Employers That Require CPR Training Must Add Naloxone Training Under AB 2150 | By: Jared W. Slater
Employers That Require CPR Training Must Add Naloxone Training Under AB 2150 | By: Jared W. Slater

Beginning on January 1, 2027, California employers that require cardiopulmonary resuscitation (CPR) certification training of their employees must also require those employees to complete online video training on the use of naloxone, the medication used to reverse opioid overdoses. The requirement is established by Assembly Bill 2150, which adds section 1797.197b to the Health and Safety Code. Employers must pay for the training and keep it separate from the existing CPR curriculum.

The new statute applies to any employer operating in California that requires CPR certification training, regardless of size. Moreover, having licensed clinical personnel on site does not, by itself, excuse an otherwise covered employer. The training must be an online video module approved by the Emergency Medical Services Authority (EMSA). The statute identifies modules offered by the American Heart Association and the American Red Cross as examples, but regardless of the provider, each module still requires EMSA approval and must cover the signs and symptoms of an opioid overdose, appropriate response actions including emergency procedures, and proper administration of naloxone or another FDA-approved opioid antagonist.

Existing training can satisfy the requirement. An employee who has completed CPR, first aid, or other training that EMSA determines meets or exceeds the content standards is deemed compliant, and the employer need not provide a separate module, provided it maintains documentation of the qualifying program or certification. EMSA may establish a process through which training providers, certifying bodies, and employers can request that determination.

Completing the training does not itself create a duty, authorization, or expectation that an employee will administer naloxone, and any applicable scope-of-practice and medication administration rules remain unchanged by AB 2150. The statute does not specify a completion window tied to hiring or CPR certification, or establish a recurring training interval. Nor does it separately address wages for time spent completing the training, though mandatory training time generally constitutes hours worked for nonexempt employees under California law. EMSA’s role is limited to approving content, with no part in monitoring or enforcing employer compliance.

For employers that already require CPR certification, AB 2150 adds a second training obligation. Whether an employer can rely on its employees’ existing training will turn on EMSA’s equivalency determination and the documentation the employer maintains.

This publication is published by the law firm of Ervin Cohen & Jessup LLP. The publication is intended to present an overview of current legal trends; no article should be construed as representing advice on specific, individual legal matters. Articles may be reprinted with permission and acknowledgment. ECJ is a registered service mark of Ervin Cohen & Jessup LLP. All rights reserved.

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