BILL ANALYSIS                                                                                                                                                                                                    Ó





          SENATE COMMITTEE ON LABOR AND INDUSTRIAL RELATIONS
                             Senator Tony Mendoza, Chair
                                2015 - 2016  Regular 

          Bill No:               AB 1505      Hearing Date:    June 10,  
          2015
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          |Author:    |Committee on Labor and Employment                    |
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          |Version:   |March 4, 2015                                        |
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          |Urgency:   |No                     |Fiscal:    |No               |
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          |Consultant:|Deanna Ping                                          |
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                                Subject:  Car washes.


          KEY ISSUE
          
          Should the legislature require a car wash employer to provide  
          written notice to a successor employer regarding the  
          requirements of existing law prior to the sale or other transfer  
          of the business? 

          ANALYSIS
          
           Existing law  requires every employer to register annually with  
          the Labor Commissioner and lists the following conditions for  
          registration or renewal: 

             1)   The employer must present proof of compliance with the  
               local government's business licensing or regional  
               regulatory requirements to the Labor Commissioner 

             2)   The employer has obtained a surety bond with a principal  
               sum no less than $150,000 and file a copy of the bond with  
               the Labor Commissioner. The bond shall be payable to the  
               people of California for the benefit of any employee  
               damaged by his or her employer's failure to pay wages,  
               interest on wages, or fringe benefits








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             3)   The employer has documented that a worker's compensation  
               insurance policy is in effect and has paid necessary fees
            (Labor Code §§2054 and 2055) 

           Existing law  regulates the car washing and polishing industry by  
          requiring specific recordkeeping requirements of car wash  
          employers on employee wages, hours and working conditions.  
          (Labor Code §2052) 

           Existing law  establishes a car wash worker fund for which  
          penalties and registration fees are deposited for disbursement  
          by the Labor Commissioner to employees of car washing or  
          polishing businesses found to be in violation of current law.  
          (Labor Code §2065)

           Existing law  states that charitable groups, rental car agencies,  
          self-service or automated car wash that have no more than two  
          full-time employees for cashiering and/or maintenance purposes,  
          and licensed vehicle dealers or automotive repair businesses are  
          exempted. (Labor Code §2051)

           Existing law  also provides that a successor to an employer that  
          owed wages and penalties to the predecessor's employees is  
          liable for those wages and penalties under specified  
          circumstances. (Labor Code §2066) 
           

          This bill  would require a car wash employer to provide written  
          notice to a successor employer regarding the above provisions,  
          such as owed wages and penalties, prior to the sale or other  
          transfer of the business. 



          COMMENTS

          1.  Background on Legislative Efforts to Regulate the Car Wash  
            Industry 
           
            In 1999, SB 1097 (Hayden), which sought to regulate the car  
            wash industry, was vetoed by the Governor.  In his veto  
            message the Governor said, in part: "I am vetoing this bill.   
            I do not believe that the need to register car washes with the  
            Labor Commissioner has been demonstrated.  I am however asking  







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            the Director of Industrial Relations (DIR) to review the  
            activities of the car washing industry and make any and all  
            appropriate recommendation to me by June 30, 2001."

            In response DIR filed an internal report about labor law  
            violations in the industry and possible remedies, considering  
            limited resources and widespread violations that affect other  
            industries in the state.  Additionally, in early 2003, DIR  
            conducted a coordinated enforcement sweep of the car washing  
            and polishing industry in the Los Angeles area, finding  
            numerous labor law violations, collecting back wages and  
            penalties due totaling over $250,000.

            As a result of proven violations in this industry AB 1688  
            (Goldberg) "The Car Wash Worker Bill" was signed into law and  
            took effect on January 1, 2004.  AB 1688 contained a sunset  
            date of January 1, 2007.  The final car wash regulations were  
            promulgated by DIR and finally adopted by the Office of  
            Administrative Law December 2005.

            SB 1468 (Alarcon) of 2006 extended the sunset date relating to  
            the regulation of  the car washing and polishing industry to  
            January 1, 2010, and  required the LC to report to the  
            Legislature no later than December 31, 2008, on the status of  
            labor law violations and enforcement in the car washing and  
            polishing industry.

            In March 2008, the Los Angeles Times reported the results of  
            an investigation of the car wash industry finding that many  
            owners pay less than half of the required minimum wage and  
            that two-thirds of those inspected by the state since 2003  
            were out of compliance with one or more labor laws -including  
            underpaying workers, hiring minors, operating without workers'  
            compensation insurance and denying workers their meal and rest  
            breaks.

