Seyfarth Synopsis: A workplace violence prevention law passed by the New York State legislature in June 2024, signed into law by the Governor in September 2024, and amended in February 2025 is set to take effect in part on June 2, 2025. On May 29, 2025, just days before the law’s effective date, the State released a website, which includes FAQs, a model policy, and model training.
As previously detailed here and here, on September 5, 2024, New York Governor Kathy Hochul signed a bill (Assembly Bill A8947C) that will impose significant workplace violence prevention requirements on retail employers effective June 2, 2025, including policy and training requirements. The law specifically indicates a separate effective date—January 1, 2027—for the “silent response button” requirement to allow employers more time to prepare for implementation.
With the June 2, 2025 effective date fast approaching, employers have been anxiously awaiting a forthcoming website from the State, which the State promised would include: (1) a model policy; and (2) a model training. On May 29, 2025, the State released the website, which indeed includes a model policy, model training, and FAQs.
The State’s new materials clarify several key requirements:
- Covered Retail Employers. The website confirms, “[r]etail stores include any store that sells goods directly to the public at retail. Retail stores do not include businesses that primarily sell food to be eaten on-site, such as restaurants.”
- Only Retail Employees Count. The FAQs clarify “[t]he law only covers employers with 10 or more retail employees in New York State.” Therefore, as the FAQs explain, a store employing 12 total employees, “seven [of whom] are retail employees while the other five provide marketing and administrative support” would not be covered by the law. However, the FAQs note that “all employers are encouraged to take steps to reduce the risk of workplace violence.”
- Employers with 10 Employees in the Aggregate Count. The website confirms, “The Retail Worker Safety Act applies to all New York State employers who employ 10 or more employees to work at a retail store (or stores).” More specifically, “This law covers employers with 10 or more retail employees anywhere in New York State, regardless of if those employees are working across multiple store locations.” Therefore, as the FAQs explain, an employer with 10 total employees across multiple stores is covered by the law.
- Training Cadence for Smaller Employers. The amendments ease the cadence by which employers of fewer than 50 employees must provide workplace violence prevention training. The amendments require that such small employers provide trainings upon hire and once every two years thereafter (differing from the upon hire and annual training requirement for all other covered employers with 50 or more employees).
- Policy Provision. The FAQs confirm “[t]he retail workplace violence prevention policy needs to be distributed to employees when they are first hired and once a year after that.”
- Languages for Model Policy. The amendments direct the Labor Commissioner, in crafting a model policy, to determine the “twelve most common non-English languages spoken by limited-English proficient individuals in the state, based on the data in the most recent American Community Survey published by the United States Census Bureau and published online by the New York state office of language access.” As of the date of publishing, the State has not yet made available non-English model policy or training materials.
