BILL ANALYSIS                                                                                                                                                                                                    Ó



                                                                  SB 556
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          SENATE THIRD READING
          SB 556 (Corbett)
          As Amended  September 4, 2013
          Majority vote 

           SENATE VOTE  :24-13  
           
           JUDICIARY           7-3                                         
           
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          |Ayes:|Wieckowski, Alejo, Chau,  |     |                          |
          |     |Dickinson, Garcia,        |     |                          |
          |     |Muratsuchi, Stone         |     |                          |
          |     |                          |     |                          |
          |-----+--------------------------+-----+--------------------------|
          |Nays:|Wagner, Gorell,           |     |                          |
          |     |Maienschein               |     |                          |
          |     |                          |     |                          |
           ----------------------------------------------------------------- 
           SUMMARY  :  Prohibits nongovernmental persons or entities  
          contracting to perform services relating to public health or  
          safety for public agencies from displaying a logo of a public  
          agency on a uniform or vehicle, as specified, unless a  
          disclosure statement is also displayed identifying the identity  
          of the uniform wearer or vehicle operator providing services for  
          the public agency.  Specifically,  this bill  :    

          1)Makes it unlawful for a person, firm, corporation, or  
            association that is a nongovernmental entity and contracts to  
            perform labor or services relating to public health or safety  
            for a public agency to display on a vehicle a logo of a public  
            agency that reasonably could be interpreted or construed as  
            implying that the labor or services are being provided by  
            employees of the public agency, unless the vehicle  
            conspicuously displays one of the following disclosures:

             a)   A statement indicating that the contractor is the  
               service provider, such as "SERVICE PROVIDED BY:" or  
               "CONTRACTED BY:" immediately followed by the name of the  
               contractor, its state or federal tax designation, and its  
               place of legal incorporation; or


             b)   A statement indicating that the contractor is the  
               service provider, such as "SERVICE PROVIDED BY:" or  








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               "CONTRACTED BY:" immediately followed by the logo of the  
               contractor providing the labor for the public agency.


          2)Makes it unlawful for a person, firm, corporation, or  
            association that is a nongovernmental entity and contracts to  
            perform labor or services relating to public health or safety  
            for a public agency to display on a uniform a logo of a public  
            agency that reasonably could be interpreted or construed as  
            implying that the labor or services are being provided by  
            employees of the public agency, unless the uniform  
            conspicuously displays one of the following disclosures:

             a)   A statement indicating that the contractor is the  
               service provider, such as "SERVICE PROVIDED BY:" or  
               "CONTRACTED BY:" immediately followed by the name of the  
               contractor, its state or federal tax designation, and its  
               place of legal incorporation; or


             b)   A statement indicating that the contractor is the  
               service provider, such as "SERVICE PROVIDED BY:" or  
               "CONTRACTED BY:" immediately followed by the logo of the  
               contractor providing the labor for the public agency.


          3)Requires the disclosure to be placed near the largest logo  
            referring to the public agency if the vehicle or uniform  
            displays more than one such logo.


          4)Clarifies that the term "conspicuously displays" means to  
            display a disclosure that is at least the same size as and  
            located close to the logo referring to the public agency.

          5)Defines the term "logo" to mean a symbol, graphic, seal,  
            emblem, insignia, trade name, brand name, picture, or text  
            identifying a person, firm, corporation, association, or  
            public agency.

          6)Clarifies that an identifying mark affixed to a uniform as  
            required by state or federal law, and a local agency  
            regulating the activity of the person, firm, corporation, or  
            association shall not be construed as implying that the labor  
            or services are being provided by employees of the public  








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            agency.

          7)Provides that violations of this act shall be subject to the  
            remedies provided in the Consumers Legal Remedies Act (CLRA)  
            (Title 1.5 (commencing with Section 1750) of Part 4), and that  
            the duties, rights, and remedies provided in this bill are in  
            addition to any other duties, rights, and remedies provided by  
            state law.

