Naloxone kits in the workplace: balancing privacy with responsibility

Naloxone kits became mandatory in high-risk Ontario workplaces on June 1.
Pamela Patry
Occupational health and safety consultant, Workplace Safety & Prevention Services
Caucasian woman Pamela Patry smiles at the camera
Naloxone spray with warning labels. Naloxone is sold under the brand name of Narcan and is used to treat overdoses from heroin, Fentanyl, and opiates.

Does your workplace need a naloxone kit?

It can be tricky for an employer to determine if they have any employees at risk of an overdose while at work, so the Ministry of Labour, Immigration, Training and Skills Development has provided some guidance to help with this. They have outlined five ways an employer may become aware of an employee who is at risk of an opioid overdose.

  1.  A worker opioid overdose has already occurred in the workplace.
  2.  A worker who uses opioids voluntarily discloses this risk
  3. Opioid use is observed in the workplace or discovered during a workplace inspection.
  4. Discarded opioid paraphernalia, such as used needles, are found in the workplace.
  5. The joint health and safety committee (JHSC) or others in the workplace bring the risk to the employers attention.

Under the new legislation, the onus is not on the employer to discover if employees are at risk. “This is not an opportunity to dig into your employees’ personal lives. Employers are not expected to survey employees to assess risk level," says Patry. Privacy around personal information must still be considered.

“Remember that this legislation focuses on the risk of an overdose while at work,” says Patry. “It’s not about what people are doing on the weekend.” Employers are still bound by the Ontario Human Rights Code, so must ensure that they are not infringing on those rights.

Even if your workplace does not meet the criteria outlined in the legislation, you may choose to have a naloxone kit available anyway to serve workers, customers, or others that may enter your workplace. “It would be considered a best practice to have a naloxone kit available and staff trained, especially if you are in a high-risk community,” says Patry.

Going beyond naloxone

When an employer does become aware that there is a risk of an employee having an opioid overdose at work, they may have questions about how to manage this risk beyond the naloxone requirement. As with other hazards, controls must be in place to protect workers. “Employers need to look at other health and safety pieces such as an impairment policy and reporting system,” says Patry. “Make sure everyone understands how to recognize impairment and knows how to report it.” She also points out that managers and supervisors will likely need training and support, so they know how to handle an impaired worker.

Patry recommends reviewing all your health safety policies and procedures through the lens of protecting a worker from an opioid overdose. For example, if you have a working alone policy, you may need to revise it to account for the possibility of needing someone to administer naloxone. Employers may want to integrate their first aid and naloxone training so that there’s no confusion about who to contact if an overdose occurs. “If the risk exists at your workplace, your first aiders should know how to deal with an opioid overdose,” says Patry. Ultimately, clear communication, training, and the necessary tools will help employers manage addictions in the workplace.

How WSPS can help

WSPS has multiple resources including workplace mental health consultants, online information and free training as well as kits. 

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. 

For more details, and to register, visit these program providers:  

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