Do California Employers Have to Provide Naloxone Training in 2027?

Yes, if you require CPR certification. Starting January 1, 2027, AB 2150 requires those employers to also require a separate online naloxone video module approved by the state’s Emergency Medical Services Authority, and to pay for it. Employers that do not require CPR are not covered by this law.

I am Mac Malbrough. I hold a J.D. and an MS-HRM, I am not an attorney, and this is general information, not legal advice. I read AB 2150, Chapter 384 of the Statutes of 2026, on the California Legislative Information site on November 6, 2026. It was approved on September 20, 2026 and adds Section 1797.197b to the Health and Safety Code. This guide is written for employers of 10 to 150 people who run front desks, warehouses, studios, clinics, classrooms or job sites where someone may be certified in CPR.

Who has to provide naloxone training under AB 2150?

The trigger is a requirement, not a headcount. The text covers “an employer operating in this state that requires cardiopulmonary resuscitation (CPR) certification training of its employees.” If your policy, contract, license or customer agreement makes certain employees get CPR certified, you are in. If CPR is something a few people take on their own, with no requirement from you, the sentence does not describe you.

The text also says the rule applies uniformly. No employer classification, facility type or program type is exempt just because of its clinical staffing or its own medication policies. A small employer cannot rely on a size exception, because I did not find one in the bill.

The law I found in the bill is about training, not about stocking naloxone. A separate part of existing law, described in the bill’s digest, directs Cal/OSHA to bring a draft rule on first aid materials, including naloxone, to the Standards Board before December 1, 2027. That is a different track, and I would watch it.

What exactly does the law require?

Three things, all in subdivisions (a) and (b) of the new section:

• You must require each employee you send to CPR certification to also take an approved online video module on using naloxone.
• You must pay the costs of that training. The text says each employer “shall pay for the costs of the training.”
• The training must be separate from your existing CPR curriculum, so a vendor cannot simply add a slide to the CPR class and call it done.

The statute does not set a completion deadline that I could find, and it does not say how often the module must be repeated. That leaves a gap employers should fill with their own written policy rather than guess.

What does the module have to cover, and who approves it?

The Emergency Medical Services Authority, usually called EMSA, reviews and approves the online video modules. To be approved, a module must include at least 3 things:

1. Recognition of the signs and symptoms of an opioid overdose.
2. Appropriate response actions, including emergency procedures.
3. Proper administration of naloxone or another opioid antagonist approved by the U.S. Food and Drug Administration.

The text says modules offered by the American Heart Association or the American Red Cross are examples of what may be approved. That is not the same as saying they are approved today. When I wrote this on November 6, 2026, I did not find a published EMSA list of approved modules, so check the EMSA website before you buy anything. EMSA’s role is limited to approving content. The bill says that role does not include administering the law, enforcing it or monitoring whether employers comply.

Can your current CPR vendor’s course count?

Possibly. Subdivision (d) says an employee who has completed CPR certification, first aid certification or other training through a program that EMSA determines meets or exceeds the minimum standards is deemed to satisfy the requirement. The employer then does not have to provide separate training to that employee, as long as the employer keeps documentation of the qualifying program or certification. EMSA may set up a process for a training program, certifying body or employer to ask for that determination.

Two cautions. First, “deemed” turns on an EMSA determination, so a vendor’s marketing line is not proof. Second, the separate-curriculum rule in subdivision (b) and the deemed-satisfied rule in subdivision (d) sit side by side, and the text does not say how they interact in practice. Until EMSA says more, get any claim that a current course counts in writing from the vendor, and file it.

Who pays, and what does it cost?

You pay. The bill does not set a price, and I did not find a published price for an approved module, so I will not give you a number. Budget it with this formula: the number of employees you require to hold CPR, multiplied by the module fee plus the minutes of work time it takes. California wage rules generally treat required training as hours worked, so the paid time is part of the cost even when the module itself is free. Confirm how that applies to your pay practices with an employment attorney if you have hourly staff who complete it off the clock.

If you have not mapped who is required to hold CPR, that is your first cost driver. Many small employers find the real list is shorter than they thought, and a few find it is longer, because a customer contract or insurance policy requires certification they never tracked.

What does AB 2150 not require?

It does not require your employees to carry or give naloxone. Subdivision (e) says the training is for educational and preparedness purposes and does not create a duty, authorization or expectation that any employee will administer it. It also leaves licensing and scope-of-practice rules alone, including the rules that apply to healthcare settings.

It sets a floor, not a ceiling. Subdivision (f) says other agencies, including Cal/OSHA, can adopt broader opioid overdose training rules later, and a more protective rule would control. Meeting AB 2150 does not mean you meet every future rule. If your site stocks naloxone in first aid kits because of a risk assessment, keep doing that, and keep it in the same file as your workplace violence prevention plan and other safety records.

What happens if an employer does not comply?

The bill’s digest says a violation would be a crime, because existing law makes a violation of these emergency medical services provisions a misdemeanor. The bill gives EMSA no enforcement role. I did not find in the text a civil penalty schedule or a private right to sue. Whether and how local prosecutors or other agencies would act on it is not clear to me yet, and an employment attorney can speak to your risk. My practical view is simple: a misdemeanor exposure is a poor trade for a module that costs little time, so document compliance from the first day.

What is a five-step rollout calendar?

Here is the sequence I would run between now and the first quarter of 2027. These dates are my plan, not statutory deadlines.

1. By November 20, 2026: list every role you require to hold CPR, with the document or contract that requires it.
2. By December 4, 2026: check the EMSA website for approved modules and ask your CPR vendor, in writing, whether its course already meets the standard under subdivision (d).
3. By December 18, 2026: choose a module, set the budget, and decide which hours are paid work time.
4. By January 15, 2027: assign the module to each covered employee and add it to new-hire onboarding for any role that needs CPR.
5. By February 15, 2027: collect the completion records, file them with each CPR card, and add a line to your handbook.

The handbook line can be short: “Employees required to hold CPR certification must also complete the approved naloxone training. The company pays for the training and the time to complete it. The training is for awareness and preparedness and does not require any employee to administer naloxone.” My guide to California employee handbook requirements shows where a safety training paragraph belongs, and the handbook gap checker flags sections you have not updated.

What should you do this week?

This week, make the list from step 1: which roles do you require to hold CPR, and where is that requirement written? Then email your CPR vendor and ask whether its course will be approved by EMSA to meet the naloxone standard. Put both answers in one folder. If you want a second set of eyes on your safety training records, the HR compliance check-up covers them, and the January 2027 employer checklist shows where this task fits among the others.

Sources

• AB 2150 (Haney), Chapter 384, Statutes of 2026, approved September 20, 2026, read November 6, 2026
• Health and Safety Code Section 1797.197b, as added by AB 2150, in the chaptered text above

McKinley holds a J.D. but is not a licensed attorney. Articles here are general information, not legal advice. For your specific situation, talk with an employment attorney.

Data current as of November 2026. Sources are linked where each figure appears.