NALOXONE KIT REQUIREMENTS FOR ONTARIO CONSTRUCTION SITES

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The opioid crisis has hit the construction industry harder than almost any other sector. Construction workers in Ontario are disproportionately represented in opioid-related deaths — studies have consistently shown that construction trades workers are among the occupational groups most at risk of opioid overdose. In response, Ontario introduced requirements for naloxone kits in workplaces, making it one of the first provinces to mandate this life-saving medication at work sites.

This guide covers what Ontario construction employers need to know about naloxone kit requirements, including when the requirement took effect, what the kits must contain, who needs to be trained, and how to handle the sensitive privacy issues involved.

When Naloxone Kits Became Mandatory

On June 1, 2023, Ontario's naloxone kit requirement came into effect through amendments to the Occupational Health and Safety Act and Ontario Regulation 559/22. The requirement applies to all workplaces covered by the OHSA, including construction projects.

Under this regulation, employers must provide and maintain a naloxone kit in the workplace if the employer becomes aware, or ought reasonably to be aware, that there may be a risk of a worker having an opioid overdose at the workplace. This is not limited to situations where the employer knows a specific worker uses opioids. The risk assessment is broader than that.

Risk Assessment Requirements

The regulation requires employers to assess the risk of an opioid overdose occurring at the workplace. For construction sites, several factors make this risk assessment particularly important:

• Industry-wide statistics — construction workers are overrepresented in opioid-related deaths across Ontario. The Ontario Drug Policy Research Network has identified construction as one of the highest-risk occupational groups. This statistical reality alone may trigger the duty to provide a naloxone kit.
• Prescription opioid use for pain management — construction work is physically demanding, and musculoskeletal injuries are common. Workers may be prescribed opioids for chronic pain from work-related injuries. The risk of overdose exists even with prescription use, particularly when combined with other substances or medications.
• Workplace culture factors — long hours, physical stress, job insecurity, seasonal employment patterns, and the stigma around seeking help for substance use disorders can all contribute to opioid misuse in the construction workforce.
• Remote or isolated work locations — on sites where emergency medical services may take longer to arrive, the availability of naloxone on site becomes even more critical.
• Previous incidents — any past overdose or suspected overdose on a project or involving workers in the employer's workforce is a clear indicator that a naloxone kit is needed.

Given the well-documented prevalence of opioid-related harm in the construction industry, most construction employers should err on the side of having naloxone kits available on their sites. The cost is minimal, and the potential to save a life is real.

Kit Contents

Ontario Regulation 559/22 specifies the contents of a naloxone kit. Each kit must contain:

• Naloxone hydrochloride — the kit must contain at least two doses of naloxone in a form suitable for administration by a trained non-medical person. This is typically provided as nasal spray (each device delivers a single dose) or as injectable naloxone with appropriate supplies.
• Delivery devices — for nasal naloxone, the spray devices are self-contained. For injectable naloxone, the kit must include syringes, needles, and alcohol swabs.
• Protective equipment — non-latex gloves and a pocket mask or face shield for providing rescue breathing
• Instructions — clear, easy-to-follow instructions for recognizing an opioid overdose and administering naloxone

The naloxone in the kit must be current and not expired. Employers must check expiry dates regularly and replace expired naloxone promptly. Nasal naloxone spray typically has a shelf life of approximately 24 months, but this varies by product. Store kits according to manufacturer instructions — most naloxone products should be stored at room temperature and kept away from direct sunlight and extreme heat or cold.

Training for Administration

The regulation requires that at least one worker at the workplace be trained to recognize an opioid overdose and administer naloxone. However, best practice — particularly on construction sites with multiple shifts, large workforces, or multiple work areas — is to train several workers so that a trained person is always available.

Naloxone training is straightforward and typically takes 30 to 60 minutes. It covers:

• Recognizing an opioid overdose — signs include slow or stopped breathing, blue or grey skin colour (particularly around lips and fingertips), unresponsiveness, gurgling or snoring sounds, and pinpoint pupils
• Calling 911 — naloxone is a temporary measure. Emergency medical services must always be called immediately.
• Administering naloxone — the specific steps for nasal spray or injection, including dosage and timing for a second dose if the first does not produce a response within 2 to 3 minutes
• Rescue breathing — how to provide breaths using the pocket mask while waiting for naloxone to take effect and for EMS to arrive
• Recovery position — placing the person on their side to prevent choking if they vomit upon regaining consciousness
• Post-administration monitoring — naloxone wears off in 30 to 90 minutes, and the person may relapse into overdose. Continuous monitoring until EMS arrives is essential.

Free naloxone training is available from many sources, including local public health units, community health centres, and the Ontario Harm Reduction Network. Some construction safety associations also offer naloxone training as part of their programming.

Placement and Signage

Naloxone kits must be placed in a location that is readily accessible and known to workers. On a construction site, this means:

• Near the first aid station — placing the naloxone kit alongside the first aid kit is a practical approach, as workers already know where the first aid station is located
• In a visible, accessible location — the kit should not be locked away or stored in a location that requires special access. Time is critical during an overdose, and any delay in retrieving the kit can be fatal.
• Marked with signage — the location of the naloxone kit should be indicated with clear signage so that any worker on site can locate it quickly, even if they are not the designated trained person
• Protected from extreme temperatures — on construction sites, where trailers and storage areas may be subject to extreme heat in summer or freezing temperatures in winter, the kit should be stored in a temperature-controlled environment

WSIB Coverage

Workers who administer naloxone to a co-worker in the workplace are covered under the Workplace Safety and Insurance Act. If a worker sustains an injury or illness as a result of administering naloxone (for example, a needlestick injury from an injectable kit), they are eligible for WSIB benefits. This coverage extends to the act of providing emergency assistance, including administering naloxone.

Additionally, the Good Samaritan Act, 2001, provides protection from civil liability for individuals who provide emergency first aid assistance, including naloxone administration, as long as the assistance is provided in good faith and without gross negligence.

Privacy Considerations

The intersection of naloxone requirements and worker privacy is a sensitive area that construction employers must navigate carefully:

• No requirement to identify individual users — the naloxone kit requirement is based on a workplace-level risk assessment, not on identifying individual workers who may use opioids. Employers should not ask workers to disclose personal substance use.
• Confidentiality of incidents — if an overdose occurs and naloxone is administered, the identity of the affected worker should be kept confidential to the extent possible. Information should be shared only with those who need to know for medical or safety reasons.
• No disciplinary action for overdose — while employers have the right to enforce workplace substance use policies, the immediate response to an overdose must be focused on saving the person's life. Disciplinary considerations should be addressed separately and in accordance with human rights obligations.
• Human rights considerations — substance use disorders are recognized as disabilities under the Ontario Human Rights Code. Employers have a duty to accommodate workers with substance use disorders to the point of undue hardship.
• Stigma reduction — the way an employer communicates about naloxone kits can either reinforce or reduce stigma. Framing naloxone as a standard safety measure — similar to a first aid kit or fire extinguisher — normalizes its presence and encourages workers to use it without hesitation.

Having a naloxone kit on your construction site is a simple, low-cost measure that can save a worker's life. The opioid crisis is not abstract — it is present on Ontario construction sites every day. Compliance with the regulation is the minimum. Building a workplace culture where workers feel safe to seek help and where life-saving medication is accessible without stigma is the goal.