Is Your Ergonomics Program Compliant With the Recent New York Warehouse Worker Injury Reduction Act?

Musculoskeletal injuries never grab the media headlines, but they are a major driver of the injury rate in warehouse workers.

As of June 1, 2025, the New York Department of Labor has set ergonomics-related guidelines and regulations to ensure workplace safety and health. While there still isn’t a specific ergonomics standard for warehouses, employers are now required to comply with the state’s General Industry Safety and Health regulations, 12 NYCRR Part 800.

This law requires warehouse employers that employ, directly or indirectly, at least 100 employees at a single warehouse distribution center or at least 1,000 employees at more than one warehouse distribution centers in New York State to develop formal injury reduction programs, train employees on ways to reduce injuries, and work with their employees to help identify and minimize the risks of musculoskeletal injuries in the workplace. Additionally, by June 19, 2025, covered employers must enlist the help of a qualified ergonomist to provide an evaluation of risk factors that cause or are likely to cause musculoskeletal injuries.

If you run a warehouse in New York State with 100+ employees in a single facility, or 1,000+ across multiple sites, this law applies to you.

To ensure compliance and help create a safer work environment, New York State warehouses should focus on the following ergonomics requirements:

Worksite evaluations

Ergonomic evaluations should be conducted by a qualified ergonomist, who will evaluate each job, process, or operation and provide a written evaluation of risk factors that have caused or are likely to cause musculoskeletal injuries and disorders. The Act notes that the evaluation shall include, but not be limited to, the following risk factors that cause or are likely to cause musculoskeletal injuries and disorders:

• Rapid pace
• Forceful exertions
• Repetitive motions
• Twisting
• Bending
• Awkward postures
• Combinations of the above

Control of exposures

Employers must consider engineering controls, redesign work stations, provide adjustable fixtures, or redesign tools. Administrative controls, such as job rotation, reduced work pacing, or additional work breaks, must also be considered.

Covered employers must document any actions taken to control or minimize risks. The Act also requires employers to provide these records to employees and their representatives upon request.

Fix identified risks within 30 days

If a risk can’t be addressed immediately, you’ll need a documented corrective action plan. This includes a clear timeline, risk reduction strategies, and evidence of follow-up. Simply identifying the issue isn’t enough; state regulators want to see progress.

Injury reduction training must be provided to all employees involved in performing manual materials handling jobs and tasks at the worksite, during normal work hours, and without any loss of pay.

Trainings should include:

• Early symptoms of musculoskeletal injuries
• Musculoskeletal injury and disorder risk factors and exposures at work, including hazards posed by excessive rates of work
• Methods to reduce risk factors
• Your program to identify risk factors for preventable musculoskeletal injuries and disorders, including the protocols for medical treatment approved by the employer’s medical consultant
• Rights and function of workplace safety committee
• Rights of employees to report any risk factors, hazards, injuries, or health and safety concerns, as well as unlawful retaliation

Training required under the Act shall be provided in a language and vocabulary that all employees understand and shall be provided annually. Covered employers must also provide training to supervisors.

Medical and first aid station staffing

Another component of the Act requires warehouses with on-site medical or first aid stations that treat musculoskeletal injuries and disorders to be staffed according to New York State supervision requirements and with medical professionals operating within their legal scope of practice. Note that nothing in the Act infringes on the rights of employees to be treated by an authorized physician of their choosing.

Employee involvement

The required injury reduction program must have a means of employee involvement. Specifically, covered employers must ensure that employees and their designated representatives are consulted before and during the development and implementation of all aspects of the program. Employers are required to obtain recommendations from employees who regularly perform manual materials handling jobs and tasks on possible risk factors and workplace changes that can reduce current risk factors.

This is no longer an optional best practice; it’s enforceable. Failure to comply can lead to state investigations, fines, and reputational damage.

If you need help developing an ergonomics program, conducting training, or performing ergonomic assessments, Walden can help. Give our EHS Director, David Garner, a call (860-781-7141) or email dgarner@walden-associates.com.