Effective June 2025: What You Need to Know About the NY State Warehouse Worker Injury Reduction Program (WWIRP)

At the start of 2025, New York State Legislature passed an amendment bill expanding the 2022 Warehouse Worker Protection Act. This new amendment, which comes into effect on June 1, 2025, requires employers to implement an injury reduction program aimed at identifying and minimizing the work-related risks of musculoskeletal disorders among workers.

With a focus on manual material handling tasks, you may be wondering if you are affected by this bill and what it means for your workforce. Read on to find out the information you need to move forward.

An Overview of the New York Warehouse Worker Injury Reduction Program

The Warehouse Worker Injury Reduction Program (WWIRP) is an amendment to a specific section of NY Labor Law (Article 21-A). The new amendment (Section 789) expands warehouse worker protections with the goal of reducing the disproportionately high rates of musculoskeletal disorders found among warehouse workers.

The WWIRP requires employers to implement an injury reduction program aimed at identifying and minimizing the risks of work-related musculoskeletal disorders among workers engaged in manual material handling tasks.

Key elements of the WWIRP include:

• Create and Maintain Work Site Evaluations
• Control Exposures in the Workplace
• Provide Injury Reduction Training
• Provide Appropriate Onsite Medical and First Aid
• Working with Employees to Develop these Programs

Workplace injuries in New York’s warehouse industry can be a significant burden for employees and their families and cause major obstacles for employers. By codifying injury prevention programs across the state, workers can go to work knowing they will be safe, and employers can share and improve injury prevention strategies.

Review key definitions from the Warehouse Worker Protection Act on the New York State Department of Labor website.

What Businesses are Effected By the WWIRP?

The WWIRP is not a general law for every single business in New York, but it can be used as a great guideline for companies looking to implement injury prevention. Specifically, the law applies to employers who directly or indirectly employs or have control over the wages, hours, or working conditions of:

1. 100+ employees at a single warehouse distribution center
2. Or 1000+ employees across one or more warehouse distribution centers

Focused on warehouse distribution centers, the law addresses the fast-growing warehousing industry which has seen 34% growth since February 2020, beating out other transportation related industries by a significant margin. Warehouse workers also experience serious injuries at a rate 5x higher than average private industry. Addressing worker safety early and comprehensively is a boon to workers and employers.

How to Comply With New Injury Reduction Program Requirements

To address injuries in the workplace, companies need a plan. An effective injury reduction program must identify and minimize the risks of musculoskeletal disorders in the workplace. While the WWIRP focuses on manual material handling tasks, lessons from each of the requirements can be applied across organizations for improved outcomes.

For an in depth look at the requirements of this law, and how to meet them, download our WWIRP checklist for employers.

Written Work Site Evaluations

A worksite evaluation allows for an outline of jobs and tasks where manual material handling is present. This gives you the starting information you need to identify risk factors in your workplace and actively address them.

Industrial ergonomics assessments identify primary job tasks and sub-tasks, quantify associated risk factors, and pinpoint opportunities for improvement. These insights form the foundation for implementing exposure controls.

An evaluation must:

• Determine relevant job tasks and functions that involve material handling
• Be conducted by a competent professional
• Identify risk factors
• Be reviewed and updated annually and with the introduction of new jobs
• Be accessible to workers

Control of Exposures

With the information from a work site evaluation in-hand, addressing those factors is the next step in improving the workplace. The WWIRP provides guidelines for how this must be approached with timelines in place.

• Implement controls for risk factors that cause/or may cause musculoskeletal disorders.
• Reduce risks within 30 days of identification (or have a long-term improvement plan)
• Follow the Hierarchy of Controls
• Keep records to document risk available to employees

Injury prevention programs focus on proactive prevention. By identifying risk factors, you are able to proactively address issues before the onset of discomfort and injury decreasing healthcare costs across the board. While upfront time and investment may be difficult to stomach, injury prevention is always profitable and right in the long-term.

Employee Training

Even the best injury prevention programs can fall apart with a lack of communication. That communication begins and ends with training. The upcoming bill mandates several key factors on training:

• Schedule and conduct annual training for all employees and supervisors involved in relevant tasks
• Verify that training includes information on:
  • early symptoms of musculoskeletal disorders 
  • importance of early detection
  • ergonomic risk factors
  • appropriate controls
  • summary of medical procedures (including onsite first aid)
  • information on programs
  • employee rights
• Ensure that training and materials are available in workers’ language and vocabulary

While annual training is adequate for the purposes of the bill, a higher frequency rate can reduce the “forgetting curve” where any learner rapidly forgets new information over time. By implementing consistent monthly training to reinforce topics, you can drastically reduce the information your employees forget and keep them safer in the process. Hands-on training, with engaging and relevant tasks can help facilitate retention. This can also be used as an opportunity to get feedback on your programs to make sure they are having the right effect in your workspace.

Onsite Medical and First Aid Practices

WWIRP mandates a number of requirements around onsite medical and first aid. These practices must be overseen by an appropriate medical professional.

• Workers may select their own care providers
• Any examination is performed for the purpose of the injury reduction program
• Annually obtain/update a written evaluation from a medical consultant regarding your program
• Obtain a summary of treatment protocols covering specific requirements
• Staffed medical professionals have seen necessary information and risks in action
• Care is provided without delay
• Ensure there is no discrimination or retaliation for reporting injury, illness, or health & safety concerns

Employee Participation

A key component of the bill is keeping employees informed and involved in the injury prevention process. Keeping employees involved in the process is vital to creating a truly-effective injury prevention program. The perspective of the employee is invaluable in identifying risk factors, understanding program effectiveness, and keeping risk low. Employee and safety committees should be consulted during the development AND implementation of any injury reduction program.

By consulting employees who perform identified high risk job tasks employers can gather recommendations for improvements. All ergonomic safety documents, medical treatment procedures, and other relevant documentation should be available to employees in their primary language.

How to Get Help Starting an Injury Reduction Program

Creating a program from scratch is possible with the right tools. A comprehensive injury prevention provider, like Briotix Health, is staffed with the professionals you need, with the programs that go above and beyond regulated standards to save time, costs, and employees.

Briotix Health provides comprehensive injury prevention solutions that align with Section 789 of the New York Labor Law. Our services support all key areas required by the law, including worksite evaluations to identify ergonomic risks, exposure control strategies to minimize injury potential, employee training to ensure safe work practices, and onsite medical and first aid programs for effective injury management.

Additionally, Briotix Health emphasizes employee involvement, helping businesses meet compliance standards while fostering a safer, healthier workplace.

Contact our injury prevention specialists to learn more about how Briotix Health can help.