BILL ANALYSIS                                                                                                                                                                                                    Ó




                                                                  AB 1897
                                                                  Page A
          Date of Hearing:   April 23, 2014

                     ASSEMBLY COMMITTEE ON LABOR AND EMPLOYMENT
                               Roger Hernández, Chair
               AB 1897 (Roger Hernández) - As Amended:  April 10, 2014
          
          SUBJECT  :   Labor contracting: client liability.

           SUMMARY :   Establishes specified liability for client employers  
          that obtain workers from third-party labor contractors.   
          Specifically,  this bill  :

          1)Defines "client employer" to mean an individual or entity that  
            obtains or is provided workers to perform labor or services  
            within the usual course of business of the individual or  
            entity from a labor contractor.

          2)Defines "labor contractor" to mean an individual or entity  
            that contracts with a client employer to supply workers to  
            perform labor or services within the usual course of business  
            or otherwise provides workers to perform labor or services  
            within the usual course of business for the client employer.

          3)Specifies that "worker" does not include an employee who is  
            exempt from the payment of overtime wages under existing  
            exemptions for executive, administrative, and professional  
            employees.

          4)Provides that a client employer shall share with a labor  
            contractor all civil legal responsibility and civil liability  
            for the following:

             a)   The payment of wages to workers provided by a labor  
               contractor.

             b)   The failure to report and pay all required employer  
               contributions, worker contributions, and personal income  
               tax withholdings.

             c)   Failure to secure valid workers' compensation coverage.

          5)Prohibits a client employer from shifting to a labor  
            contractor any legal duties or responsibilities related to  
            workplace health and safety.










                                                                  AB 1897
                                                                  Page B
          6)Clarifies that these provisions are in addition to, and shall  
            be supplemental of, any other liability or requirement  
            established by statute or common law.

          7)Specifies that this bill does not prohibit a client employer  
            from establishing, exercising, or enforcing by contract any  
            otherwise lawful remedies against a labor contractor for  
            indemnification for liability created by acts of a labor  
            contractor, and vice versa.

          8)Provides that, upon request by a state enforcement agency or  
            department, a client employer or a labor contractor shall  
            provide to the agency or department any information required  
            to verify compliance with applicable state laws. Upon request,  
            these records shall be made available promptly for inspection,  
            and the state agency or department shall be permitted to copy  
            them.

          9)Authorizes the Labor Commissioner, the Division of  
            Occupational Safety and Health, and the Employment Development  
            Department to adopt regulations and rules of practice and  
            procedure necessary to administer and enforce the provisions  
            of this bill.

          10)Makes a waiver of the provisions of this bill contrary to  
            public policy, and void and unenforceable. 

           FISCAL EFFECT  :   Unknown

           COMMENTS  :   In recent years, some workers and worker advocates  
          have noticed an increase in the number of employers who are  
          moving away from a traditional employment model towards a  
          business model that utilizes "subcontracted" or "contingent"  
          workers.
            
          In a traditional employment relationship, an employer directly  
          hires its own workers, pays their wages and provides their  
          benefits, and controls their day-to-day work.    However, a  
          variety of other employment models have developed over the  
          years.  Numerous terms are used to describe these alternative  
          types of work arrangements: contingent work, nonstandard work,  
          contractual work, seasonal work, freelance work, "just-in-time"  
          or "temp employment," or "permatemps."

          Many advocates have expressed concern that this business model  









                                                                  AB 1897
                                                                  Page C
          results in challenges for workers and enforcement agencies in  
          ensuring that employees' rights are fully.  This issue was the  
          topic of informational hearings held by the Assembly Committee  
          on Labor and Employment in February 2012 and March 2014.

          An eloquent description of the issue and associated problems is  
          as follows:

               "We walk into a Marriott and assume that the people who  
               greet us at the front desk or who clean our rooms each day  
               are employees of the venerable brand (as their uniforms  
               imply).  We greet the technicians sent to our home to fix  
               our cable, not even questioning whether they work for the  
               media company to whom we pay our bills.  In short, we  
               assume that the companies who invest millions of dollars to  
               convince us of the benefits of buying products under their  
               retail nameplate or to purchase the unique services they  
               offer also undertake the operations needed to produce them  
               - including acting as the employer of all the  
               inter-connected people who make their businesses possible.   
               Those assumptions are increasingly wrong?

