What does AB 2150 require from California employers?
Written by Justin Alcalde, AHA and American Red Cross instructor, CPR West Covina
Price and class details checked .
AB 2150, signed September 20, 2026, adds section 1797.197b to the California Health and Safety Code. Starting January 1, 2027, an employer that requires its employees to have CPR certification training must also have those employees take a naloxone training, and the employer pays for it. The training is a separate online video module approved by the state Emergency Medical Services Authority (EMSA). As of October 19, 2026, EMSA has not published an approval process or a list of approved trainings.
For your team's own study, our SOS First Aid app is a pocket study guide built on the 2025 AHA guidelines with opioid emergencies in its BLS section, but no course or product, our app and classes included, satisfies AB 2150 yet, because EMSA has not approved a module.
What the law says
| Question | What section 1797.197b says |
|---|---|
| Which employers | An employer operating in California that requires CPR certification training of its employees. |
| Which employees | The employees the employer requires to have CPR certification training. Not every employee, and not everyone who happens to hold a CPR card. |
| What training | An online video module on the use of naloxone, approved by EMSA and separate from the CPR course. The law names modules offered by the American Heart Association or the American Red Cross as examples, "including, but not limited to" them. |
| What it must cover | Recognizing the signs and symptoms of an opioid overdose, the right response actions including emergency procedures, and how to give naloxone or another FDA-approved opioid antagonist. |
| Another way to qualify | An employee whose CPR, first aid or other training comes from a program EMSA finds meets or exceeds those minimums is covered, as long as the employer keeps documentation of that program or certification. |
| Who pays | The employer pays for the training. |
| Duty to give naloxone | None. The law says the training is for education and preparedness only and does not create a duty or expectation for any employee to give naloxone. |
| Start date | January 1, 2027. The bill has no urgency clause and no later start date, so it takes effect under California's standard rule for new laws. |
The bill is Chapter 384, Statutes of 2026. Its home is the Health and Safety Code, not the Labor Code: Senate amendments on August 21, 2026 moved it there before it passed.
AB 2150Who enforces it
Earlier versions of the bill gave enforcement to Cal/OSHA. The August 21, 2026 Senate amendments removed that. EMSA's role is limited to approving training content, and the law says EMSA does not administer, enforce or monitor whether employers comply. The Legislative Counsel's summary says a violation would be a crime, but section 1797.197b does not name a fine or a penalty. Some early summaries, and an EMSA legislative tracker page we checked on October 19, 2026, still describe Cal/OSHA enforcement; that language is not in the law that was signed.
AB 2150Where things stand on October 19, 2026
- EMSA has not published an approval process or a list of approved naloxone modules. We checked its home, legislation, EMS professionals and training programs pages.
- No course can say it satisfies AB 2150 yet. That includes ours: our classes are not EMSA-approved AB 2150 modules, because no approved list exists.
- The law sets no deadline for EMSA to approve trainings.
The law also leaves some questions open. It does not define "employer," so whether it reaches public agencies such as school districts and cities is a question for your attorney. It does not say whether the training is one time or repeats, when current employees and new hires must finish it, or what happens before EMSA approves a module. It says "employees," and does not mention volunteers, interns or contractors.
AB 2150What employers can do now
- List who you require to have CPR training.
Those are the employees the law reaches. Go role by role, shift by shift and site by site, and include anyone whose job requires a CPR card.
AB 2150 - Budget for the training.
The law says each employer pays for the costs of the training, so plan for it in your 2027 training budget.
AB 2150 - Watch EMSA for the approved list.
The module has to be approved by EMSA. Check EMSA's site for an approval process or a list of approved trainings before you buy any naloxone module sold as meeting AB 2150.
EMSA - Keep documentation.
Keep a record of who you require to be CPR trained and what training each person completes. If you rely on a CPR or first aid program EMSA finds meets the minimums, the law says you must keep documentation of that program or certification.
AB 2150 - Plan the response, not just the training.
Decide where naloxone and the AED are kept and who calls 911. Our workplace plan for an opioid overdose walks through it.
- Consider hands-on practice as a separate step.
Practicing with an instructor is a good idea on its own, but it is not the EMSA-approved online module AB 2150 asks for, and it does not replace it. We teach the Red Cross naloxone Skill Boost (see CPR and Narcan training in West Covina) and train teams at your site through onsite CPR training for employers.
AB 2150 is not the first aid kit law
| Law | What it is about | Status |
|---|---|---|
| AB 2150 (2026), Health and Safety Code 1797.197b | Naloxone training for employees whose employer requires CPR certification training. | Takes effect January 1, 2027. No approved trainings published yet. |
| AB 1976 (2024), Labor Code 6723 | Naloxone, or another FDA-approved opioid antagonist, and instructions in workplace first aid materials. Cal/OSHA must submit a draft rule before December 1, 2027, and the Standards Board is to consider adopting it on or before December 1, 2028. | A rulemaking order, not a stocking requirement today. |
Learn it before you need it
Our SOS First Aid app gives staff a way to study the BLS steps for opioid emergencies on their own, with practice quizzes, and a Pro subscription adds a certification tracker. For hands-on practice, we teach the Red Cross naloxone Skill Boost (CPR and Narcan training in West Covina) and offer onsite CPR training for West Covina employers. Neither the app nor these classes are EMSA-approved AB 2150 modules.
Questions people ask
When does AB 2150 take effect?
January 1, 2027. It was signed September 20, 2026, and has no urgency clause or later start date, so it takes effect under California's standard rule for new laws.
Does every employee need naloxone training under AB 2150?
No. It covers the employees an employer requires to have CPR certification training, not every employee and not everyone who holds a CPR card.
Does the training have to come from the AHA or the Red Cross?
No. The law names AHA and Red Cross modules as examples, "including, but not limited to" them. What matters is approval by EMSA.
Who pays for AB 2150 training?
The employer. The law says each employer shall pay for the costs of the training.
Will employees be required to give naloxone?
No. The law says the training is for education and preparedness only and does not create a duty or expectation for any employee to give naloxone.
Does Cal/OSHA enforce AB 2150?
Cal/OSHA enforcement was in earlier versions of the bill and was removed by Senate amendments on August 21, 2026. EMSA approves the training content, and the law says EMSA does not enforce or monitor employer compliance.
Does AB 2150 require naloxone in first aid kits?
No. That is a separate law, Labor Code 6723, which orders Cal/OSHA to propose a first aid kit rule before December 1, 2027. See our workplace plan.
Is your class approved for AB 2150?
No. As of October 19, 2026, EMSA has not published an approved list, so no course can claim to satisfy AB 2150 yet. Our classes are hands-on practice, offered separately from the law.
Related guides
- A workplace plan for an opioid overdose
- CPR and Narcan training in West Covina
- Can you get in trouble for helping? California law
Sources
This page is general information, not legal advice. Ask your attorney or EMSA how the law applies to you.
- California AB 2150 (2026), Chapter 384, Statutes of 2026, adding Health and Safety Code section 1797.197b (bill text, history and analyses)
- Office of the Governor: Governor Newsom issues legislative update (September 20, 2026)
- California Constitution, article IV, section 8 (when a statute takes effect)
- California Emergency Medical Services Authority: Training programs (checked October 19, 2026)
- California AB 1976 (2024), adding Labor Code section 6723 (naloxone in workplace first aid materials)