An overdose on your premises is a first aid event, and the standard first aid kit cannot answer it. Since March 2023, no prescription stands between a school district, a library system, a manufacturing plant, or a general contractor and the nasal spray that can. The remaining questions are purchasing questions: how many packs, which cabinet, what temperature, who gets trained, and what the law says when a lay responder uses it.
OTC status: what changed in March 2023
On March 29, 2023, FDA approved Narcan 4 mg naloxone hydrochloride nasal spray for over-the-counter sale, the first naloxone product approved for use without a prescription. FDA named the channels: drug stores, convenience stores, grocery stores, gas stations, and online. No standing order, no prescriber on file, no pharmacy account. Narcan goes on a purchase order next to AED pads and nitrile gloves. Other naloxone formulations and dosages remain prescription only; Keystone sells those to licensed facilities and practitioners on quote.
Keystone stocks the OTC two-pack: Narcan Naloxone HCl Nasal Spray 4 mg, Emergent part 69547-627-02, two devices per pack, 12 packs per case, in stock in Edina, Minnesota and shipping in 1 to 3 business days.
Good Samaritan and access laws, with Minnesota as the example
NIOSH puts two legal questions first for any employer weighing a program: whether the state allows a non-licensed person to administer naloxone, and whether the state Good Samaritan law covers that act. Minnesota answers both in Statute 604A.04, enacted as Steve's Law in 2014. A person who is not a health care professional may possess and administer an opiate antagonist. A person who acts in good faith to treat someone believed to be overdosing is immune from criminal prosecution and not liable for civil damages. Local government units get the same protection when they distribute or administer it. Statute 604A.05 protects the person who calls for help, provided they give their name, stay at the scene, and cooperate with responders.
Minnesota went further for schools. Statute 121A.224 requires every school district and charter school to maintain a supply of opiate antagonists, with at least two doses of a nasal opiate antagonist available on site in each school building.
Terms differ by state. Have counsel confirm the statute for each state where you operate before the policy is signed.
OSHA and NIOSH: the rule and the guidance
OSHA has no standard that names naloxone. Its first aid rule, 29 CFR 1910.151(b), requires a person adequately trained to render first aid and adequate first aid supplies readily available wherever an infirmary, clinic, or hospital is not in near proximity. NIOSH, part of CDC, published the document employers use to make that call: Using Naloxone to Reverse Opioid Overdose in the Workplace, Publication 2019-101.
NIOSH's risk questions are concrete: whether the site has had an overdose or anyone has found drugs, needles, or paraphernalia; how fast EMS can reach the site; whether first aid kits, AEDs, and trained providers are already in place for naloxone to join; whether the site has frequent visitors or public traffic; and whether overdose rates run high in your county or industry. NIOSH names libraries, restaurants, and parks as workplaces whose visitors may overdose on site, and cites Bureau of Labor Statistics data showing 217 workplace overdose deaths in 2016, 4.2 percent of occupational injury deaths that year, up from 1.8 percent in 2013.
Placement, storage, and quantities
NIOSH's placement guidance points to the cabinet you already have: fold naloxone into the existing first aid and AED procedures, and store nitrile gloves and a rescue mask or face shield next to it.
Storage comes from the label. Store between 2 C and 25 C (36 F to 77 F). Do not freeze. Protect from light. Avoid excessive heat above 40 C (104 F). Keep the device sealed in its blister and carton until use. Those limits rule out a truck glovebox in July and an unheated jobsite trailer in January; bring the pack indoors at end of shift.
Expiration is on the carton. On January 17, 2024, FDA announced that the manufacturer extended the shelf life of newly manufactured Narcan 4 mg from three years to four. The extension applies only to product produced after that date, so the printed date governs. Ask for dating on the quote, and log the date on the calendar that tracks AED pads and batteries.
NIOSH sets the quantity floor: stock a minimum of two doses, place doses in multiple locations when the size and layout of the site require it, and account for the time it takes to replace a used pack. Each Narcan two-pack is two doses. Keystone's starting point:
| Site | Placement | Starting stock |
|---|---|---|
| Office or clinic, one floor, under 50 people | With the AED and first aid kit | 1 two-pack |
| School building | Nurse's office plus the main office or gym | 2 two-packs (Minnesota floor is two doses per building) |
| Library branch or public counter | Front desk plus one per public floor | 1 two-pack per public floor |
| Plant or warehouse, multiple zones | Every first aid station and AED cabinet | 1 two-pack per station |
| Jobsite | Trailer first aid kit plus each foreman's kit | 1 two-pack per kit |
Add one spare two-pack per site; it moves to the station that used its pack the same day, and the reorder replaces the spare.
Training that fits a safety meeting
The device steps come off the label and take minutes to teach. Try to wake the person. Insert the nozzle in one nostril and press the plunger. Call 911 after the first dose. Wait 2 to 3 minutes. If the person does not wake up, give the second device, and keep giving doses every 2 to 3 minutes until the person responds or EMS arrives. Stay until the ambulance arrives.
NIOSH adds the items that make a program hold up: recognizing the signs of an opioid overdose, checking the scene for drug powders or residue and staying out when they are visible, wearing nitrile gloves on every response, recognizing when another dose is needed, handling agitation as the person comes around, and CPR or rescue breathing when breathing has stopped. NIOSH also recommends bloodborne pathogen training because needles are often present at the scene. Schedule the refresher annually with the first aid and CPR cycle already on the calendar. Budget 10 minutes at the next safety meeting for the device itself and a full block for the rest.
None of this is medical advice. Follow the label and your local protocol, and call 911 for every suspected overdose.
Put it on this week's order
- Count the stations: every AED cabinet, first aid kit, nurse's office, and jobsite trailer.
- Order one Narcan two-pack per station plus one spare per site.
- Add nitrile gloves and a CPR rescue mask at every station that lacks them.
- Log the carton expiration date on the AED calendar.
- Write the one-page policy and schedule the training block.
Public entities in Minnesota: counties and cities receive a direct share of the state's opioid settlements, so ask your county how naloxone purchases are handled before spending general fund dollars.
Browse harm reduction and public health supplies for Narcan two-packs, nitrile gloves, and rescue masks, or send the station count through the fast quote form for a same-day quote during business hours. Net 30 is available for approved accounts. Questions on state law or placement go to the sales department.
Sources
- https://www.fda.gov/news-events/press-announcements/fda-approves-first-over-counter-naloxone-nasal-spray
- https://www.fda.gov/drugs/drug-alerts-and-statements/fda-announces-shelf-life-extension-naloxone-nasal-spray
- https://www.cdc.gov/niosh/docs/2019-101/pdfs/2019-101.pdf
- https://www.revisor.mn.gov/statutes/cite/604A.04
- https://www.revisor.mn.gov/statutes/cite/121A.224
- https://dailymed.nlm.nih.gov/dailymed/drugInfo.cfm?setid=a0ebc83d-2892-40de-bc0a-775ce90b30db