               ?In essence, private strategies and public policies allow  
               major companies to simultaneously profit from the core  
               activities that create value in the eyes of customers and  
               the capital markets and shed the actual production of goods  
               and services.  In so doing, they have their cake and eat it  
               too."<1>




           Subcontracting: The New Normal?  Or Deja Vu All Over Again?
           
          Subcontracting of an employer's workforce is certainly not a new  
          phenomenon, particularly in California.  For example, since at  
          least the 19th century, the garment manufacturing industry has  
          relied heavily upon nominally separate entities to manufacture,  
          sew and press garments.  In addition, in the agriculture  
          industry, growers have long relied upon "farm labor contractors"  
          to serve as intermediaries to hire agricultural workers to  
          harvest and perform other work on farms.

          ---------------------------
          <1> Weil, David.  "The Fissured Workplace: Why Work Became So  
          Bad for So Many and What Can Be Done to Improve It."  Harvard  
          University Press (February 2014), at pp. 3-4.








                                                                  AB 1897
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               "Subcontracting out work is an old phenomenon. Until about  
               70 years ago, the use of labor intermediaries was commonly  
               known as "the sweating system" and its victims worked in  
               "sweating shops." The quintessential subcontracted worker  
               was the garment worker toiling in a tenement in New York  
               City during the last two decades of the 19th century. But  
               the problem was much more widespread. The sweating system  
               existed in many other locations, including Chicago,  
               Cincinnati, Indianapolis, Philadelphia, and Boston. The  
               "sweated trades" included production of a wide variety of  
               garments as well as cigars, artificial flowers, dolls,  
               brushes and purses.

               Worker advocates put much thought and effort into  
          addressing problems in the
               "sweated trades," which included low wages, long hours,  
               piece-rate abuses, dangerous conditions and child labor. A  
               century later, we seem to be fighting similar battles.  
               Labor subcontracting, temp agencies, employee leasing,  
               misclassifying employees as "independent contractors,"  
               outsourcing and other methods of "sweating a profit" out of  
               workers through labor intermediaries are prevalent."<2>

          It is interesting to note that in California, concerns with the  
          employment model utilized in the garment and agriculture  
          industries has led to industry-specific legislation designed to  
          protect workers.  Both garment manufacturers and farm labor  
          contractors are required to be licensed and regulated by the  
          Division of Labor Standards Enforcement (generally known as the  
          Labor Commissioner).  Existing law contains numerous additional  
          requirements to be followed by contractors in both of these  
          industries, generally to ensure that current labor and  
          employment laws are followed to protect workers.

          However, some advocates have expressed concern that the use of  
          subcontracted work appears to be a growing trend across all  
          industries.  In June 2013, the U.S. Department of Labor reported  
          that the nation had more temporary workers than ever before: 2.7  
          million.  Overall, almost one-fifth of the total job growth  
          ---------------------------
          <2> Goldstein, Bruce and Catherine K. Ruckelhaus.  "Lessons For  
          Reforming 21st Century Labor Subcontracting: How 19th Century  
          Reformers Attacked 'The Sweating System,'" in Proceedings of the  
          53rd Annual Meeting of the Industrial Relations Research  
          Association (New Orleans, LA. Jan 2001).








                                                                  AB 1897
                                                                  Page E
          since the recession ended in mid-2009 has been in the temporary  
          sector, federal data shows<3>.  The proportion of temporary  
          workers in the labor force reached its peak in early 2000 before  
          the 2001 slump and then the Great Recession.  "But as the  
          economy continues its slow, uneven recovery, temporary work is  
          roaring back 10 times faster than private-sector employment as a  
          whole.<4>"


           Subcontracting - The Good, the Bad and the Ugly  

          There is little question that temporary employment is attractive  
          to some workers, for a variety of reasons.  The Bureau of Labor  
          Statistics has stated:

               "Employment as a temporary worker is attractive to some.   
               The opportunity to earn income while enjoying flexible  
               schedules and an ability to take extended leaves of absence  
               is well-suited to students, persons juggling job and family  
               responsibilities, those exploring various careers, and  
               those seeking permanent positions in a chosen career.   
               Firms try to accommodate workers' preferences for  
               particular days or hours of work and for frequency or  
               duration of assignments. Temporary work assignments provide  
               an opportunity to experience a variety of work settings and  
               employers, to sharpen skills through practice, and to learn  
               new skills.  Nevertheless, many workers in temporary  
               assignments would prefer the stability and greater benefits  
               associated with full-time work<5>."


