Contractors should plan overdose response before work begins: make sure crews can call 911 with usable jobsite location details, assign who will meet responders, and keep required first-aid supplies accessible. Employers may also choose to stock naloxone and train workers to use it, but OSHA’s September 2026 overdose fact sheet is informational and does not require employers to stock it.
What OSHA requires—and what its overdose guidance recommends
Construction employers have first-aid and emergency-medical duties under 29 CFR 1926.50. Before a project starts, employers must make provisions for prompt medical attention. If appropriate treatment facilities are not reasonably accessible, a person with documented qualifying first-aid training must be available to render first aid.
- First-aid supplies must be easily accessible. The kit must be kept in a weatherproof container with sealed packages, checked before it is sent to each job and at least weekly on the job, and replenished when items are used.
- Employers must provide proper equipment for prompt transport of an injured or ill worker, or an effective communication system for contacting emergency medical services.
- Where 911 is available and the employer uses a communication system, it must effectively reach emergency medical services. If dispatchers do not automatically receive the caller’s coordinates, conspicuously post the worksite’s latitude and longitude or other effective location information, subject to the rule’s landline exception.
OSHA’s September 2026 fact sheet on opioid overdose reversal medications recommends preparedness measures such as making approved reversal medication available, training workers, and keeping supplies visible and accessible. The fact sheet expressly says it creates no new compliance requirements. It is guidance, not a blanket federal requirement to stock naloxone.
Build an overdose response plan for the jobsite
A plan only works if it matches the site and crew in place that day. OSHA notes that construction locations and workforces can change, making emergency planning more difficult; its emergency preparedness guidance emphasizes communication, assigned responsibilities, and trained people.
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- OSHA Compliant Emergency Kit: Includes adhesive fabric and plastic bandages, antibiotic ointments, BZK antiseptic towelettes, burn cream packets, gauze roll and pads, gloves, scissors, tweezers, and other multi-use first aid items
- Convenient Packaging: An ideal office first aid kit, home first aid kit, or car first aid kit, this set of safety-oriented office essentials comes in a durable wall mountable plastic case complete with easy slide latches
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At mobilization and whenever the site changes
- Confirm the street address, current entrance or gate, GPS coordinates, and any directions that will help emergency responders reach the person.
- Confirm which phone, radio, or other communication method can reach 911 or emergency medical services from the work area.
- Assign who calls 911, who provides first aid or administers stocked medication if trained, and who meets responders and keeps their route clear.
- Share the current site location and access instructions with crews. Do not assume a dispatcher or emergency crew knows which gate is open or where work has moved.
Recognize a possible overdose and call 911
Possible opioid overdose signs include slow, shallow, or stopped breathing; unresponsiveness or stupor; blue or discolored lips; pinpoint pupils; gurgling or snoring sounds; and cold, clammy skin. Any suspected overdose is an emergency: call 911 immediately, even if the person wakes or appears to improve.
Follow the dispatcher’s instructions. If the person has stopped breathing or is breathing very weakly, SAMHSA advises CPR; it is best performed by someone trained. Provide supportive care and stay with the person until responders arrive.
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Decide whether to stock naloxone
Employers can assess whether workplace naloxone availability fits their site, workforce, and response plan. CDC/NIOSH’s workplace naloxone resource is intended to help employers consider that decision. OSHA identifies naloxone and nalmefene as the two FDA-approved opioid overdose reversal medications. Naloxone can reverse an opioid overdose, but it does not reverse overdoses caused by non-opioid drugs and does not replace emergency care.
Nonprescription naloxone nasal spray is one option: OSHA says it can be obtained through pharmacies and other retail or online outlets. Nasal spray avoids needles and is a common form, but the right choice depends on product availability, the employer’s program, and whether workers are trained on the specific form. Other possible acquisition channels described by OSHA include wholesale supply, state standing orders, group purchasing organizations, manufacturer programs, and local public-health partnerships. Availability and processes differ, so confirm what applies locally.
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Store and maintain stocked medication
If an employer chooses to stock reversal medication, manage it as a real response supply rather than an item forgotten in a locked office. OSHA recommends keeping it visible and accessible, near AEDs or first-aid kits; larger workplaces may need multiple clearly marked kits near different work areas.
- Follow the specific product’s label and storage directions. OSHA’s fact sheet advises protecting medication from direct light and excessive heat and not freezing it.
- Track expiration dates and assign a person, such as the safety officer, to inspect and replace supplies.
- Account for changing work areas when deciding how many kits are needed and where crews can reach them quickly.
Train crews on the actual product and local rules
Training should use the medication the employer actually stocks and fit the site’s communications and emergency plan. OSHA suggests covering overdose signs, calling 911, the product’s instructions, possible repeat doses, recovery positioning, supportive care, withdrawal symptoms, respectful treatment, and connection to ongoing care.
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- OSHA-Compliant First Aid Kit: Includes 245 pieces to address cuts, bruises, scrapes, and injuries in 50 or more people; helps managers pass OSHA safety inspections and ensure workplace compliance; ideal for industrial facilities and large corporate offices
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OSHA’s fact sheet says opioid overdose reversal medications work quickly but are temporary. Repeat doses may be needed, and emergency responders must still evaluate and treat the person. Workers should follow the product label and their training rather than assume one dose has resolved the emergency.
Teach workers what Good Samaritan protections apply in their state, but verify state-specific information before training: protections and access rules vary. OSHA notes that state standing orders may allow bulk dispensing in many states; do not assume the same process applies everywhere.
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