New York Broadens Workplace First Aid Requirements To Include Opioid Antagonists

New York Governor Kathy Hochul signed Senate Bill S5922-A/A2725-A into law on Dec. 12, 2025, expanding workplace first aid requirements to include opioid antagonists where first aid supplies are required under federal law. On Feb. 13, 2026, Assembly Bill A9453/S8770 amended this law to address several issues, as Governor Hochul had identified in her approval memorandum for the original bill.

This legislation is intended to address the continuing rise of opioid-related emergencies and ensure that workplaces are prepared to respond. As amended, the law clarifies several key compliance obligations for employers. Specifically, private employers that are required by the federal Occupational Safety and Health Act of 1970 (OSH Act) and its standards to maintain readily available first aid supplies must now also make opioid antagonists, such as naloxone (Narcan), available at the workplace for use in providing first aid or emergency treatment. The amendments clarify that employers are not required to include an opioid antagonist in every individual first aid kit.

Additional amendments align the law with existing public health statutes and clarify the public-employer exemption. The law also directs the New York State Department of Labor (NYSDOL) to issue regulations, including the appropriate number of opioid antagonists based on workplace size, training requirements, and any other necessary matters. Covered employers will also have more time to comply with the new legislation, as the effective date was extended to one year from enactment (Dec. 12, 2026).

Employers should evaluate whether they are subject to federal first aid requirements and monitor forthcoming NYSDOL guidance on implementation.

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