          Similarly, the American Staffing Association (ASA) states that  
          the staffing industry "offers flexibility to both employees and  
          companies.  People can choose when, where, and how they want to  
          work.  Companies can get the skills they need to keep fully  
          ---------------------------


          <3> Grabell, Michael.  "The Expendables: How the Temps Who Power  
          Corporate Giants Are Getting Crushed." ProPublica (June 27,  
          2013).   
           http://www.propublica.org/article/the-expendables-how-the-temps-w 
          ho-power-corporate-giants-are-getting-crushe  
          <4> Id.
          <5> United States Department of Labor, Bureau of Labor  
          Statistics.  "Career Guide to Industries, 2010-11 Edition."








                                                                  AB 1897
                                                                  Page F
          staffed during busy times<6>."  


          Similarly, subcontracting can allow an employer to subcontract a  
          portion of its work to concentrate on its "core" or primary  
          business, leaving ancillary or related services to someone else.

          However, worker advocates and others have long alleged that  
          motivation for an employer to use "subcontracted" or "temporary"  
          employees is sometimes driven more by a desire to flout labor  
          and employment laws than by legitimate business necessity.

          Some have described the problem as follows:

               "Well before the current economic downturn, the sweatshop  
               ethic expanded broadly throughout the economy, with a wide  
               range of business owners and managers adopting a  
               'gloves-off' approach to their own employees.  In the best  
               cases they have simply turned a blind eye to the  
               shenanigans of subcontractors, in effect outsourcing their  
               moral and legal responsibility.  In the worst cases  
               employers have directly engaged in inhumane acts, cheating  
               their staff out of hard-earned pay and blithely ignoring  
               codes meant to ensure their health and safety?

               ?Employers can take the gloves off without violating labor  
               laws-especially by shifting responsibility for worker  
               protections to subcontractors.  They can hire labor  
               suppliers to perform work on-site (as with subcontracted  
               janitorial workers) or off-site (as with industrial laundry  
               workers cleaning linens for hotels and hospitals).  Of  
               course, greater use of subcontracting in and of itself does  
               not necessarily imply an attempt to evade workplace laws.   
               But it can facilitate such evasions by creating greater  
               legal distance between the ultimate employer and the  
               worker.  When a fly-by-night cleaning subcontractor pays  
               less than the minimum wage, the business manager whose  
               building is getting cleaned can deny responsibility.  And  
               in the event regulators catch up with the subcontractor, he  




               -------------------------
          <6>  http://www.americanstaffing.net/jobseekers/facts.cfm  













                                                                  AB 1897
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               simply disappears, leaving the workers in the lurch<7>."

           Profile of Subcontracted Work in California  

          In March 2014, the National Employment Law Project (NELP)  
          released a paper<8> highlighting key facts about subcontracted  
          work in California.  The paper noted the following statistics:

                 Subcontracted and temporary jobs are on the rise:
                  o         According to the Government Accountability  
                    Office, an estimated 31 percent of the workforce could  
                    be considered "contingent workers" in 2005.
                  o         According to the Bureau of Labor Statistics,  
                    there are 2.68 million temporary workers in the United  
                    States-approximately the same number of workers in the  
                    airline, real estate, and mining industries combined.
                  o         Almost one-fifth of total job growth since the  
                    end of the recession in 2009 is in the temporary  
                    sector; according to the American Staffing  
                    Association, one in every ten workers finds a job at a  
                    staffing agency.
                  o         More than one in twenty blue-collar workers  
                    nationwide are temporary workers.
                 Workers and communities suffer in jobs provided by labor  
               suppliers:
                  o         Temporary workers earn lower wages, fewer  
                    benefits, and have less job security. A UC Berkeley  
                    study found that median hourly wages were $13.72 for  
                    temps, versus $19.13 for non-temporary workers in  
                    California.  Studies have found that outsourced call  
                    center workers earn 8 percent less than in-house  
                    counterparts; contract company janitors earn 4 to 7  
                    percent less, and contract security guards earn 8 to  
                    24 percent less than directly employed counterparts.
                  o         Workers in jobs provided by labor suppliers  
                    face greater risks of workplace illness, injury, and  
                    death. California recorded the highest number of fatal  
                    occupational injuries among contractors in the United  
                  -----------------------
          <7> Martelle, Scott.  "Confronting the Gloves-Off Economy:  
          America's Broken Labor Standards and How To Fix Them."  (July  
          2009).
          <8> Cho, Eunice.  "Labor Contracting in California: Key Facts."   
          National Employment Law Project (March 2014).   
           http://nelp.3cdn.net/9ba033b722b6df0dd6_w8m6iii52.pdf  









