NY S5922A Compliance Guide: Narcotic Antagonists in Workplace First Aid
New York Employers Now Have a Legal Requirement
New York employers now face a major update to workplace first aid requirements. In December 2025, Governor Kathy Hochul signed Senate Bill S5922A (Chapter 621 of the Laws of 2025), which requires private employers who are already obligated under federal OSHA rules to maintain first aid supplies to also keep an opioid antagonist (often called a narcotic antagonist) in the workplace. The law takes effect on June 10, 2026, and employers have 180 days after that date, roughly until December 2026, to comply.
Crucially, the law has been clarified so that narcotic antagonists must be available in the workplace, but do not have to be placed in every individual first aid kit. That gives employers flexibility to position overdose‑response supplies strategically while still meeting the new standard.
This guide explains what S5922A requires, who is covered, how to deploy narcotic antagonists in your facilities, and a practical step‑by‑step plan to get compliant on time.
"Workplace overdoses don't announce themselves. When seconds count, New York Employers need to be ready to save lives right when the crises happens."
Mike Johnson - Safety Compliance Manager
Why New York Passed S5922A
New York’s change is a direct response to the growing impact of opioid overdoses on workers and workplaces:
- In the United States, unintentional drug overdoses led to 525 occupational deaths in 2022, according to the U.S. Bureau of Labor Statistics.
- In New York, opioid overdose deaths increased more than 360 percent, from 1,074 deaths in 2010 to 5,017 deaths in 2021.
- Overdose events are increasingly occurring in or around workplaces, not just in private homes, which means employers and co‑workers may be the first people in a position to respond.
S5922A essentially says: if you are required to be ready for medical emergencies with first aid supplies, you should also be ready to respond to an opioid overdose with a narcotic antagonist.
What S5922A Actually Requires
The law amends New York Labor Law so that private employers in the state who are required by OSHA to maintain workplace first aid kits must also provide access to an opioid antagonist. In practice, that means:
- Covered employers are those where OSHA’s first aid standard (29 CFR 1910.151) already requires first aid supplies because a hospital, clinic, or infirmary is not “in near proximity” to the workplace.
- Narcotic antagonists (such as naloxone/Narcan) must be provided in the workplace, but do not have to be placed in every individual first aid kit.
The New York State Department of Labor will issue rules that address:
- How much of the antagonist must be kept on hand
- What training, if any, is required for employees
- Additional implementation details and timelines
The law is written to line up with existing opioid overdose prevention programs in New York, so employers are not being asked to invent something entirely new, just to adopt an already proven life‑saving tool into their first aid planning.
Who Must Comply Under S5922A?
The law applies to private employers in New York State who are mandated by OSHA to maintain first aid kits. “Employer” is defined broadly as any person, corporation, LLC, or association employing any individual in any occupation, industry, trade, business, or service.
Under OSHA rules:
- If a workplace does not have an infirmary, clinic, or hospital close enough to provide treatment within a few minutes, adequate first aid supplies must be readily available.
- S5922A links the narcotic antagonist requirement directly to that existing obligation.
Practically speaking, this will often include:
- Manufacturing and industrial facilities
- Construction sites and contractors
- Warehouses and distribution centers
- Many office environments, especially in multi‑floor buildings or campuses where medical care is not truly “right next door”
- Retail, hospitality, and service operations with significant employee counts
- Schools, colleges, and other institutions where OSHA first aid standards apply
If your safety or HR documentation already references the need for first aid kits to meet OSHA requirements, S5922A almost certainly applies to you.
Legal Protections for Employers and Employees
New York law also provides important protections for employers and employees who act in good faith to help someone experiencing an overdose:
- New York Public Health Law § 3309(4)(b) offers civil, criminal, and professional liability protections for individuals and organizations that administer opioid antagonists reasonably and in good faith.
- The New York State 911 Good Samaritan Law provides protections against certain criminal liability for individuals who call for emergency assistance for a drug or alcohol overdose that requires medical care.
If your employees follow your policies, act in good faith, and call 911, the law is designed to protect rather than punish them.
Where Do Narcotic Antagonists Have to Be Kept?
One of the most important clarifications is that the narcotic antagonist:
- Must be kept in the workplace,
- But does not have to be placed inside every single first aid kit.
In fact, it is preferable that narcotic antagonists are stored separately from general first aid kits, in their own clearly identified case. This dedicated case should have a clear face or a breakaway/seal tab so it’s immediately obvious whether a dose has been used and needs to be replaced.
This gives employers flexibility. Instead of trying to fit a dose into each kit (which could be inefficient or impractical), you can locate antagonists where they make the most operational sense, such as:
- Central first aid or safety stations
- Next to AEDs
- In security offices or reception areas
- In construction trailers or field offices
- In break rooms or high‑traffic staff areas
The key is that the antagonist must be readily accessible in the event of an emergency, not locked away in a manager’s desk or stored where staff cannot reasonably get to it quickly. Maintaining visibility of the case and its seal also helps ensure the product is in stock, unexpired, and available when needed.
This is where your choice of packaging matters. A portable EVA hardshell case with internal pockets may be ideal for field supervisors or roving safety staff, while a plastic box with a clear front or breakaway tab that can be wall‑mounted is well‑suited for fixed locations such as break rooms, near AEDs, or in a main first aid cabinet.
