Workers' Comp, Payroll and Class Codes for a Self-Storage Facility

A self-storage facility's workers' comp premium is a rate per $100 of payroll, set by the class code your insurer assigns. An experience mod (a multiplier built from past claims, where 1.00 is average) then raises or lowers it, and the mod usually follows the business to you. The three surprises for new owners are the resident manager's apartment, roof work done by your own staff and the ownership change report. This guide is for a buyer who wants those right before the first audit.

Which of my employees drive workers' comp cost?

Trade descriptions of a facility manager include daily inspections, lien notices and sales, gate and lock problems, roof leaks and maintenance. The table connects each role to its exposure and payroll question.

No public data breaks storage injuries down by type, so start from your own loss runs. See the workers' comp review.

What class code does a self-storage facility use?

A class code is a number that tells the insurer which rate to apply to your payroll. The example below is Massachusetts. Outside it, use the same questions with your own carrier: which class, which duties fall outside it, and whether office staff qualify for a separate class. As one state's example, the Massachusetts rating bureau (an independent bureau, so this is state text, not National Council on Compensation Insurance (NCCI) text) puts renting self-storage units under class 9015, building operation by owner or lessee, when the work is building management or maintenance, including parking for boats, motor homes and RVs. A third-party lookup site lists some states as cross-referencing self-storage to 9015 and others to a warehousing class, and California uses its own system, so do not carry a code across state lines. The insurer assigns your code. See workers' comp class codes.

The same Massachusetts text puts these outside 9015:

• Contractors, extraordinary repairs and new construction by your regular or temporary employees, which belong in construction classes.
• An employer that uses the building for its own business.
• Property managers, leasing agents and office or showing staff, who go to the highest-rated standard exception class (a small set of classes, such as clerical and outside sales, that can sit beside the main class) representing any part of their duties.

Anyone who inspects the grounds or buildings or oversees maintenance is classified to 9015 regardless of job title. A manager who does counter work and daily inspections may not qualify for a clerical class at all, and the clerical definition excludes areas where customers bring products for payment. In practice, in Massachusetts a manager who inspects the grounds or oversees maintenance is in 9015. Counter-only or office-only staff may fall in a standard exception class instead, and the carrier decides. Ask the carrier for its classification letter, and see workers' comp class code corrections.

How do injuries at storage facilities compare with other employers?

The Bureau of Labor Statistics (BLS) publishes 2023 national injury rates per 100 full-time workers for self-storage lessors (North American Industry Classification System (NAICS) code 53113), and the second column counts only cases with days away, job restriction or transfer.

This is a national figure for one year, not a forecast for your site. Your premium follows your own claims history, your mod and your payroll by class. See the experience mod and reviewing the mod for errors.

Will the seller's mod follow me into the facility I bought?

A facility often runs on a few hourly staff and a resident manager, so one old injury claim can matter to a small mod. Under NCCI rules a change in ownership includes buying the stock or membership interests, buying the assets and taking over operations, a merger, or forming a successor entity. Past claims history generally follows the business, so a new LLC does not start at a 1.00 mod.

If you buy only one facility from a seller with several, whether any experience moves depends on whether the seller's insurer can split out the data for that site. If it can, that experience transfers to you. If it cannot, it generally stays with the seller and a buyer with no mod starts at 1.00 until it qualifies. Rules also differ by state. Small facilities may not reach the premium threshold for a mod. Texas lets most private employers opt out of coverage. North Dakota, Ohio, Washington and Wyoming sell workers' comp only through a state fund.

Under NCCI rules and several state versions of them, including Massachusetts, the employer reports an ownership change to the insurer within 90 days, whether or not a mod applies. New York uses the same 90 day rule, Pennsylvania and Delaware have their own bureau forms for the report, California has its own ownership process, and in the state-fund states you deal with the fund. Ask your carrier which rule applies. In an asset purchase the seller's policy does not move to your company without the insurer's written consent, so your entity needs its own policy in force at closing.

What about a live-in manager and unpaid hours?

Federal wage rules say a live-in employee is not considered to be working all the time on the premises, and a reasonable agreement on hours is accepted (Title 29 of the Code of Federal Regulations, section 785.23). State wage law can be stricter, and an attorney warns that overnight and weekend duties are a known source of wage and hour claims. Ask employment counsel how your state treats a live-in manager's hours before you set or change the arrangement. Employment practices liability insurance (EPLI) may sublimit or exclude wage and hour defense, so read it. See inherited wage and hour exposure.

