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Protecting your workforce: Understanding new legislation for New York warehouse employees

The Warehouse Worker Injury Reduction Program (WWIRP) — effective June 1, 2025 — mandates employers to develop and implement formal injury reduction programs.

02/28/2025 · 5 minute read

On December 21, 2024 the New York State Senate established the Warehouse Worker Injury Reduction Program as an amendment to the state’s labor law, signed into action by Governor Kathy Hochul. This will require warehouse employers in New York to proactively develop injury reduction strategies to safeguard their workforce from musculoskeletal injuries.

Concern around the impact of musculoskeletal injuries — such as pain, impaired mobility, and reduced productivity and quality of life — on warehouse employees has led to the introduction of new requirements for employers by New York State under the Warehouse Worker Protection Act, enacted in June 2023.

The Warehouse Worker Injury Reduction Program (WWIRP) — effective June 1, 2025 —  mandates employers to develop and implement formal injury reduction programs. Aimed at reducing musculoskeletal injuries, the law requires covered employers enlist qualified ergonomists to help create these programs by June 19, 2025. All employers that directly or indirectly employ at least 100 employees at a single warehouse or 1,000 employees across multiple warehouses are impacted by the law.

To remain compliant with WWIRP, warehouse employers should ensure they understand key requirements before they go into effect in the coming months, proactively evaluate their warehouse sites, and implement strategies to identify and minimize the risks of musculoskeletal injuries to their employees.

Key requirements of the WWIRP

The WWIRP requires covered employers to take proactive steps to mitigate risks associated with musculoskeletal injuries. Some of the defining components of the program that organizations should be aware of include:

A comprehensive injury reduction program: Covered employers must create formal injury reduction programs that continuously evaluate and mitigate the risk of musculoskeletal injury in the workplace. These programs should include:

  • Worksite evaluation: Employers must engage a qualified ergonomist to conduct a thorough, written evaluation of each job and operation within the warehouse, detailing risk factors that could cause or contribute to musculoskeletal injuries. This evaluation must identify risk factors related to the pace of work, forceful exertions, repetitive motions, twisting, bending, or awkward postures that could lead to injuries. Employers are required to correct identified risks within 30 days or provide a revised action plan to minimize the exposure as much as possible, such as redesigning workstations or implementing better job rotation. Worksite evaluations must be reviewed and updated annually to ensure ongoing compliance and effectiveness in reducing injury risks.
  • Injury reduction training and employee engagement: All employees who handle materials manually, along with their supervisors, must undergo annual training focused on:  
  1. Recognizing the initial signs of musculoskeletal injuries and disorders.
  2. Factors and exposures related to musculoskeletal injuries and disorders in the workplace, including the dangers associated with excessive workloads.
  3. Strategies for preventing musculoskeletal injuries and disorders, encompassing both engineering solutions and administrative measures, such as regulating work pace and promoting regular scheduled and unscheduled breaks.
  4. The employer's program for identifying risk factors and prevention, which should include an overview of the medical treatment protocols endorsed by the employer’s medical consultant.
  5. Employees’ rights to report risk factors, hazards, injuries, and any health and safety issues.
  6. Protections against unlawful retaliation and discrimination in the workplace.

This training must also be paid and conducted during regular work hours, in a language that all employees can understand.

  • Onsite medical care: Warehouses with onsite medical facilities must ensure they are staffed according to state regulations and that medical professionals are operating within their legal scope of practice. Employers must also consult with a licensed medical consultant to evaluate and improve their onsite medical protocols for treating musculoskeletal injuries.

Strategies to remain compliant with the WWIRP

As these new requirements take effect, warehouse employers should begin making any necessary changes to their operations to support employee health and safety, and to specifically address the risks associated with musculoskeletal injuries. The following strategies can help organizations manage new requirements and avoid unintentional missteps:

  • Connect with qualified ergonomists: Qualified ergonomists, as described in the new legislation, can help you accurately identify your risks by conducting comprehensive worksite evaluations and recommending improvement plans tailored to your specific operations.
  • Prioritize employee education and engagement: Customized onsite and eLearning training around ergonomic practices can empower employees, supervisors, and managers to recognize potential hazards and encourage them to actively participate in creating a safer work environment.
  • Reevaluate injury reduction programs and strategies: Regular assessments allow organizations to identify areas for improvement, adapt to changing workplace conditions, and incorporate new best practices. By continuously monitoring and updating these programs, businesses can enhance their ability to prevent injuries, reduce associated costs, and foster a safer work environment. Engaging with knowledgeable advisors can provide valuable insights and support in maintaining compliance and optimizing the implementation of these critical safety measures.

By proactively addressing musculoskeletal risks and fostering a culture of safety, employers can not only comply with new requirements but also enhance the overall wellbeing of their workforce.

As the deadline to implement an injury reduction strategy approaches, it is crucial to begin preparing to ensure a smooth transition to these new requirements.

How Marsh can help

Marsh Advisory has certified professional ergonomists who are uniquely positioned to help your organization evaluate your worksite, identify risks, develop improvement plans, and provide ongoing support to meet new requirements.

With decades of experience, our certified professional ergonomists can work with you to enhance workplace safety and efficiency, providing tailored recommendations for improvement and customized eLearning capabilities and onsite training programs. Our comprehensive approach focuses on helping you to assess risks, implement effective solutions, and foster a culture of continuous improvement designed to reduce injuries and enhance employee performance.

To learn more, speak with your Marsh representative.

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