The Industrial Commission of Arizona’s (ICA) proposed rules under Arizona’s new paid sick time (PST) law incentivize employers to front load 40 hours of immediately-available PST or equivalent paid time off to each employee (24 hours for small employers). According to the ICA, employers who do that will be exempt from the PST law’s carryover and additional accrual requirements.

Notably, the exemption only applies to employers who front load at least 40 (or 24) hours to all employees. The PST law gives employers an alternative option to front load PST on an individualized basis in the amount an employee is expected to accrue that year, which may be less than 40 (or 24) hours for some employees. The proposed rules do not exempt those front-loading employers from the PST law’s carryover and additional accrual requirements.

The proposed rules are not final and may change before going into effect, but they provide valuable insight into how the ICA interprets the new PST law. The ICA will hold a hearing on the proposed rules on August 8 at 9:00 a.m. in the ICA auditorium in Phoenix. Employers may submit written comments until August 8.