The Occupational Safety and Health Administration (OSHA) has published a new fact sheet, Opioid Overdose Rescue with Reversal Medications (FS-4519, September 2026). The document explains how opioid overdose reversal medications work, how employers can obtain them, how to store and place them, and what employee training should cover.
The fact sheet arrives as states begin to require these medications in the workplace. New York’s requirement takes effect on December 12, 2026, and California has directed its occupational safety agency to adopt a similar rule. For dealerships, the fact sheet offers a practical framework for building an overdose response program before a state mandate applies.
How Reversal Medications Work
When a person takes more opioids than the body can handle, breathing can slow and stop. Opioid overdose reversal medications (OORMs) attach to receptors in the brain, reversing and blocking the effects of opioids so that normal breathing can resume. OSHA notes that OORMs are generally safe and effective when used as directed. They work only when opioids are present and generally have no effect on a person who has not taken opioids.
The two FDA-approved OORMs are naloxone and nalmefene, sold under several brand names. Some naloxone nasal sprays are available without a prescription at pharmacies and other retail outlets. Other naloxone and nalmefene products require a prescription.
OORMs are available in two forms:
- Nasal sprays. The most common form. They do not require needles or special training.
- Injectables. Vials or prefilled syringes, more often used by first responders and healthcare workers. Certain forms can be used by untrained personnel.
OSHA advises employers to tell employees which OORM is available at their workplace and to ensure employees are familiar with how to use it. OORMs act quickly, but their effect is temporary. Anyone who administers one should call 911. An additional dose may be needed if the medication wears off before emergency responders arrive.
Acquisition, Storage, and Placement
Obtaining Naloxone
OSHA identifies several sources:
- Pharmacies and retailers. FDA-approved nonprescription naloxone nasal sprays can be purchased from pharmacies and other retail or online outlets. Other naloxone products remain prescription-only and may be available through state-specific mechanisms.
- Wholesale distributors. Employers can place bulk orders through wholesale pharmaceutical distributors.
- Standing orders. Many states have standing orders that allow pharmacies to dispense prescription naloxone in bulk.
- Group purchasing organizations. Some may offer naloxone to businesses at discounted rates.
- Manufacturer programs. Some manufacturers offer programs for employers.
- Public health partnerships. Many state and local health departments distribute naloxone at low or no cost.
Storage and Supply Management
OSHA recommends following the storage conditions on the product labeling, keeping the medication away from direct light and excessive heat, and not freezing it. Employers should track expiration dates and assign a responsible person, such as a safety officer, to manage storage and restocking. Dealerships should account for heat exposure when choosing locations in service and collision areas.
Placement
OSHA recommends keeping naloxone in visible, easy-to-reach locations, such as alongside automated external defibrillators (AEDs) and first aid kits. Larger workplaces may want kits in multiple areas. Clear signage helps employees locate the medication quickly in an emergency.
Employee Training
OSHA encourages employers to consider a voluntary training program. The fact sheet recommends covering the following topics:
- Calling 911. Emergency services should be called even if the person regains consciousness. Naloxone is not a replacement for emergency medical care.
- Recognizing an overdose. Signs may include slow or stopped breathing, blue lips, unresponsiveness, and pinpoint pupils. A gurgling or snoring sound, stupor, cold and clammy skin, coma, or respiratory failure are also warning signs.
- How OORMs work, with step-by-step instructions for the product the dealership stocks.
- Additional doses. More than one dose may be needed. Employees should follow the dosage and administration instructions on the product labeling.
- Withdrawal symptoms. In people dependent on opioids, symptoms such as shaking, sweating, nausea, or feeling angry may occur after an OORM is given. This is expected.
- The recovery position, to position the person safely while waiting for emergency services.
- Good Samaritan laws. Employees should know what protections exist in their state for people who help during an overdose.
ComplyAuto Can Help
As naloxone requirements move from guidance to law, dealerships need more than a first aid kit on the wall. They need a documented program that employees understand, that someone owns, and that holds up when a state regulator or OSHA inspector asks to see it. ComplyAuto Safety helps dealerships build and maintain that program alongside the rest of their workplace safety obligations.
With ComplyAuto Safety, dealerships can deliver employee safety training and track completion across every rooftop and department, keep written safety programs and emergency response procedures organized and current, and assign clear ownership for recurring tasks like inspecting emergency equipment and monitoring supply expiration dates. Schedule a demo to learn more.