BILL ANALYSIS                                                                                                                                                                                                    Ó



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          CONCURRENCE IN SENATE AMENDMENTS


          AB  
          302 (Cristina Garcia)


          As Amended  July 14, 2015


          Majority vote


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          Original Committee Reference:  ED.


          SUMMARY:  Requires that schools provide reasonable  
          accommodations to breastfeeding students on school campuses.


          The Senate amendments change from 30 to 60 the number of days by  
          which the California Department of Education (CDE) would be  
          required to issue a written decision on the appeal of a local  
          complaint decision under the Uniform Complain Procedures (UCP).


          EXISTING LAW:  


          1)Requires (Labor Code Section 1030 et seq.) employers to  
            provide break time and a location which is not a bathroom  
            stall in which employees can express milk.










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          2)Federal law, known as the Patient Protection and Affordable  
            Care Act (42 United States Code Section 18001 et seq., 2010)  
            requires that employees covered by the Fair Labor Standards  
            Act be given break time and a place which is not a bathroom to  
            express breastmilk.  


          3)Prohibits (Government Code Section 12926) discriminatory  
            practices in employment or housing accommodations on the basis  
            of sex.  For purposes of the act, the term sex also includes  
            breastfeeding or medical conditions related to breastfeeding. 


          4)Requires, in federal (34 Code of Federal Regulations Section  
            106.40(b)(1)) and state law (Education Code Section 200) that  
            pregnant students and those recovering from childbirth-related  
            conditions must be provided with the same accommodations and  
            support services available to other students with temporary  
            medical conditions. 


          FISCAL EFFECT:  According to the Senate Appropriations  
          Committee:


          1)New lactation mandate:  Unknown, potentially significant  
            reimbursable state mandate costs for schools to provide  
            required accommodations for breastfeeding needs.  The bill  
            allows for broad interpretation of accommodation requirements  
            which could result in a broad range of activities determined  
            to be reimbursable under state mandate law.  (Proposition 98,  
            1988)


          2)The California Department of Education (CDE) anticipates the  
            need for one full-time position and one part-time position and  
            about $147,000 to address a potential increase in appeals due  
            to adding a new category of potential complaints.  Costs will  
            depend on actual complaints received and appeals filed.   
            (General Fund) 










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          3)Expansion of existing UCP mandate:  Unknown, potentially  
            significant reimbursable state mandate costs related to  
            developing procedures and local investigation of complaints.   
            To the extent the Commission on State Mandates determines this  
            bill to impose a new or expansion of an existing state  
            mandate, this could create pressure to increase the K-12  
            Mandate Block Grant to reflect their inclusion.  (Proposition  
            98)


          COMMENTS:  


          Need for this bill.  The author's office states, "Lactation is  
          indisputably related to pregnancy and childbirth, and students  
          who are nursing may need to express milk or breastfeed as  
          frequently as every two to three hours.  The California School  
          Boards Association has a model policy for parenting students  
          that includes optional lactation language, but few schools adopt  
          it.  Current law specifies how lactation accommodations are to  
          be provided to school staff, but there is nothing in the  
          Education Code that specifies how schools should meet parenting  
          students' rights to lactation accommodations.


          "Pregnant and parenting students should not be forced to make  
          decisions about where to attend school or whether to breastfeed  
          their child solely based on whether they can access appropriate  
          lactation accommodations at school.  California law should be  
          clear that accommodations for lactating students include access  
          to a private, secure room to breastfeed or express milk."


          State and federal law extend rights to employees but not to  
          students.  Both state and federal law require most employers to  
          provide reasonable accommodations to lactating employees,  
          including break time and the provision of private space in which  
          to express milk.  Though Title IX of the Education Amendments of  
          1972 requirements, given recent changes in state housing and  
          employment non-discrimination law which define "related  
          conditions" of pregnancy to include lactation, might be  
          understood to include lactation accommodations for students,  








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          these rights are not explicitly extended to students in state  
          law.


          Schools already required to provide space for employees.  The  
          requirements of this bill largely mirror those required under  
          state and federal law for employees.  As a result, schools may  
          not have to designate a space for students beyond what they have  
          already established for employees. Recent amendments make clear  
          that an existing facility set aside for other mothers on a  
          school site may be used to meet the requirements of this bill.


          Lack of accommodations may affect educational choices.  In a  
          2015 report titled, "Breaking Down Barriers for California's  
          Pregnant and Parenting Students," the American Civil Liberties  
          Union found: 


               Failure to provide adequate lactation  
               accommodations at one school site may result in a  
               student's decision to forego breastfeeding  
               altogether or enroll in a school site exclusively  
               based on the ability to pump or breastfeed during  
               school hours.  During focus group discussions,  
               some pregnant and parenting students shared that  
               school administrators discouraged them from  
               expressing breast milk at school.  Two out of the  
               nine pregnant and parenting students interviewed  
               said that their decision to leave regular school  
               was based entirely on their inability to  
               breastfeed or pump milk.


          Analysis Prepared by:                                             
                          Tanya Lieberman / ED. / (916) 319-2087  FN:  
          0001935













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