Heavy Lift for Employers? Connecticut Sets New Limits on Warehouse Worker Productivity Quotas

Takeaways

• A new Connecticut law aims to prevent musculoskeletal injuries, allow workers legally required work breaks, and strengthen health and safety standards by limiting how large warehouse employers can use production quotas. 
• Beginning 07.01.26, the law requires employers to provide written quota disclosures, maintain multi-year records, and respond promptly to employee data requests.
• Covered employers should update their processes for onboarding new hires, implementing quota changes, and responding to employee data requests.

Related links

• SB 298, Secs. 50-57
• Bill Notification 2026-2 (3.6.26)

Article

On Mar. 3, 2026, Connecticut Gov. Ned Lamont signed SB 298, aiming to strengthen health and safety standards for warehouse workers. The new law goes into effect July 1, 2026.

The law imposes new requirements for certain in-state large warehouse distribution center employers that use productivity quotas and related performance tracking. It also emphasizes transparency, guardrails on quota design, recordkeeping, and employee access to “work speed data,” particularly where a quota may interfere with legally protected breaks or other workplace mandates.

Covered Employers

The law applies to employers that, at any time in the prior 12 months:

• Employ at least 250 employees at a single Connecticut warehouse distribution center; or
• Employ at least 1,000 employees across one or more Connecticut warehouse distribution centers.

A “warehouse distribution center” is a warehouse or group of warehouses as defined by specific North American Industry Classification System (NAICS) codes. Covered industries include:

• General warehousing and storage;
• Certain wholesale trade operations; 
• E-commerce and mail-order businesses; 
• Couriers and express delivery services; and
• Certain retail and home center operations.

Manufacturers with warehousing or distribution operations should review whether those activities fall within the law’s scope, even where the employer’s primary classification is manufacturing.

Quotas, “Work Speed Data”

The statute defines “quota” broadly. A quota may include any work-performance standard tied to required speed or output, including, but not limited to:

• Quantified tasks or materials handled within a defined period;
• Measurements of time performing tasks and not performing tasks;
• Time increments assigned to specific activities; or
• Rankings of employees against one another.

The statute also defines “work speed data,” which encompass the metrics an employer collects or analyzes to measure an employee’s performance against a quota. Examples of speed data include:

• The number of tasks performed; 
• Rate or speed of work; and 
• Time categorized as performing tasks versus not performing tasks.

The law excludes certain records unrelated to quota-based performance standards.

Key Employer Obligations

Written quota disclosures. Employers must now provide each employee with a written description of every quota that applies to the employee, including potential adverse employment actions for not meeting the required quota. Current employees must receive these quota disclosures by Aug. 1, 2026, and new hires must receive them upon hire. If an employer modifies a quota that creates a new quota, the employer must notify affected employees as soon as practicable before the change takes effect and provide a written description within two business days after the change is made.

Restrictions on quota design. The law prohibits quotas that:

• Prevent compliance with Connecticut’s meal period requirements;
• Interfere with bathroom use, including reasonable travel time to and from bathroom facilities;
• Measure total output over a time increment shorter than the employee’s full workday; or
• Rely solely on ranking employees against one another.

Manufacturing employers that measure productivity by shift, line, or hourly interval should be mindful that quotas must be based on a full workday. Employers should review their productivity measurements to ensure they do not operate as impermissible partial‑day quotas.

Recordkeeping. Employers must maintain for three years contemporaneous, accurate records of individual and aggregated work speed data, as well as copies of the written quota disclosures provided to employees. This requirement does not apply to employers that do not use quotas or collect or interpret work speed data.

Responding to employee requests. If an employee believes that meeting a quota has caused, or will cause, a violation of the law’s quota limitations, the employee may request quota descriptions and certain work speed data covering the prior 90 days.

Employers must provide the requested records as soon as practicable, but within 10 calendar days of receiving the request. Employers must also provide the records in English and in the employee’s primary language.

Anti-Retaliation, Enforcement

The law prohibits employers from taking adverse action against employees for requesting records or filing a civil action. It also establishes a rebuttable presumption of retaliation when an adverse action occurs within 90 days of protected activity, subject to specified conditions.

Employees and the Connecticut attorney general on behalf of a group of employees may bring a civil action to enforce the law. Remedies include damages, injunctive relief, and reasonable attorney’s fees and costs. Courts may also assess civil penalties.

Next Steps for Employers

Covered employers with warehouse operations in Connecticut should consider taking the following steps:

• Inventory existing quota‑based performance standards and the systems used to generate work speed data;
   
• Evaluate whether current quota designs risk interfering with meal periods, bathroom access, or compliance with the law’s full‑workday measurement requirement;
   
• Employers should involve IT and operations teams to understand what performance- or time‑based data is collected by automated systems, even if the data is not currently relied upon for disciplinary decisions;
   
• Prepare compliant written quota disclosures for current employees ahead of the statutory Aug. 1, 2026, deadline; and
   
• Establish processes for onboarding new hires, implementing quota changes, and responding to employee data requests.

If you have questions about Connecticut’s new requirements governing warehouse worker productivity quotas or other workplace issues, contact a Jackson Lewis attorney.