The Office of Labor Policy & Standards, the office responsible for enforcing NYC’s employment laws, recently released guidance on the new Temporary Schedule Change Law. The law, which took effect on July 18, 2018, was passed with little fanfare, but left employers asking many questions about how to effectively implement its requirements. In particular, employers were left scratching their heads over the law’s “shoot first, ask questions later” procedural requirements and an employee’s nearly unhindered ability to disrupt their operations at a moment’s notice.
The law also came on the heels of the passage of several other New York State and New York City laws aimed at accommodating employees’ personal obligations and improving work-life balance, including laws providing for paid sick and safe leave, paid family leave, fair workweek and scheduling requirements, protection against caregiver and familial discrimination, and the requirement to accommodate pregnancies, disabilities and other personal obligations. The newly-released guidance is likely to intensify employer concerns, but with the law now in effect employers must work (once again) to update their policies, procedures and practices as necessary not only to comply with its requirements, but to minimize disruption to their operations.