                                                                  AB 1897
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                    States. California's temporary workers face a 50  
                    percent higher risk for injury on the job and are  
                    twice as likely as regular workers to be stricken by  
                    heat exhaustion. These workers are more likely to be  
                    placed in dangerous jobs, without proper training or  
                    safety equipment.
                 Low-income, immigrant, and communities of color workers  
               are more likely to work for labor suppliers:
                  o         Temporary workers are twice as likely to be on  
                    government assistance. 18.8 percent of temporary  
                    workers in California lived in poverty, as compared to  
                    8.9 percent of non-temp workers.
                  o         Temporary workers are more likely to be  
                    non-white or Hispanic and without a high school  
                    diploma or GED. 65 percent of temporary workers are  
                    non-white or Hispanic, compared to 55.6 percent of  
                    non-temp workers. 21 percent of temporary workers did  
                    not have a high school diploma or GED, as compared to  
                    15.7 percent of non-temp workers.

           Do Policy Solutions that Focus on Labor Contractors Get at the  
          Heart of the Problem?
           
          For a number of years, policy recommendations have tended to  
          focus on regulating the subcontracted employers or labor  
          contractors themselves.  Examples of this in California law  
          include statutes regulating farm labor contractors and garment  
          manufacturers.

          But some commentators have questioned whether such approaches  
          miss the mark, instead suggesting that policies should instead  
          place the emphasis on the user employers of subcontracted work:
          
               "The history of the sweating system offers us useful  
               lessons for today. Any strategy to ameliorate the harms of  
               subcontracting must focus on the entities that have the  
               economic power to change the system: the companies that  
               retain the subcontractors.  Efforts to regulate the  
               subcontractors themselves will rarely be sufficient because  
               the subcontractors are too numerous, the economic pressures  
               on contractors to compete by undermining labor standards  
               are too intense, and new subcontractors will always replace  
               ones that are put out of business.

               Laws, regulations, law enforcement efforts, consumer  









                                                                  AB 1897
                                                                  Page I
          boycotts, and collective
               bargaining agreements should attempt to place  
               responsibility for wages and working conditions on the  
               companies that subcontract out. Emphasizing the  
               responsibility of the company that subcontracts, rather  
               than that of the subcontractor, will maximize the impact of  
               the limited resources available to prevent substandard  
               employment practices.

               This approach also benefits those employers that prefer to  
               treat their workers well.  Companies deserve protection  
               against unfair competition by unscrupulous employers that  
               seek to undermine labor standards and lower labor costs by  
               resorting to labor contractors."<9>

           Solutions to the "Fissured Workplace"  

          David Weil is a professor at Boston University as well as a  
          researcher at Harvard University.  In September 2013, President  
          Obama nominated Weil to head the U.S. Department of Labor's Wage  
          and Hour Division.

          In February of this year, Weil authored a book<10> which  
          examines the economic phenomenon which is the subject of this  
          bill.  Weil uses the term "the fissured workplace" to describe  
          the current situation as follows:

               "The modern workplace has been profoundly transformed.   
               Employment is no longer the clear relationship between a  
               well-defined employer and a worker.  The basic terms of  
               employment - hiring, evaluation, pay, supervision,  
               training, coordination - are now the result of multiple  
               organizations.  Responsibility for conditions has become  
               blurred.  Like a rock with a fracture that deepens and  
               spreads with time, the workplace over the past three  
               decades has fissured.  And fissuring has serious  
               consequences for the bedrock that people depend upon from  
               -------------------------
          <9> Goldstein, Bruce and Catherine K. Ruckelhaus.  "Lessons For  
          Reforming 21st Century Labor Subcontracting: How 19th Century  
          Reformers Attacked 'The Sweating System,'" in Proceedings of the  
          53rd Annual Meeting of the Industrial Relations Research  
          Association (New Orleans, LA. Jan 2001).
          <10> Weil, David.  "The Fissured Workplace: Why Work Became So  
          Bad for So Many and What Can Be Done to Improve It."  Harvard  
          University Press (February 2014).








                                                                  AB 1897
                                                                  Page J
               employment: the share of the economic pie available to  
               workers and their families; their exposure to health and  
               safety and other risks each day at work; and the likelihood  
               that their workplaces comply with the standards set out by  
               law<11>." 

