Philadelphia recently amended its fair employment practices ordinance to expand protection for employees against discrimination based on pregnancy, childbirth, or a related medical condition. Among other things, employers must provide a written notice of rights to all existing employees by April 20, 2014, and to all new hires thereafter. For more on the new ordinance, which took effect on January 20, 2014, see our prior client alert Philadelphia Latest to Protect Pregnancy, Require Reasonable Accommodation.
The Philadelphia Human Relations Commission recently published the required form of notice on its website. Employers should take steps now to include the notice in their new hire packages. Employers also should plan to distribute the notice to employees on or before April 20th. Although the new ordinance is silent on the method of distribution, electronic notice likely is permissible; if an employer sends the notice by email, it should obtain acknowledgment of receipt by electronic means.
While employers are not required to post the notice, the new ordinance encourages posting in an area accessible to employees. Thus, employers also may want to consider including the notice on any bulletin boards where other postings are located; adding a pregnancy accommodation policy to their employee handbooks; and/or including the notice on their intranet pages if other policies are posted there. Please contact your Proskauer relationship attorney for further guidance on compliance.