Ontario Naloxone Kit Requirements: Everything Employers Need to Know  

In response to the opioid crisis, Ontario introduced amendments to the Occupational Health and Safety Act (OHSA) requiring employers to provide naloxone kits in workplaces where there is a risk of a worker suffering from an opioid overdose. Certain industries and workplaces have a higher risk of a worker experiencing an opioid overdose than others. According to the government of Canada, since 2016, 30% to 50% of those who passed away from an opioid overdose worked in the trades. And three out of four of those workers were men.  

This blog discusses employer obligations on providing naloxone kits in the workplace.

What is naloxone? 

Naloxone is a medication that temporarily reverses the effects of an opioid overdose. Opioids
are drugs that are prescribed by a medical practitioner as therapy for pain relief. Opioids can be used recreationally (e.g., Morphine, Heroin, Fentanyl, Codeine, among others). Employers must note that naloxone found in naloxone kits can only reverse overdose from opioids. Naloxone can be administered through a nasal spray or with an intramuscular injection. Thus, the presence of a naloxone kit in a workplace, where there is a risk of a worker experiencing an opioid overdose, can prevent an overdose-related death. 

When you utilize your naloxone kit, and naloxone is administered, best practices suggest you also call 911 and request the assistance of an ambulance. Employers or an appointed worker responsible for administering naloxone should stay with the employee and assist first responders with information. 

Which workplaces must have a naloxone kit? 

Not every workplace in Ontario must provide a naloxone kit. Only employers that are aware or ought to reasonably be aware of the risk of a worker experiencing an opioid overdose at the
workplace must have a naloxone kit on site. Employers are required to provide at least one
naloxone kit for every 50 employees. 

An employer with several locations should only have a naloxone kit on the site(s) where they believe there is risk of an opioid overdose. If a worker has an overdose outside of their hours of work and is not present in the workplace, that will not trigger the obligation. Furthermore, employers are not required to provide naloxone to a customer, client, or member of the public that is experiencing an opioid overdose within their premises. 

According to Ontario’s Ministry of Labour, Immigration, Training, and Skills Development, common signs of risk of opioid overdose in the workplace are: 

• The employer has learned or has witnessed a worker having an opioid overdose in the workplace.
• The employee has volunteered information to the employer that they feel at risk of overdosing at work. 

What should a naloxone kit include? 

According to Ontario’s OHSA, naloxone kits must contain:  

• 2 doses of intra-nasal spray
• 1 rescue breathing barrier
• 1 pair of non-latex gloves.  

If employers opt for injectable naloxone, the naloxone kit must include:  

• 2 vials or ampoules of naloxone medications 
• 2 sterilized syringes
• 2 alcohol swabs
• 1 rescue breathing barrier
• 1 pair of non-latex gloves 

Employers should note that the naloxone medicine has an expiry date. This information can be found on the ampoules, vials, or on the nasal spray device. If the naloxone contained in their naloxone kit has expired, employers must replace it promptly. 

Who must administer naloxone? 

Employers must appoint a worker responsible for administering naloxone in the workplace.

Otherwise, the employer can choose to administer naloxone themselves. The OHSA requires that the appointed worker performs their job responsibilities close to where the naloxone kit is stored. Employers must also ensure that the appointed worker is present on site whenever there are workers in the workplace. This may require the appointment of multiple employees. 

The OHSA requires employers to provide training to the appointed employees responsible for administering naloxone. Employers can opt to provide the training themselves or use an external training provider. Appointed employees must be trained on how to recognize an opioid overdose, how to administer naloxone, and should receive instructions on how to operate in the event of complications or immediate effects related to the administration of naloxone (i.e., how to respond to a potentially violent person or protections from biological exposure). Naloxone kit training must be provided at least once a year. Employers are also required to document and keep records of naloxone training and naloxone kit distribution. 

Consequences for non-compliance 

Employers face risk of penalties and legal action for failure to comply with the OHSA minimum
requirements. Currently, the maximum fine under the OHSA is $2 million for organizations that contravene workplace health and safety regulations. 

The Ontario government has been providing free nasal spray naloxone kits to businesses at risk of opioid overdoses through the Workplace Naloxone Program. The Program also provides free training to equip appointed staff with the tools to respond to opioid overdoses in the workplace.  

Employers can order free nasal spray naloxone kits from:  

• The Canadian Red Cross (https://www.redcross.ca/ohrontario/home) 
• Ontario Workplace Naloxone Program (https://www.redcross.ca/ohrontario/home) 

Ontario’s Free Workplace Naloxone Program is ending on March 31, 2024. After this date, employers in the province will bear all costs associated with compliance with naloxone requirements under the Occupational Health and Safety Act.

The temporary funding provided by the Ontario government for workplaces to access free training and naloxone kits will no longer be available. But the paid training option will still be available to employers at $30 per person.

Do you need help implementing the naloxone kit requirement in your workplace? 

Whether you are looking to develop health & safety policies or need advice on any HR, health & safety, or employee management issue, our experts are here to help you 24/7.   

To learn more on how our services can benefit your business, call us today at (1) 833 247-3652.