          Later in the book, in a chapter entitled, "Rethinking  
          Responsibility," Weil discusses potential solutions to "the  
          fissured workplace" and states the following:

               "Successful legislation to address the problems arising  
               from fissured employment would?impact the balancing  
               decision faced by lead businesses by requiring them to  
               include social as well as private benefits and costs in  
               making decisions on employment.  In some cases, by changing  
               laws so that the lead business cannot have it both ways,  
               those companies may choose to keep employment inside the  
               organization.  But that is not the only outcome legislation  
               should seek.  Lead businesses might still choose to move  
               employment outward through contracting, franchising,  
               third-party management, or other organizational forms.   
               However, they might do so with greater scrutiny in the  
               selection, monitoring, and coordination of those  
               subordinate organizations given their heightened  
               responsibility.

               Framed in this broader way, public policies amending  
               existing workplace policies, or breaking new ground  
               entirely, can be evaluated in terms of their impact on the  
               decisions made by lead organizations.  There are three  
                                                                   major objectives for legislative initiatives in this  
               regard.  First, legislation can attempt to stop lead  
               organizations from shedding employment simply as a means to  
               avoid workplace obligations created by law.  Second,  
               policies placing greater legal responsibility on lead  
               businesses can cause those firms to include the social  
               consequences of the fissured workplace when deciding to  
               shed employment to others.  Third, public policies can  
               affect how wages and human resource policies are set in  
               fissured workplace forms<12>."

           ARGUMENTS IN SUPPORT  :



          ---------------------------
          <11> Id. at 7.
          <12> Id. at 203-204.








                                                                  AB 1897
                                                                  Page K
          This bill is co-sponsored by the California Labor Federation,  
          AFL-CIO, the California Teamsters Public Affairs Council, and  
          the United Food and Commercial Workers Union.

          The California Labor Federation, AFL-CIO states the following in  
          support of this bill:

               "Across our economy, we are seeing a resurgence in the use  
               of labor contractors and the reemergence of what in the  
               late 1800's was called "the sweating system." Like the  
               sweatshops of old, companies are once again using third  
               party labor suppliers to squeeze workers to work harder for  
               less pay while insulating the company in charge from  
               responsibility for what is done to those workers.  This  
               structure does more than just drive down wages; it makes  
               accountability almost impossible. 

               The workers at the bottom of this chain work directly for  
               the contractor and are supplied to companies on as "as  
               needed" basis with no strings attached. In some cases, they  
               are treated as day laborers and gather every morning at the  
               staffing agency to see whether they will be assigned work.  
               Others work full-time for years but are considered  
               temporary. 

               Subcontracted workers wear hotel uniforms and clean rooms,  
               but are hired by a temporary agency. When they get cheated  
               out of wages, the hotel denies any responsibility. Other  
               workers pack lettuce and onions for years in food  
               processing plants, but are hired through farm labor  
               contractors. When they speak out about working conditions,  
               the company threatens to cut its ties with the contractor  
               so workers will lose their jobs. When workers look for  
               help, even state enforcement agencies are often uncertain  
               about who the actual employer is and who can be held  
               accountable. 

               Today's subcontracted workforce bears little resemblance to  
               the "Kelly Girls" who were once the poster child of the  
               temporary industry.  Instead, third party labor suppliers  
               are being used to provide low cost "perma-temps" to do  
               strenuous and often dangerous work for years on end. One in  
               20 blue collar jobs in America are temporary, including one  
               in five manual laborers and one in six auto workers. 










                                                                  AB 1897
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               Temporary workers by definition have no guarantee of  
               additional work and so a worker can easily be punished for  
               speaking out. Employers also use the threat of terminating  
               the contract with the staffing agency or contractor if the  
               workers exercise protected labor rights. These types of  
               retaliation are hard to prove and hard to remedy?.

               ?When two recycling workers lost fingers in similar machine  
               accidents in 2009, Soex West Textile Recycling told CalOSHA  
               it could not be held responsible as it had no employees.  
               The workers injured on their property by their equipment  
               were employed by another entity, who also denied any role  
               in supervision or control.  This example underscores the  
               challenge for state agencies in preventing workplace  
               accidents in these subcontracted settings?

