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New guidance on naloxone requirements in the workplace

January 31, 2023  By Don Horne

Queen’s Park is offering new guidance on how to determine if your workplace must comply with new naloxone requirements in Ontario, as well as support in the form of a free naloxone kit and training for two workers.

Recent amendments to the Occupational Health and Safety Act, which come into effect June 1, require life-saving naloxone kits in workplaces where workers are deemed at risk of overdose. Naloxone is a medication that temporarily reverses the effects of an opioid overdose and allows time for medical help to arrive.

“One of the key questions from employers has been how to determine if there is at risk of overdose from opioids,” says Workplace Safety & Prevention Services (WSPS) Consultant Pam Patry. “We now have some clarification from the government to help with that.”

Below, Patry answers this and other top questions about the naloxone legislation and support for employers. She reminds workplaces that if they do need to comply, it’s time to prepare. “Don’t wait until June 1. Opioid overdoses can happen tomorrow.”


What are the new legal requirements? 

Workplaces at risk of a worker opioid overdose must have at least one naloxone kit onsite and train staff on how to administer it. (Note that the requirements only apply if your own workers are at risk, not other workers that may be in the workplace, or customers, clients, and the public.)

“A workplace can decide to provide multiple kits,” says Patry, “depending on the degree of risk and the size of the workplace, in order to meet the legal obligation to take every reasonable precaution to protect workers.”

How do I determine whether there is a risk of worker opioid overdose?  

If you are aware of, or ought to be aware of, a risk of overdose, the regulations apply. “There are five ways you might become aware of a risk of worker opioid overdose,” says Patry.

  • a worker opioid overdose has already occurred in the workplace;
  • a worker who uses opioids voluntarily discloses this risk;
  • opioid use is observed in the workplace or discovered during a workplace investigation;
  • discarded opioid paraphernalia, such as used needles, are found in the workplace; and
  • the joint health and safety committee (JHSC) or others in the workplace bring the risk to the employer’s attention.

“If workplaces are still unsure of their status, they can opt to purchase a kit and provide training on its use to be on the safe side,” she says.

How many staff need to be trained? And what training is required? 

“The requirements only say trained staff must be available to administer naloxone anytime there are workers in the workplace,” says Patry. “You’ll need to take into consideration vacation, sick days, shifts, and the number of naloxone kits you have when determining how many people require training.” Kits must be located in the vicinity of trained staff.

Training covers how to recognize an opioid overdose, how to administer naloxone, and hazards related to administering naloxone,” says Patry. Depending on the form in which the naloxone is administered (nasal spray or injection), these could include physical, chemical, biological and psychological hazards.”

What supports are available to help workplaces comply with the naloxone requirements? 

Ontario’s Workplace Naloxone Program will provide support to employers for up to two years by providing free online naloxone training for two workers per workplace and a free nasal spray naloxone kit.

How do I incorporate naloxone kits into my existing emergency response planning? 

“Follow the process you use for other first aid emergencies,” says Patry. Set down in writing:

  • who will administer the naloxone;
  • where kits are stored;
  • what training is required;
  • what procedures to follow when administering naloxone;
  • who to contact externally and internally;
  • what controls you have put in place to prevent identified hazards;
  • what personal protective equipment must be worn; and
  • how you will support first aiders and other employees affected by the incident.


How WSPS can help


Downloads & Forms 

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