BILL ANALYSIS                                                                                                                                                                                                    



                                                                       



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          |SENATE RULES COMMITTEE            |                   SB 404|
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                                 THIRD READING


          Bill No:  SB 404
          Author:   Benoit (R)
          Amended:  5/19/09
          Vote:     21

           
           SENATE LABOR & INDUST. RELATIONS COMMITTEE  :  5-0, 5/13/09
          AYES:  DeSaulnier, Ducheny, Hollingsworth, Leno, Yee
          NO VOTE RECORDED:  Wyland


           SUBJECT  :    Employment:  information for employees

           SOURCE  :     California Employment Law Council


           DIGEST  :    This bill clarifies that an employers obligation  
          to provide wage information when paying an employee may be  
          satisfied by putting the information on a detachable part  
          or a separate page from the check.
           
           ANALYSIS  :    Existing law, Section 226 of the Labor Code,  
          requires every employer, semimonthly or at the time of each  
          payment of wages, to give each of his/her employees, either  
          as a detachable part of the check, draft, or voucher paying  
          the employee's wages, or separately when wages are paid by  
          personal check or cash, an accurate itemized statement in  
          writing showing, among other things:

          1. Gross wages earned.

          2. Total hours worked by the employee, except for any  
             employee whose compensation is solely based on a salary  
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             and who is exempt from payment of overtime under Section  
             515(a) or any applicable order of the Industrial Welfare  
             Commission (IWC). 

             Section 515(a) of the Labor Code provides that the IWC  
             may establish exemptions from the requirement that an  
             overtime rate of compensation be paid for executive,  
             administrative, and professional employees, provided  
             that the employee is primarily engaged in the duties  
             that meet the test of the exemption, customarily and  
             regularly exercises discretion and independent judgment  
             in performing those duties, and earns a monthly salary  
             equivalent to no less than two times the state minimum  
             wage for full-time  employment.
           
           This bill:

          1. Deletes language specifying that an employer, at the  
             time he/she pays an employee, may provide the attendant  
             required information on a page separate from the  
             instrument of payment only when wages are paid by  
             personal check or cash.  Henceforth, an employer would  
             be allowed, at the time of each payment of wages, to  
             provide the required information either as a detachable  
             part of the check in accordance with existing law, or  
             the employer would be allowed, at his/her option, to  
             provide the required information to the employee on a  
             separate page.

          2. Deletes language that exempts employers from the  
             requirement that they provide the information on total  
             hours worked on the statement accompanying paychecks for  
             those employees whose compensation is solely based on a  
             salary and who are exempt from the payment of overtime  
             under Section 515(a) of the Labor Code or any applicable  
             order of the IWC.  The language remaining specifies that  
             the release from the requirement to provide information  
             on total hours worked applies simply to any employee  
             whose compensation is solely based on a salary and who  
             is exempt from the payment of overtime under Section  
             515(a) of the Labor Code or any applicable order of the  
             IWC.  Thus, the exemption applies to any employee  
             covered by Section 515 of the Labor Code or an IWC  
             order, including those so covered who are not salaried. 

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           FISCAL EFFECT  :    Appropriation:  No   Fiscal Com.:  No    
          Local:  No

           SUPPORT  :   (Verified  5/19/09)

          California Employment Law Council (source)
          Rancho Mirage Chamber of Commerce

           OPPOSITION  :    (Verified  5/19/09)

          American Federation of State, County and Municipal  
          Employees
          California Labor Federation
          California Nurses Association/National Nurses Organizing  
          Committee
          California Rural Legal Assistance Foundation
          United Nurses Association of California/Union of Health  
          Care Professionals

           ARGUMENTS IN SUPPORT  :    The author and sponsor note that  
          Section 226(a) of the Labor Code appears to limit most  
          employers to the sole option of "detachable" pay stubs when  
          providing earnings statements to employees.  A plain  
          reading of Section 226(a) seems to permit a separate,  
          non-detached pay stub only in situations where the employer  
          utilizes either a personal check or cash as the means of  
          delivering the employee's wages.  Employers do not believe  
          that this was the intent of this section and are asking for  
          the simple clarification that employers have the option of  
          providing a separate pay itemization when providing wages  
          in a legal fashion.  The way to solve this problem is to  
          amend the current law to ensure that employers are able to  
          use either a detachable or a separate page as an itemized  
          pay stub.

          Supporters note that employers do not have to list total  
          hours worked on most exempt employee pay stubs.  However,  
          due to the awkward fashion that Section 226 of the Labor  
          Code is currently written, some employers must supply the  
          total hours worked for certain exempt workers that are not  
          salaried due to other Labor Code requirements or IWC Wage  
          Orders such as outside salespersons or certain motor  
          carrier safety exemptions.  Because of this confusion,  

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          employers have faced lawsuits and significant fines for  
          violating Section 226 of the Labor Code.  As a way to end  
          the confusion and avoid unnecessary fines or litigation,  
          employers believe that Section 226 should be clarified to  
          apply to all exempt workers.  

           ARGUMENTS IN OPPOSITION  :    Opponents of this bill point  
          out the overtime exemptions are largely based on the time a  
          worker spends doing certain tasks.  These tasks may vary  
          from week to week, so that a worker is at times eligible  
          and at other times ineligible for overtime pay.  It is  
          important to track those hours to ensure that a worker is  
          paid at the overtime rate for the hours during which he/she  
          is qualified for overtime.  In addition, the  
          misclassification of workers as exempt is a commonplace way  
          to cheat workers out of basic labor protections.  If hours  
          are not tracked, workers who are misclassified will have no  
          way to document the wages they are owed.


          AGB:mw  5/19/09   Senate Floor Analyses 

                         SUPPORT/OPPOSITION:  SEE ABOVE

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