           FISCAL EFFECT  :  None
           
          COMMENTS  :  This bill, co-sponsored by the California Labor  
          Federation and the California Professional Firefighters, seeks  
          to prohibit private contractors who contract to perform labor or  
          services relating to public health or safety with public  
          agencies from displaying a logo of a public agency on a uniform  
          or vehicle, as specified, that reasonably could be interpreted  
          as implying that the contracted labor or services are being  
          provided by employees of the public agency-unless, that is, a  
          disclosure statement is also conspicuously displayed on the  
          uniform or vehicle providing specified information about the  
          private contractor.  Violations of this bill may be enforced  
          using the remedies provided by the CLRA.

          According to the author, this bill is needed to ensure that  
          members of the public can visually distinguish between  
          government employees and non-government employees who  
          increasingly are subcontracted to perform services relating to  
          public health or safety that traditionally have been the domain  
          of government employees.  Proponents assert that the public has  
          the right to know if a particular worker providing a service  
          that appears public in nature is in fact a public employee, or  
          is instead an independent contractor, subcontracted worker, or  
          other non-governmental employee not working for a public agency.  
           This matters, they contend, because in certain situations, the  
          public employee is required to have greater training and is held  
          to a higher degree of accountability to the public by virtue of  
          being an employee of a public agency, rather than that of a  
          private employer or as an independent contractor.  Accordingly,  
          the bill seeks to prevent confusion or misperceptions that  
          result, proponents contend, when private contractors hired by  
          public agencies perform services relating to public health or  
          safety and use uniforms or vehicles appearing very similar to  
          those used only by employees of the public agency.  In those  
          circumstances, this bill seeks to promote transparency by  








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          requiring the uniform or vehicle conspicuously display a  
          disclosure identifying the contractor's name, state or federal  
          tax designation, and place of organization or legal  
          incorporation.

          As recently amended, this bill provides that a person or company  
          that is a nongovernmental entity and contracts to perform labor  
          or services relating to public health or safety for a public  
          agency must abide by specific disclosure requirements with  
          respect to that entity's vehicles and uniforms.  Unless the  
          vehicle or uniform at issue displays the identifying information  
          about the private contractor specified in the bill, the  
          contracting nongovernmental entity may not display on the  
          vehicle or uniform a logo of the public agency that "reasonably  
          could be interpreted or construed as implying that" the service  
          is being provided by a public employee.  "Logo" is defined as a  
          symbol, graphic, seal, emblem, or other content identifying the  
          company or agency.

          Violations of the requirements proposed by this bill may be  
          enforced using the remedies provided by the CLRA (Civil Code  
          Section 1750 et seq.)  The CLRA establishes a nonexclusive  
          statutory remedy for unfair methods of competition and unfair  
          acts or practices in various consumer transactions, as  
          specified.  According to the author, the CLRA offers an  
          appropriate set of remedies for violations of the bill-remedies  
          which prioritize disclosure and display requirements over the  
          recovery of money damages.  Specifically, the CLRA allows an  
          action for injunctive relief to enjoin acts that do not comply  
          with the bill, in this case non-compliance with the uniform and  
          vehicle-related display and disclosure requirements of the bill.  
           In addition, the CLRA requires notice and opportunity to  
          correct for a period of thirty days before any action for  
          damages is allowed, including cases where the plaintiff seeks to  
          amend a complaint for injunctive relief to include a request for  
          damages.  

          It is not known whether the most recent amendments have removed  
          opposition from, among others, the California State Association  
          of Counties (CSAC), the League of California Cities, or American  
          Medical Response (AMR), California's largest provider of 9-1-1  
          emergency ambulance services.  Opponents generally contend that  
          they are unaware of any problem associated with a private  
          contractor wearing a similar uniform or having a similar vehicle  
          that causes confusion for the public, and that the bill is a  








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          solution in search of a problem.  Furthermore, opponents contend  
          that allowing similar uniforms and vehicles to be used by  
          contractors should be a matter of local control.  In addressing  
          the previous version of the bill, the opponents state: "Many  
          public agencies that contract for services specify uniform  
          requirements and/or affixing logos to a vehicle in their written  
          contracts with a service provider.  These uniform requirements  
          are oftentimes done for the purpose of ensuring that the public  
          knows who the contractor is serving and for identifying regional  
          operations during a major disaster or mutual aid request from a  
          public agency.  This bill would eliminate public agencies'  
          ability to determine what works best locally."  


           Analysis Prepared by  :    Anthony Lew / JUD. / (916) 319-2334 


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