OSHA Releases New Guidance for Opioid Emergencies

With the opioid epidemic showing no signs of abating, OSHA released new guidance on September 24, 2026, as part of a government-wide effort to prioritize addiction treatment and recovery. The guidance is in the form of a Fact Sheet, "Opioid Overdose Rescue with Reversal Medications," designed to assist workplaces in recognizing the signs of an overdose and responding swiftly. 

OSHA’s Fact Sheet provides several opioid overdose preparedness strategies, including:

• Keeping lifesaving, FDA-approved reversal medications – such as naloxone or nalmefene – on hand. 
• Treating overdose kits like first aid kits by storing them in highly visible, easily accessible locations.
• Educating workers on how to recognize and react to symptoms of an overdose, such as slow or stopped breathing, blue lips or skin, pinpoint pupils, and unresponsiveness.
• Preparing to take immediate action in an emergency by training individuals on administering medication, safely positioning the individual, and providing care until first responders arrive.

Although the guidance recommends treating overdose kits like “first aid,” it does not require an employer to implement these strategies. The guidance explicitly declines to create any new OSHA-specific requirements under existing provisions such as the Agency’s Medical Services and First Aid standard or Recordkeeping regulation. Employers should, however, consider proactive steps such as maintaining a naloxone policy that addresses the right of employees to refuse to be administered the drug and making sure that existing emergency response plans adequately address such urgent situations. Employers in states with their own OSHA programs should consider whether state law imposes any additional requirements.

Employers interested in considering such strategies should consult workplace safety counsel.