Earlier this year, New York Governor Kathy Hochul signed a bill that requires opioid antagonists to be present and ready to administer at all worksites that are required to maintain a first aid kit under federal OSHA standards. The original bill, Senate Bill S5922-A, was signed into law on December 13, 2025. Governor Hochul followed up with amendments earlier this year that clarified a few things dealers should know. First, you do not need to stock an opioid antagonist in every individual first aid kit; one accessible location in the workplace is sufficient. Second, the amendments spell out that “opioid antagonist” means naloxone (Narcan) or a similar FDA-approved drug that reverses the effects of an opioid overdose. Third, the New York Department of Labor is required to issue regulations on employee training and how many units employers need to keep on hand before the December 13, 2026 deadline (so more guidance is coming).
Compliance Questions
New York businesses have until December 13, 2026 to comply, but the law is not as sweeping as it sounds. It only applies to employers already required to maintain first aid supplies under federal OSHA, and that obligation, under 29 CFR § 1910.151(b), only kicks in when there is no infirmary, clinic, or hospital nearby. For dealerships, the first aid kit requirement is nothing new as most service departments already have them. The only question is whether yours includes an opioid antagonist and, if it does not, to add one before December 13.
One thing still to come: the New York Department of Labor has yet to issue regulations on how many units employers must keep on hand and what training will be required. Though the team at ComplyAuto will be all over this, dealers should also watch for it and update their first aid protocols accordingly.
Don’t Miss the Forest
Opioid overdoses are a public health crisis, and they do not stop at the workplace door. In New York, opioid overdose deaths have increased more than 360% since 2010. Narcan is inexpensive, easy to administer, and has no meaningful downside — it will not harm someone who is not experiencing an overdose. The few minutes between an overdose and emergency medical response can be the difference between life and death, and having Narcan on hand gives your employees a fighting chance to bridge that gap.
As a best practice, all workplaces should have a well-stocked, unexpired first aid kit on site (both in the office and showroom area, as well as the service bays!), and they should be stocked with an opioid antagonist.
California: The Bellwether State
California has long been a leader in worker protections, and the opioid crisis is no exception. In September 2024, Governor Newsom signed AB 1976, requiring Cal/OSHA to develop a regulation mandating that workplace first aid kits include naloxone or another opioid antagonist. The job’s not done, however. Cal/OSHA must submit a draft proposal to the Standards Board by December 1, 2027, and the Standards Board must adopt final regulations by December 1, 2028. The law also extends Good Samaritan protections to anyone who voluntarily administers naloxone or another FDA-approved opioid antagonist in an emergency.
ComplyAuto Safety Can Help
As states enact their own workplace safety laws and regulations, ComplyAuto Safety stays ahead of the curve by tracking the movements in each individual state. With a comprehensive compliance platform covering everything from training and inspections to documentation, reporting, and more, automotive dealerships can leave the heavy lifting to us while they can focus on what they do best, which is to sell and service motor vehicles.
Contact us to learn more about how our workplace safety compliance platform can support your team.