For premium, payroll includes pay in all forms. In the North Carolina edition of NCCI rules, the rental value of a house or apartment provided to an employee, and the value of meals, count as payroll, and that rule has no exception for resident managers. Other states vary, so ask the carrier how an on-site apartment is treated at audit, and how an injury inside it is handled, in writing.

How do audits, roof work and contractors show up in the bill?

The premium on a policy is an estimate. The final premium is set after the policy ends using actual payroll and correct classes, and the insurer can audit records during the policy period and for up to three years after it ends. At a storage facility the audit lines to watch are manager hours, any lodging, roof and gate repair work, and outside plow and roofing crews. Work the policy classes do not describe can be reclassified, which changes the bill.

A hypothetical example. A new owner of a Massachusetts facility has staff replace several roof panels and rebuild two doors over a summer, about $12,000 of payroll. The policy classes it as ordinary building operation, but the auditor reads the work as extraordinary repair or construction. The audit moves that payroll to a construction class, which may carry a higher rate, and the owner gets a balance bill. Asking first, and keeping separate time and pay records, would have helped.

If you bought the company's stock or membership interests, the same insured entity owes its own audit balance, so a post-closing audit can bill it for payroll from before closing. In an asset deal the seller's policy normally carries the seller's audit. The purchase agreement decides who bears the cost, so ask deal counsel. An audit can also charge uninsured subcontractors' pay as if they were your employees. See payroll estimates and audit bills. If a third-party manager runs the site, ask in writing whose employees they are for workers' comp.

Am I covered if I work at the site myself?

If you work at the site yourself as an owner, officer or LLC member, whether you are covered or may elect to be excluded, and how your pay counts for premium, varies by state. Ask your carrier how your state treats working owners and how that shows up on the payroll estimate.

What should I do in the first 90 days?

1. Report the ownership change to the insurer, using the rule that applies in your state.
2. Ask for the carrier's classification letter.
3. Pull the last three payroll reports and the latest audit, and get the apartment treatment in writing.
4. Collect certificates from roofers, paving and plow crews.

Morrow can compare the classification letter and payroll to what you inherited. Any quotes depend on carrier underwriting.

Keep reading

• Just Bought a Self-Storage Facility? What Insurance Do You Need?
• What Drives Insurance Cost for a Self-Storage Facility?
• Contracts, Licenses and Bonds for a Self-Storage Facility
• Payroll Estimates and Surprise Workers' Comp Audit Bills
• How to Check Your Experience Mod for Errors After an Acquisition
• All guides for new business owners

Frequently asked questions

What workers' comp class code applies to a self-storage facility?

It depends on the state and rating bureau, and the insurer assigns it. The Massachusetts bureau uses class 9015, building operation by owner or lessee. Other states differ, and California has its own system.

Is my rental office clerical for workers' comp?

Do not assume so. In Massachusetts, office-type staff go to a standard exception class only if their duties fit its definition, and anyone who inspects the grounds or oversees maintenance is classified to 9015 whatever their title. Ask the carrier for its classification in writing.

Does the seller's experience mod transfer to me?

Usually, when you buy all of the seller's operations. Under NCCI rules both a stock purchase and an asset purchase where you take over operations are ownership changes, and the seller's experience generally transfers. Report the change promptly. NCCI sets 90 days, and other states differ.

Do I need workers' comp if I only use contractors for maintenance?

Whether you must carry it depends on your state and on whether anyone is your employee. Texas lets most private employers opt out, and four states use only a state fund. If you have employees, such as a site manager, most states generally require coverage. An insurer may charge uninsured subcontractors' pay to you at audit, so collect certificates and ask the carrier.

References

• WCRIBMA: Massachusetts classification 9015 (building operation by owner or lessee)
• WCRIBMA: Massachusetts classification 8810 (clerical office employees)
• BLS: Table 1, incidence rates of nonfatal occupational injuries and illnesses by industry, 2023 national (check for a newer year)
• Cornell LII: 29 CFR 785.23, employees residing on employer's premises
• NCCI: Experience Rating Plan Manual, Item E-1411 (Texas filing), ownership change rules
• NCCI: standard policy WC 00 00 00 C (carrier-hosted copy)
• North Carolina Rate Bureau: Basic Manual Rule 2, Premium and Payroll
• American Academy of Actuaries: Influential Features in the Workers' Compensation System (Oct 2025)
• Inside Self-Storage: Complying With Employment Laws in Self-Storage (attorney author)
• Texas Department of Insurance: Employers (workers' compensation coverage is optional for most private employers)

This article is general information, not legal, tax or financial advice, and not a coverage determination. Coverage depends on the actual policy wording, carrier underwriting, your purchase agreement and your contracts. Ask your attorney and accountant about deal and legal questions.