New York 9/11 Notice Law Offers Counsel a Post-Disaster Blueprint

Corporate, legal, and government leaders across the country should study the framework of the New York State 9/11 Notice Act, created in 2023 to prevent the “forgotten victim” syndrome that so often follows manmade or natural disasters. They need to pay close attention because the next public health crisis is already being written into the fine print of environmental risk.

More than two decades have passed since the Sept. 11, 2001, terrorist attacks, but the crisis they unleashed is far from over. The toxic cloud that hung over lower Manhattan that day settled into the lungs, bones, and bloodstreams of hundreds of thousands of unsuspecting people—first responders, office workers, teachers, students, and residents.

Many are dying slow, invisible deaths, unaware that the symptoms stealing their lives were caused by the very toxic air they breathed in the days, weeks, and months after the towers fell.

The World Trade Center Health Program now recognizes 69 cancers linked to Sept. 11 toxins, many appearing decades earlier than expected. And research from Stony Brook University recently revealed something even more alarming: Survivors in their 50s are experiencing early-onset dementia, as their brains are aging prematurely because of their exposure.

We know these diseases are just the beginning. The damage was vast. The danger was hidden. All of this is why New York’s 9/11 Notice Act should be adopted by corporate risk managers, general counsel, and compliance officers nationwide.

Hesitation Hurts Health

Ask any Sept. 11 responder or survivor, and you’ll hear a version of the same line: “I didn’t think anything of it—I was just doing my job.” That mindset is why tens of thousands have failed to access the benefits created for them. The 9/11 Notice Act educates and reminds them that they matter.

The law directs New York City companies with 50 or more employees that operated below Canal Street in lower Manhattan to notify workers about how to register for the World Trade Center Health Program, get certified, and then access free health care and support.

A simple notification can lead to a potentially life-saving action. That’s why the notice must be in writing, include basic eligibility criteria, and provide contact information for the federal health programs.

That’s it. No elaborate red tape. No requirement to determine medical status. Just outreach, documentation, and care.

Identifying Former Employees

One of the most common challenges employers face when complying with the 9/11 Notice Act is deceptively simple: How do we find and contact people who worked here more than two decades ago? The answer lies in collaboration and modernization.

Human resources professionals and legal counsel should coordinate with payroll providers, retiree funds, and third-party benefit administrators to identify eligible individuals. These institutions often retain critical records that can validate work locations, trace employment history, and supply the contact information needed to fulfill the law’s notification requirement.

While this may involve multiple vendors, the process can be streamlined with the right internal leadership and a focused outreach plan. Payroll records, pension files, and COBRA plan administrators may all hold pieces of the puzzle. Engaging them early can reduce delays and ensure no one is left behind.

If a former employee has died, their surviving spouse or family members may still be eligible for benefits through the World Trade Center Health Program and the 9/11 Victim Compensation Fund. That’s why outreach efforts shouldn’t stop with a returned letter.

Follow-up protocols, survivor outreach, and collaboration with estate representatives can make all the difference for families who have already endured immense loss.

Emerging technologies can further transform this process. Artificial intelligence tools have the potential to sift through decades of archival data, organizing and cross-referencing personnel files, location logs, and benefits records with unprecedented speed and accuracy.

This is more than a legal obligation. It’s a call to action for institutions to embrace the tools available today to honor the sacrifices of the past.

Dignity and Disclosure

I’ve buried too many clients. I’ve spoken with too many spouses who never got the chance to say goodbye. And all too often, the dying words of those clients echo the same thought: I wish someone had told me.

The 9/11 Notice Act ensures someone finally will.

For legal and executive professionals, this isn’t just a compliance checkbox—it’s an opportunity to lead with integrity and protect lives before the harm becomes irreversible.

This article does not necessarily reflect the opinion of Bloomberg Industry Group, Inc., the publisher of Bloomberg Law and Bloomberg Tax, or its owners.

Author information

Michael Barasch is the managing partner at Barasch & McGarry and a leading 9/11 legal advocate. His office is—and was on Sept. 11, 2001—two blocks from Ground Zero.

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