New York employers must have opioid antagonist in OSHA-mandated first aid kits

The federal Occupational Safety and Health Administration (OSHA) mandates certain employers to have first aid supplies readily available for the treatment of all injured employees. Effective December 12, 2026, the recently-enacted New York Labor Law § 27-F will require all such OSHA-mandated first aid kits to include an opioid antagonist, such as naloxone (Narcan), available for use in providing first aid or emergency treatment at the workplace.

OSHA requirements

The regulations under the Occupational Safety and Health Act of 1970 (OSH Act) currently require employers to make sure first aid supplies are readily available in the workplace. An example of the minimal contents of a generic first aid kit is described in American National Standard (ANSI) Z308.1-1998 “Minimum Requirements for Workplace First-aid Kits.” 

The contents of the kit listed in the ANSI standard should, under federal law, be adequate for small worksites. When larger operations or multiple operations are being conducted at the same location, employers must determine the need for additional first aid kits at the worksite, additional types of first aid equipment and supplies, and additional quantities and types of supplies and equipment in the first aid kits.