Addressing Opioid Overdoses - OSHA Issues Guidance and New York Adopts New Law

The opioid overdose crisis has made emergency preparedness a growing concern for employers, including printing operations. Although overdose deaths have declined recently, the U.S. Centers for Disease Control and Prevention (CDC) estimates that opioids were involved in more than 44,000 deaths nationwide in 2025. Government agencies, such as the Occupational Safety and Health Administration (OSHA), are addressing the continuing threat through workplace guidance, access to reversal medications, and new legal requirements.

OSHA’s new guidance encourages employers to stock overdose reversal medications and train employees to respond, while state and local health departments offer medication distribution and training programs. New York has taken an additional step by requiring covered employers to make opioid antidotes available at work. These developments make this an appropriate time for printing operations to review their first aid procedures and determine whether new requirements apply to their facilities.

OSHA’s Guidance

On September 24, 2026, OSHA released Opioid Overdose Rescue with Reversal Medications, a new fact sheet addressing preparation for opioid overdose emergencies at work. An overdose can affect an employee, customer, or visitor, making preparedness relevant to printing operations of all sizes. OSHA encourages employers to maintain overdose reversal medications, educate employees, and establish procedures for a rapid response.

It is important to recognize that OSHA’s guidance does not impose new federal compliance requirements. OSHA’s existing first aid standard, 29 CFR 1910.151, requires adequate first aid supplies to be readily available and trained first aid personnel when an infirmary, clinic, or hospital treating injured employees is not nearby. The new guidance provides a framework for adding overdose response to workplace first aid programs.

OSHA identifies naloxone, commonly known by the brand name Narcan, and nalmefene as Food and Drug Administration (FDA) approved overdose reversal medications. These medications temporarily block opioid effects and can restore breathing. Employers should place supplies in clearly identified, accessible locations, such as near first aid kits and automated external defibrillators. Follow product storage instructions, protect medications from direct light and excessive heat, and assign someone to monitor expiration dates and replenish supplies. Larger printing facilities should consider multiple locations.

Employee training also needs to be provided, and it should address overdose symptoms, medication administration, the possible need for additional doses, safe positioning, and applicable Good Samaritan protections. Warning signs include unresponsiveness, slow or stopped breathing, blue lips, and pinpoint pupils.

Reversal medications do not replace emergency medical care. It is important to call 911 immediately, even if the person regains consciousness. Printing operations should evaluate supply access and response arrangements across every shift. OSHA also identifies state and local health departments as potential sources of low-cost medications and free training.

New York State Law

New York is one of the first states to address the issue by enacting a separate mandate under Labor Law Section 27-f requiring private employers subject to federal first aid supply requirements to have an opioid antagonist available for workplace emergencies. Government employers are excluded. The requirement takes effect on December 13, 2026, and requires workplace availability rather than expressly requiring medication in every individual first aid kit. Covered printing operations should assess their locations and begin preparing supplies and emergency procedures.

New York’s September 23 proposed implementing rules would require "sufficient number of opioid antagonists” based on factors such as worksite size and layout, the nature of the work, whether high-risk populations access the site, and any history of on-site overdoses. No fixed quantity is required. Employers must ensure there is accessible storage of supplies, communication of supply locations, and at least one trained employee present during business hours. Employers must also regularly monitor supplies and promptly replace and dispose of expired, used, missing, or compromised doses when aware, or when they should reasonably be aware that such action is required.

Employers sharing a workplace may comply with the law jointly through a written plan. These rules remain proposed as of October 9, 2026. Printing operations should plan for coverage during operating hours and monitor the final regulations before completing their compliance programs.

Summary and Conclusion

Printing operations nationwide will need to monitor their state and local governments to determine whether similar mandates have already been imposed or are being considered. Assign responsibility for reviewing legislative developments and labor and health department notices for each facility's location. Confirm applicable deadlines, supply requirements, and training obligations, then update first aid procedures accordingly. Regular monitoring will help printing operations maintain compliance and prepare employees to respond effectively to a potentially fatal emergency.

In this article, Gary Jones, vice president, EHS Affairs, PRINTING United Alliance, covers recent actions by OSHA and New York State to address opioid overdoses in the workplace. Reach out to Gary should you have additional questions specific to how these issues may affect your business: gjones@printing.org.         

To become a member of the Alliance and learn more about how our subject matter experts can assist your company with services and resources such as those mentioned in this article, please contact the Alliance membership team: 888-385-3588 / membership@printing.org. 

Gary Jones Vice President of Environmental, Health, and Safety Affairs

Gary A. Jones is the Vice President of Environmental, Health and Safety (EHS) Affairs at PRINTING United Alliance. His primary responsibility is to monitor and analyze EHS and sustainability related legislative and regulatory activities at the federal and state levels, including some international actions. He provides representation on behalf of the printing, packaging, and graphic arts industry. Mr. Jones works closely with the federal and state-level Environmental Protection Agencies (EPA), Occupational Safety and Health Agency (OSHA), Department of Transportation (DOT), and other agencies. He also provides membership assistance on EHS compliance and sustainability programs through a variety of approaches including responding to inquiries, presentations, writing, and consulting services.

Mr. Jones is also supporting PRINTING United Alliance’s efforts for the Sustainable Green Printing Partnership (SGP). SGP is dedicated to assisting printing operations respond to customer demands for sustainable printing.

He holds a BS in biology from LaRoche College and an MS in chemistry from the University of Pittsburgh.

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