What Type of Narcotic Antagonist Should Employers Use?
The statute does not require a specific brand or type of antagonist, but practical considerations matter.
Options include:
Nasal spray forms (like Narcan)
- Easy for non‑medical personnel to use
- No needles
- Clear, simple instructions
Injectable forms (intramuscular or intravenous naloxone)
- Typically require greater comfort with giving injections
- Less practical for most workplaces unless medical personnel are on site
Because many workplaces rely on non‑medical staff to respond initially, the nasal spray format is usually the most practical and defensible choice. It aligns with existing public overdose response programs and is easier to train on at scale.
Six Practical Steps for Employers to Comply
Below is a straightforward framework you can use to build your compliance plan.
- Confirm Whether You Are Covered
- Review your OSHA obligations and determine whether your workplaces are required to maintain
first aid supplies under 29 CFR 1910.151. - Identify each facility, floor, or job site where first aid kits are already present because of OSHA or internal safety requirements.
If you are already keeping kits for OSHA, you should assume S5922A applies.
2. Decide Which Narcotic Antagonist You Will Use
- Select the type and format of opioid antagonist that makes sense for your staff.
- For most non‑medical workplaces, a nasal spray formulation is the most practical option because it is easy to administer and does not require injections.
- Decide how many doses you want available at each location, recognizing that New York’s Department of Labor may later set minimum quantities.
3. Review Legal Protections and Risk
- Work with your legal or risk team to understand New York’s liability protections for good‑faith administration of opioid antagonists and the 911 Good Samaritan law.
- Use that understanding to shape your written policies, documentation practices, and any internal guidance you give to managers and employees.
Most employers will want to show they acted reasonably: they stocked appropriate antagonists, trained staff, and adopted clear procedures.
4. Update Policies and Emergency Procedures
- Incorporate overdose response into your existing emergency action plans.
- Clarify:
-
- When to call 911 (almost always immediately)
- Who is encouraged or authorized to administer the antagonist
- How to report and document an overdose event
Written policies ensure consistency, support training, and demonstrate that you are taking the requirement seriously.
5. Train Key Employees
Provide straightforward training for supervisors, designated responders, or all staff, depending on your risk profile.
- Focus on recognizing overdose symptoms, calling 911 immediately, locating the antagonist in your workplace, and following the product’s instructions safely.
- A short, focused session is usually enough to build confidence and awareness.
6. Monitor Guidance and Maintain Your Program
- Plan to revisit your program regularly.
- Track expiration dates on antagonists and refresh training as staff change.
- Monitor future guidance or regulations from New York State that may specify quantities, training expectations, or additional details.
- Adjust your approach as needed to stay current.
A Simple Action Plan and Timeline
For a typical New York employer, here is a clear, practical path to complying with S5922A while integrating narcotic antagonists into your existing safety program.
Week 1 – Assess and Map
- Confirm which locations are required to maintain first aid supplies under OSHA (29 CFR 1910.151).
- Create a simple list or map of:
- Each facility, floor, or job site.
- Where first aid kits, AEDs, and main safety stations are currently located.
Weeks 2–3 – Design Your Placement Strategy
- Decide where narcotic antagonists should be available so they are easy to find and use in an emergency, for example:
- Main first aid or safety rooms.
- Near AEDs or in break/breakfast rooms.
- Security desks, reception, or construction trailers and field offices.
- Choose the packaging format that best fits each location:
- Portable cases for supervisors or mobile staff.
- Wall‑mountable boxes for fixed, central locations.
Weeks 4–6 – Install, Label, and Document
- Place the antagonist kits in the selected locations and ensure they are:
- Visible, not hidden behind other supplies.
- Easily reachable by staff who may need them quickly.
- Add clear labels or signage indicating:
- Where overdose response kits are kept.
- That 911 should be called immediately in any suspected overdose.
- Update written safety and emergency procedures to reflect:
- Where the antagonists are located.
- Who is encouraged or authorized to use them.
- How to document an incident.
Weeks 6–8 – Train and Communicate
- Provide short, focused training to managers and key employees on:
- Recognizing common opioid overdose symptoms.
- Calling 911 promptly.
- Locating and using the specific narcotic antagonist format you have chosen.
- Include overdose response in new‑hire safety orientation and periodic refresher sessions so awareness stays high over time.
Ongoing – Monitor, Maintain, and Adjust
- Track expiration dates on all antagonist doses and set reminders to replace them before they expire.
- Review locations annually (or after any major layout or staffing changes) to confirm kits are still well‑placed and accessible.
- Monitor future guidance and regulations from New York State that may define:
- Minimum quantities per facility or per number of employees.
- Training requirements or additional documentation expectations.
- Adjust your program as needed so it remains current, practical, and clearly understood by your workforce.
What This Means for New York Employers
New York’s S5922A does more than create another compliance checkbox, it acknowledges that opioid overdoses are now a real workplace risk and that rapid access to a narcotic antagonist can save lives.
By integrating opioid overdose response into your existing first aid and safety programs now, you can:
- Protect your employees and visitors
- Reduce uncertainty and legal risk
- Be fully ready when regulators and inspectors begin looking at this requirement
With the right mix of clear policies, basic training, and well‑placed, workplace‑ready narcotic antagonist kits, New York employers can turn a new legal mandate into a meaningful safety improvement that may one day make the difference between life and death.