“Strict Enforcement” of Pittsburgh’s Paid Sick Leave Act is Coming…Do Your Policies Comply?

On March 15, 2020, Pittsburgh’s Paid Sick Leave Act (the “Act”) went into effect. It is understandable if you do not remember this, though, as the global pandemic became more noteworthy to most. However, the Act is back in the spotlight.  On January 3, 2024, the City of Pittsburgh’s Office of Equal Protection (OEP) announced that it will begin strict enforcement and compliance checks for local businesses to ensure they are complying with their obligations under the Act.

Under the Act, employees accrue paid sick time at the rate of one hour for every 35 hours worked in Pittsburgh unless the employer provides a faster accrual rate. For employers with fewer than 15 employees, employees may accrue up to 24 hours of paid sick time in a calendar year. For employers of 15 or more employees, employees may accrue up to 40 hours of paid sick time in a calendar year. In addition to the above accrual requirements, there are compliance provisions under the Act, such as carryover and record keeping requirements. 

The January 3 OEP announcement stated that they will conduct compliance investigations into food service businesses according to zip code, starting with zip codes 15201 and 15203, very soon. If you own a food service business in the City of Pittsburgh, be prepared. Although the OEP is reportedly focused on the food service industry now, that does not mean that other businesses are exempt. In terms of coverage, the Act applies to all full- and part-time employees working within the geographic boundaries of the City of Pittsburgh, unless they are independent contractors, state and federal employees, members of a construction union covered by a collective bargaining unit, or seasonal employees. As such, all employers need to be prepared for enforcement and compliance checks.

Should you have any questions about company’s handbook or policies, please reach out to Anthony Judice at (412) 227-0264 or ajudice@smgglaw.com, or any of the attorneys in the firm’s employment practice group.

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