates no new money, so the bill falls to employers.

Who is covered, and who is not sure

Coverage tracks OSHA's first-aid standard, which turns on how far a workplace sits from professional emergency care. High-risk settings such as manufacturing plants must keep first-aid supplies when emergency help cannot arrive within three to four minutes, while lower-risk workplaces such as office buildings must do so when help is more than 15 minutes away.

"The best practice is to assume you're covered by this New York State law and get yourself some naloxone or other opioid antagonists," said Jim O'Connor, an employment lawyer and partner at the Buffalo firm Phillips Lytle.

O'Connor said emergency administration of the medication falls under New York's Good Samaritan Law, which protects people who act in good faith, and he recommended that employers write formal procedures for using naloxone.

Not every employer is comfortable with the idea. Michael Schwarzer, co-founder of the Armory Square art gallery art haus SYR, said his concern is liability. "What if I get involved, and what if I don't do it right?" he said. "Now all of a sudden I'm responsible for something that I may not want to be responsible for."

Employers who already stock it

Some New York workplaces have carried naloxone for years. Syracuse Cooperative Market has stocked it in first-aid kits at its Westcott and Salt City Market locations since 2021, and chief executive Jeremy DeChario credited the Onondaga County Health Department with making the change cheap and simple. The county provides free Narcan, staff training and a contact person for businesses.

"We can call her, and she comes and brings free Narcan," DeChario said. He added a practical warning for employers making the switch: "You also have to remember you woke somebody up from the best high of their life. People aren't always glad to have it administered."

Still, he said, the medication is worth keeping close. "Be careful with it, but also you're saving a life," he said. "That's pretty spectacular."

A mandate arriving alongside the numbers

The requirement lands in a state where naloxone is already spreading through public life. The Onondaga County Health Department has stocked naloxone boxes in churches, libraries and other public locations since 2022 and mails kits to residents who ask for them.

Unintended opioid-related deaths in Onondaga County fell by half between 2021 and 2025, from 186 to 81, according to data from the Onondaga County Medical Examiner's Office.

New York is not acting alone. In September, the federal Occupational Safety and Health Administration published its first dedicated fact sheet on workplace overdose response, urging employers to stock reversal medications and train workers to recognize an overdose — but stopping short of requiring it. The New York statute converts that advice into a legal obligation for workplaces that already have to keep first-aid supplies, and the employment lawyers now briefing clients describe the gap between the two approaches as one of the clearest state-federal splits in workplace drug policy this year.

Employers with questions about dose counts, training or liability have about two months to settle them. The law takes effect December 13, while the regulations that spell out how to comply remain in the state's rulemaking process. O'Connor's advice to clients was to start with the county health departments before buying anything: much of the naloxone and training available to New York businesses is free.