When unregulated substances are present in the workplace, they can be a risk to workers. Employers need to be aware of the potential for exposure to unregulated substances (also known as illicit drugs or street drugs) and implement controls to protect workers.

What are unregulated substances?

Unregulated substances are non-prescribed substances with inconsistent composition and potency of ingredients that are not controlled through regulated manufacturers and suppliers. They include opioids, sedatives, stimulants, and psychedelics. Examples of unregulated substances include fentanyl, fentanyl analogs, and W-18 that, when used alone or in combination with other substances, have an increased toxic nature for the people using them and with it the risks associated with worker exposure.

How workers can be exposed

Workers may be exposed to unregulated substances in the following types of workplaces:

• Places where unregulated substances are known or expected to be present, such as supervised consumption and overdose prevention sites
• Places where it is reasonable to anticipate that unregulated substances may be present and consumed, such as supportive housing and social services facilities
• Spaces where workers may occasionally be exposed to unregulated substances as a result of members of the public consuming substances on the premises, such as hospitals, community centres, libraries, and restaurants

Unregulated substances can be in powder, crystal, pill, or liquid forms. The risk of worker exposure depends on the substance and how it is consumed by a person. When substances are smoked or vaporized nearby, workers can be exposed to second-hand smoke, especially in enclosed or poorly ventilated spaces.

Other potential routes of worker exposure include:

• Skin or mucous membrane contact with contaminated surfaces
• Ingestion when substances are present where workers are eating or drinking
• As a result of needle sticks or other sharps injuries

How to reduce the risks

Employers must assess how a worker could be exposed and implement ways to eliminate or reduce the risk to workers.

Some substances, including fentanyl and fentanyl citrate, have a B.C. exposure limit. If there is evidence that indicates workers may be exposed above the exposure limit, employers must take immediate action to protect workers, including implementing an exposure control plan that meets the requirements of section 5.54 of the Occupational Health and Safety Regulation. See OHS Guidelines G5.48-3 to G5.59 for information about controlling exposure.

For supervised consumption or overdose prevention sites where unregulated substances are expected to be present, control measures may include restricting worker access to consumption areas, installing effective ventilation, and providing respiratory protection. Follow the guidance of the BC Centre for Disease Control (BCCDC), health authorities, and/or health and safety advisors with expertise in controlling exposures of this type.

For other workplaces, follow the hierarchy of controls to prevent or minimize the risk to workers. In workplaces where unplanned consumption may occur, elimination or substitution may not be possible. The following are examples of other types of controls that can be applied.

Engineering controls

• Evaluate and maintain ventilation equipment to ensure it is working as designed, especially in areas where consumption is most likely to occur (e.g., common areas, bathrooms).
• Consider the use of portable air cleaning units.

Administrative controls

• Use signage to communicate rules for consumption (e.g., no smoking allowed of any substance). Where available, provide clients and visitors with information on how to access nearby supervised consumption sites or overdose prevention services.
• Establish safe work procedures for responding to drug consumption events in a way that minimizes risks to workers. This may include procedures for disposing of drug use supplies and responding to medical emergencies. Ensure workers are trained in these procedures.
• Develop procedures for cleaning spaces where unregulated substances have been consumed.
• Keep workers’ eating and rest areas separate from publicly accessible spaces where consumption may take place.
• Where possible, control public access to areas that could be used to consume unregulated substances.
• Train workers in how to recognize and report the presence of any substances they suspect may be hazardous.

Personal protective equipment

Personal protective equipment (PPE) may be needed in combination with other controls for certain types of work. PPE can include:

• Respiratory protection during cleaning and in areas where consumption activities have taken place
• Skin protection (such as nitrile gloves) for workers who may come in contact with contaminated surfaces

What to do if a worker is exposed

The effects of short-term exposure to second-hand smoke or residue from unregulated substances in the workplace are usually mild and temporary. Some symptoms experienced after exposure may be unrelated to the primary health effect of the substance and do not indicate drug poisoning (overdose). Because the effects of longer-term exposures are unknown, the following measures apply:

Employers

• Train workers in the procedures to follow if they are exposed.
• Investigate all reports of unsafe conditions or where workers report symptoms resulting from exposure to unregulated substances.
• Review your risk control measures and make sure they are adequate to protect workers.

Workers

• If you see evidence of recent consumption (e.g., visible smoke, odour), follow your employer’s procedures for minimizing exposure.
• Wash your hands with soap and water if you may have touched contaminated surfaces, and put on gloves before cleaning up the area.
• Report any exposure to your supervisor and seek first aid if necessary.

Involve workers in risk management

Open and respectful communication is essential to maintaining a safe and healthy workplace. Encourage workers to speak up, and help them feel comfortable reporting their concerns about unregulated substance exposure. Respond promptly to concerns raised, and let workers know the steps you have taken to help keep them safe.

Consult with your joint health and safety committee, worker representative, or other workers when you develop your approach to managing risk. Your workers have first-hand experience about the risks and procedures in your workplace. Having meaningful conversations with workers about all aspects of managing risk helps make your response more effective.

Resources

New exposure limit for fentanyl and fentanyl citrate

A new exposure limit for fentanyl is in effect for B.C. workplaces as of January 29, 2025. This resource provides more information about the exposure limit and what it means for employers.

Publication Date: Jan 2025

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Web resources

The BCCDC’s webpage Harm Reduction Clinical Resources has information and resources that can help employers understand the risks, including Post-Exposure Management Guidance (PDF) and OD Prevention Services Guide (PDF).

The Government of British Columbia's webpage Mental Health and Substance Use Information and Publications also has resources that can help employers, including Overdose Prevention Services Minimum Service Standards (PDF) under the heading “Overdose Emergency.”