In 2024, the state of New York passed the Warehouse Worker Protection Act (WWPA) in response to increasing concerns over warehouse worker safety and injuries. The law aims to create safe conditions for employees working in fast-paced distribution environments, with a focus on minimizing the risk of musculoskeletal injuries and disorders.

Starting June 1, 2025, employers operating large warehouses in New York must comply with the WWPA’s new requirements.

Covered Employers

The WWPA applies to employers who directly or indirectly employ or have control over the wages, hours, or working conditions of either:

• 100 or more employees at a single warehouse location; or
• 1,000 or more warehouse employees across all New York warehouses.

Warehouses covered by the law include those that fall under the North American Industry Classification System codes for warehousing and storage. This includes facilities such as general warehouses, e-commerce fulfillment centers, wholesale distribution hubs, and courier operations, where employees perform tasks like receiving, stocking, packaging, sorting, labeling, or shipping merchandise.

What Is Required

The WWPA aims to improve safety for warehouse employees by addressing the risks associated with fast-paced working environments and repetitive motion injuries. To that end, employers must implement a comprehensive injury reduction program at each covered warehouse facility. This program must include the following five components:

1. Worksite Evaluations – Employers must ensure that each job, process, or operation involving manual materials handling undergoes a written worksite evaluation by a qualified ergonomist. These evaluations should identify risk factors such as rapid pace, forceful exertions, repetitive motions, twisting, bending, and awkward postures that could lead to musculoskeletal injuries and disorders. Evaluations must be conducted initially by June 19, 2025, and reviewed and updated annually.
2. Control of Exposures – Upon identifying risk factors, employers are required to correct them in a timely manner. If corrections necessitate more than thirty days, a schedule for the proposed corrections must be provided.
3. Employee Training – Employers must provide annual injury reduction training to all employees involved in manual materials handling tasks. This training should cover early symptoms of musculoskeletal injuries, risk factors, methods to reduce risks, and the employer’s injury reduction program. Training must be conducted during normal work hours, without loss of pay, in a language and vocabulary that workers understand.
4. Onsite Medical & First Aid Practices –For warehouses with on-site medical offices or first aid stations, employers must ensure these are staffed with medical professionals operating within their legal scope of practice. Employers are also required to consult with a licensed medical consultant to evaluate and oversee protocols for the identification and treatment of musculoskeletal injuries and disorders. The medical consultant must review and update these protocols annually.
5. Employee Involvement – Employers must involve employees and their designated representatives in the development and implementation of all aspects of the injury reduction program. This includes consulting with workplace safety committees, where established, and providing access to worksite evaluations and related records. All documents should be provided in writing, both in English and in the primary language identified by each employee.

In addition to implementing the injury reduction program, employers must also maintain accessible copies of worksite risk evaluations at the warehouse and make them readily available to workers. Upon request, these documents must be provided to employees in writing, free of charge, and within one business day of the request. 

What Employers Should Do Now to Prepare

As we approach the WWPA’s effective date, employers should take proactive steps to ensure compliance with the WWPA’s requirements. Key actions include: 

• Determine if You’re Covered: Review your warehouse headcount and facility types. If you operate high-volume distribution, fulfillment, or shipping centers and meet the employee thresholds, then the law likely applies.
• Establish or Update Your Injury Reduction Program: Ensure your warehouse has a written injury reduction program that meets the requirements of the WWPA as outlined above.
• Set Up Employee Training: Develop an annual training program for warehouse employees that covers safe work practices and details of the injury reduction plan.
• Establish a Request Process: Be ready to respond to employee requests for worksite evaluations and quota records.