               ?The reliance on labor contractors undermines the  
               enforcement of labor laws and erodes working conditions in  
               key industries. Warehousing, food production, trucking,  
               waste and recycling are all industries where unions have  
               had significant density and maintained good middle-class  
               jobs for decades. These are the industries where the use of  
               contract labor is on the rise and is resulting in lower  
               wages and more labor violations.

               Not only does the use of a contractor make it harder to  
               hold the company accountable for the treatment of workers,  
               but it also interferes with the right to organize. Contract  
               laborers work for the labor contractor, so at one site,  
               there can be multiple employers. That results in split  
               bargaining units, multiple elections, and a constantly  
               divided workforce. 

               Current law is simply insufficient to protect workers'  
               rights in the shadows of the subcontracted economy.  Under  
               existing law, a company can only be held responsible if a  
               worker can prove joint employer status. This process is  
               costly, slow, and difficult to navigate for most workers.  
               It requires litigation, rather than providing a simple and  
               straightforward rule. It is also easily manipulated by  
               companies that have the labor contractor provide  
               supervision on site to shield them from liability. 

               [This bill] offers a far better approach. It holds  
               companies accountable for serious violations of workers'  









                                                                  AB 1897
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               rights committed by their own labor suppliers to workers on  
               their premises.  This simple rule will incentivize the use  
               of responsible contractors, rather than a race to the  
               bottom. It will protect vulnerable temporary workers, as  
               well as businesses that follow the law and don't profit  
               from cheating workers. It offers workers a clear path to  
               accountability for workplace violations and it offers  
               employers a clear path to compliance."

          Similarly, the California Rural Legal Assistance Foundation  
          (CRLAF) argues that this bill is an important contribution to  
          efforts made in recent years to protect workers from wage theft,  
          substandard working conditions and other abuses committed by  
          labor contractors in the underground economy:

               "Despite the passage of recent legislation such as the  
               Financially Responsible Contractors Act (Labor Code Section  
               2810 (2003)) and the expansion of the definition of  
               employer by the California Supreme Court in Martinez v.  
               Combs (2010), efforts to hold the users of labor  
               contractors jointly liable for their labor law violations  
               remains a fact intensive, expensive, case by case exercise  
               that takes years to successfully litigate against a single  
               employer."

          CRLAF also provides data that illustrates the difficulty in  
          efforts that merely focus on regulating the "labor contractor,"  
          rather than focusing on the user or client employer.  Despite  
          the fact that farm labor contractors have been regulated for  
          over sixty years, a survey conducted by CRLAF early this year  
          highlights cases involving thousands of farm workers,  
          potentially several millions of dollars in unpaid wages and  
          penalties, and a host of other alleged violations including  
          health and safety abuses, sexual harassment, retaliation, and  
          physical threats and actual beatings of workers.  As CRLAF  
          concludes, "Taken together, these cases are a reliable 'snap  
          shot' of labor law compliance by some farm labor contractors in  
          California in 2014 and are powerful evidence that more than six  
          decades of state regulation has failed to curb widespread abuses  
          in agriculture's underground economy."

           ARGUMENTS IN OPPOSITION  :

          A coalition of employer groups, including the California Chamber  
          of Commerce, opposes this bill and argues that it forces one  









                                                                  AB 1897
                                                                  Page N
          company to essentially insure the wage and hour obligations,  
          workers' compensation coverage, and occupational health and  
          safety duties of a separate employer's employees.

          Specifically, opponents contend that this bill holds an innocent  
          third-party individual or business liable for the employment  
          obligations of another employer:
          
               "[This bill] imposes liability upon a third party  
               individual or business for the wage and hour obligations of  
               another employer even though there is absolutely no  
               evidence or proof that the third party exerted any control  
               over the working conditions of the contractor's employees.   


               Currently, a third party may be liable for the labor  
               obligations of another employer under two legal theories:   
               (1) joint employer liability or (2) independent contractor  
               misclassification.  The key factor for both of these  
               analyses is that the third party exerted such control over  
               the working conditions of the contractor's employees that  
               essentially the third party acted as the real employer.   
               See Bradley v. California Dept. of Corrections and  
               Rehabilitation, 158 Cal.App.4th 1612 (2008)(state agency  
               exerted sufficient control over individual to be considered  
               employer for purposes of FEHA); Martinez v. Combs
               49 Cal.4th 35 (2010)(stating that for joint employer  
               liability, employee must prove the third party exerted  
               control over the working conditions of the employee);  (S.  
               G. Borello & Sons, Inc. v. Department of Industrial  
               Relations, 48 Cal.3d 341 (1989) ("the principal test of an  
               employment relationship is whether the person to whom  
               service is rendered has the right to control the manner and  
               means of accomplishing the result desired"); Cristler v.  
               Express Messenger Systems, Inc., 171 Cal.App.4th 72 (2009)  
               (same); Lara v. Workers' Compensation Appeals Bd., 182  
               Cal.App.4th 393 (2010) (same).  The burden to establish  
               either theory is on the employee who is seeking to hold the  
               third-party liable for any alleged employment violations.