            The Division of Labor Standards Enforcement in the Department  
            of Industrial Relations released the mandated study of the car  
            wash and polishing industry in April of 2009.  In the report,  
            DLSE said the number of registered firms increased from 2007  
            to 2008 and that the number of citations decreased in that  
            period.  However, the report found that there continue to be  
            hundreds of violations of labor standards.  Many firms had no  
            workers' compensation for their workers, and there were many  
            other violations of labor law (e.g., child labor violations,  







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            and failure to pay minimum wages and overtime pay).

            In 2013, the legislature passed and the governor signed AB  
            1387 (Hernandez) which eliminated the sunset date on existing  
            law regulating the car washing and polishing industry. AB 1387  
            also increased the surety bond from $15,000 to $150,000 and  
            provided a specified exemption for employers with a valid  
            collective bargaining agreement.

          2.  California Courts and Successorship Provisions:  

            In People ex rel. Harris v. Sunset Care Wash, LLC (205 Cal.  
            App. 4th, 2012) the plaintiff filed an action against Sunset  
            Car Wash, LLC to recover unpaid wages and penalties owed by  
            the defendant Auto Spa Express, Inc. which had operated a  
            carwash at the same location before being evicted by the  
            property owner. The trial court denied a motion for summary  
            judgment filed by Sunset Carwash and ruled that because it  
            operated at the same location and performed the same services  
            it was considered a successor under Labor Code section 2066.  
            In its decision the Court noted that the Legislature was  
            motivated to enact the Section 2066 provisions by its findings  
            that carwash operators sometimes employed practices that  
            resulted in state labor law violations. 

          3. Need for the bill?  :

            Existing law regulates the employment practices of car washes  
            and requires employers of car wash employees to register with  
            the Labor Commissioner and pay a specified registration fee or  
            be subject to a specified civil fine. Existing law also states  
            that a successor car wash employer may be liable for unpaid  
            wages and penalties incurred by a predecessor car wash  
            employer if certain conditions are met. 

            This bill would require a car wash employer to notify a  
            successor in writing of the requirement of the car wash  
            registration law. According to the author this bill would  
            provide important information about the law's requirements to  
            a prospective purchaser and would ensure greater compliance. 


          4.  Proponent Arguments  :
            
            According to the author's office, this bill would require a  







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            car wash employer to notify a successor in writing of the  
            requirement of the car wash registration law, including the  
            potential for successor liability for unpaid wages, prior to  
            the sale or other transfer of the business. Further, the  
            author's office argues that requiring a person selling their  
            car wash business to inform a prospective purchaser about the  
            requirements of the law will ensure greater awareness of and  
            compliance with the law.

          5.  Opponent Arguments  :

            None on file. 

          6.  Prior Legislation  :

            AB 2750 (Hernandez) of 2013 - would have required a car wash  
            employer to provide written notice to a successor employers  
            regarding the requirements of existing law prior to the sale  
            or other transfer to the business. The bill was amended out of  
            Labor Code and into Business and Professions Code. 

            AB 1387 (Hernandez), Chapter 751, Statues of 2013 - eliminated  
            the sunset date on existing law regulating the car washing and  
            polishing industry. Also, AB 1387 increased the surety bond  
            from $15,000 to $150,000 and provided a specified exemption  
            for employers with a valid collective bargaining agreement. 

            AB 236 (Swanson), Chapter 224, Statutes of 2009 - extended the  
            sunset date of the licensing and registration program for car  
            washes from January 1, 2010 to 2014. 

            SB 1468 (Alarcon), Chapter 656, Statutes of 2006 - extended  
            the sunset date of the licensing and registration program to  
            January 1, 2010 and required the Labor Commissioner to report  
            on the status of labor law violations and enforcement in the  
            car washing and polishing industry. 

            AB 1688 (Goldberg), Chapter 825, Statutes of 2003 - enacted  
            regulations for the car wash industry including registration  
            and bonding requirements, as well as protections against  
            'successor' entities avoiding previous judgments for unpaid  
            wages or penalties.

            SB 1097 (Hayden) of 1999 - would have required persons who  
            employ others in car washing and polishing to register with  







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            the Labor Commissioner and would have required an employer who  
            has violated specified labor laws to obtain a surety bond and  
            meet other specified requirements. SB 1097 was vetoed by  
            Governor Davis. 



          SUPPORT
          
          None on file.
          
          OPPOSITION
          
          None on file. 

                                      -- END --