               [This bill] completely ignores this long-standing common  
               law analysis and imposes liability despite the lack of any  
               control exerted by the third-party.  Even though the  
               third-party did not control the wages owed, did not control  
               the hours the employee worked, and did not control the work  









                                                                  AB 1897
                                                                  Page O
               environment of the employee, the third party will be held  
               liable for all such obligations."

          Opponents also argue that this bill jeopardizes employee  
          confidentiality:

               "[This bill] mandates that a client employer or a labor  
               contractor shall comply with any agency or department's  
               request to inspect records in order to verify compliance  
               with applicable laws.  This means that a third party  
               entity, who is not the employee's actual employer, will  
               have an obligation to produce personnel records of an  
               employee, that includes sensitive information such as  
               hourly rate, social security numbers, birth date, and  
               potential medical information regarding any alleged  
               injuries.  This is an impossible mandate with which to  
               comply, as the third party "client employer," does not  
               maintain personnel records of individuals that are not its  
               employees and cannot force the actual employer to comply  
               with an agency's request.  Accordingly, this provision  
               creates a liability trap for third party client employers."

          In addition, opponents contend that this bill will create  
          significant litigation: 
          
               "As a part of the Labor Code, any violation of [this bill]  
               will trigger a potential representative action under the  
               Labor Code Private Attorney General Act (PAGA), Labor Code  
               Section 2699 et seq., thereby expanding the threat of  
               onerous litigation against any third party that utilizes  
               contractors as a part of its usual course of business.  To  
               the extent a third party is held liable under PAGA for the  
               employment obligations of another, there will  
               unquestionably be a second lawsuit for indemnity between  
               the third party and actual employer.  

               The judicial branch has suffered severe budget cuts over  
               the last three years, with multiple courthouses shut down  
               and drastic staff reductions, thereby significantly  
               delaying the time it takes for civil disputes to be  
               resolved.  Forcing an innocent third party to pursue  
               litigation that may take years in order to recover monies  
               paid out for the violations of another, is simply unfair."

          Finally, opponents contend that there are already adequate  









                                                                 AB 1897
                                                                  Page P
          protections under existing law for dealing with documented  
          problems that involve contracting:

               "For those industries in which there has been documented  
               evidence of unlawful contracting practices, the legislature  
               has already enacted laws to address and prevent such  
               abuses.  Specifically, for several industries, including  
               farm labor, garment, construction, security guards,  
               janitorial, and most recently warehouse workers, Labor Code  
               Section 2810 holds the entity that contracts for workers in  
               those industries liable if the contract for such labor does  
               not include the following:  (1) a description of the total  
               hours to be worked, the total wages to be paid, and the  
               dates of payment; (2) the worker's compensation policy and  
               insurance carrier information; (3) the employer tax  
               identification number; (4) the address of where the work  
               will be performed; and, (5) the name, address, and  
               telephone number of the person or entity through whom the  
               labor or services are to be provided.  [This bill] expands  
               liability to all industries and all individuals who  
               contract for labor or services, despite the lack of any  
               evidence that there is a need beyond the industries already  
               regulated."

           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          Alameda County Labor Council
          American Federation of State, County and Municipal Employees
          Asian American Alliance for Justice--Asian Law Caucus
          Asian Americans Advancing Justice | Los Angeles
          California Alliance for Retired Americans
          California Conference of Machinists
          California Conference of the Amalgamated Transit Union
          California Employment Lawyers Association
          California Faculty Association
          California Immigrant Policy Center
          California Labor Federation, AFL-CIO (co-sponsor)
          California Nurses Association
          California Professional Firefighters
          California Rural Legal Assistance Foundation
          California School Employees Association
          California State Association of Electrical Workers
          California State Council of Service Employees International  









                                                                  AB 1897
                                                                  Page Q
          Union
          California State Pipe Trades Council
          California Teamsters Public Affairs Council (co-sponsor)
          Centro Legal de la Raza
          Chauffeurs, Teamsters and Helpers Local 150
          Chinese Progressive Association
          CLEAN Carwash Campaign
          Community Action Board of Santa Cruz County 
          Consumer Attorneys of California
          Employee Rights Center
          Engineers & Scientists, IFPTE Local 20
          Equal Rights Advocates
          Garment Workers Center
          General Teamsters Local 137
          General Teamsters Local 386
          General Teamsters Local 431
          International Longshore and Warehouse Union, West Coast Division
          Jockeys Guild
          Katherine & George Alexander Community Law Center
          Koreatown Immigrant Workers Alliance (KIWA) 
          Legal Aid Society-Employment Law Center
          Los Angeles County Federation of Labor
          Maintenance Cooperation Trust Fund
          Merced-Mariposa Central Labor Council
          Monterey Bay Central Labor Council
          Napa Solano Central Labor Council
          National Association of Social Workers, California Chapter
          National Employment Law Project
          National Lawyers' Guild Labor & Employment Committee
          North Bay Labor Council
          Northern California Carpenters Regional Council
          Orange County Labor Federation
          Professional & Technical Engineers, Local 21
          San Mateo Central Labor Council
          Sanitary Truck Drivers and Helpers Local 350
          SEIU 1000
          South Bay Labor Council
          State Building and Construction Trades Council
          Teamsters Joint Council # 42
          Teamsters Joint Council # 7
          Teamsters Joint Council 7
          Teamsters Local 315
          Teamsters Local 396
          Teamsters Local 517
          Teamsters Local 542









                                                                  AB 1897
                                                                  Page R
          Teamsters Local 63
          Teamsters Local 856
          Teamsters Local 890
          Teamsters Local 986
          UNITE HERE
          United Auto Workers, Local 5810
          United Food and Commercial Workers Western States Council  
          (co-sponsor)
          Utility Workers Union of America, Local 132
          Warehouse Workers United
          Western States Council of Sheet Metal Workers

           Opposition 
           
          Agricultural Council of California 
          American Staffing Association 
          Associated Builders and Contractors of California 
          Associated General Contractors
          Building Owners and Managers Association of California
          California Ambulance Association 
          California Asian Chamber of Commerce
          California Association of Winegrape Growers
          California Bankers Association
          California Business Properties Association
          California Cable and Telecommunications Association 
          California Chamber of Commerce
          California Chapter of American Fence Association 
          California Citrus Mutual
          California Coalition on Workers' Compensation
          California Cotton Ginners Association 
          California Cotton Growers Association 
          California Employment Law Council
          California Farm Bureau Federation
          California Fence Contractors' Association 
          California Grape and Tree Fruit League
          California Grocers Association 
          California Hospital Association 
          California Landscape Contractors Association
          California League of Food Processors
          California Manufacturers and Technology Association 
          California Newspaper Publishers Association
          California Pool and Spa Association 
          California Restaurant Association 
          California Staffing Professionals
          California Trucking Association 









                                                                  AB 1897
                                                                  Page S
          Chambers of Commerce Alliance of Ventura and Santa Barbara  
          Counties
          Civil Justice Association of California
          Consolidated Communications, Inc.
          Desert Hot Springs Chamber of Commerce & Visitors Center
          El Dorado County Chamber of Commerce
          Family Winemakers Association
          Flasher Barricade Association 
          Fullerton Chamber of Commerce
          Greater Bakersfield Chamber of Commerce
          International Council of Shopping Centers
          International Franchise Association 
          International Warehouse Logistics Association 
          Marin Builders Association 
          NAIOP of California, the Commercial Real Estate Development  
          Association
          National Federation of Independent Business
          Oxnard Chamber of Commerce
          Redondo Beach Chamber of Commerce
          San Diego East County Chamber of Commerce
          San Gabriel Valley Legislative Coalition of Chambers
          San Jose Silicon Valley Chamber of Commerce
          Santa Clara Chamber of Commerce and Convention-Visitors Bureau
          Simi Valley Chamber of Commerce
          South Bay Association of Chambers of Commerce
          Southwest California Legislative Council
          The Chamber of Commerce of the Santa Barbara Region
          The United Chambers of Commerce of the San Fernando Valley 
          Visalia Chamber of Commerce
          Western Agricultural Processors Association 
          Western Growers Association 
          Wine Institute

           
          Analysis Prepared by  :    Ben Ebbink / L. & E. / (916) 319-2091