Showing posts with label OSHA. Show all posts
Showing posts with label OSHA. Show all posts

Thursday, November 4, 2021

COVID-19 Alert: OSHA Issues Emergency Temporary Standard Affecting Private Employers

*By Scott Coghlan

Today, the Occupational Safety and Health Administration (OSHA) issued an emergency temporary standard (ETS) expected to reach two-thirds of all private sector workers in the nation.

The ETS requires private employers to either mandate COVID-19 vaccinations for their employees or have unvaccinated employees show a negative test for the virus at least weekly and wear masks. Covered employers must provide employees up to four hours of paid time to receive each vaccination dose (if during working hours) and reasonable time and paid sick leave to recover from side effects of the vaccine. Additionally, employers must provide each employee with information about the ETS (see Workers’ Rights fact sheet issued by OSHA available here). This information includes the following: workplace policies and procedures to implement the ETS; COVID-19 vaccine information; protections against retaliation and discrimination; and laws that provide for criminal penalties for knowingly supplying false statements or documentation.

Who Does the ETS Cover?

The ETS covers private employers with 100 or more employees. The 100-employee count is based on the number employees that are employed company-wide, not at each individual work location. Therefore, for a single corporate entity with multiple locations, employers must count their total employees at all locations. Employers must include part-time, temporary, and seasonal employees in the employee count. Independent contractors do not count towards the total number of employees.

Importantly, once an employer falls within the scope of the ETS, they remain within its scope – even if their total number of employees drops below 100. The determination of whether an employer falls within the scope of the ETS is based on the number of employees as of November 5, 2021. If an employer has 100 or more employees on November 5 and later reduces their workforce below 100, the ETS continues to apply to the employer for the remainder of the time the ETS remains in effect. Conversely, if an employer who has less than 100 employees on November 5 (and therefore the ETS would not initially apply) later hires more employees that exceed 100, the employer must comply with the ETS at that time.

The ETS does not apply to employees covered by previous mandates such as federal contractors and healthcare workers. Additionally, if an employer is covered by the ETS, it does not mean all of its employees must follow the ETS requirements. The ETS does not apply to employees who do not report to a workplace where other individuals are present, work from home, or work exclusively outdoors (so long as they do not routinely occupy vehicles with other employees).

For employers that do not comply with the ETS by its effective date, OSHA can impose a maximum penalty of $13,653 per citation. For willful violations, OSHA can increase the fine up to 10 times that amount.

Effective Date

By December 5, 2021, employers must comply with all requirements of the ETS (except the testing requirement for employees who are not fully vaccinated). By January 4, 2022, employers must comply with all requirements of the ETS, including the testing requirement for employees who are not fully vaccinated.

Emergency temporary standards generally remain in effect for six months at which time a determination is made as to whether the standard will become permanent. Due to the nature of COVID-19, OSHA anticipates that the ETS will remain effective for six months but states that it will update the ETS if it determines that the grave danger from the virus no longer exists or new information requires a change in the measures necessary to address the virus.

Additional Requirements

There are a number of additional requirements under the ETS. Most significantly, employers also must require their employees to provide proof of vaccination and maintain a roster with this information. Employers must keep this information strictly confidential and treat it as it would other confidential medical information. Employers also must require employees to provide prompt notice of when they test positive or are diagnosed with COVID-19.

Employers should contact counsel for the full list of requirements and any questions they may have (including, but not limited to, disability and religious accommodations). For an earlier article on the ETS, please see Z&R’s blog post here.

*Scott Coghlan chairs the firm’s Workers’ Compensation Group and regularly advises clients on all workers’ compensation and OSHA related matters. If you have a question about the Ohio BWC’s OSHA’s response to COVID-19 or any other workers’ compensation or OSHA related questions, please contact Scott at sc@zrlaw.com or (216) 696-4441.

Tuesday, September 21, 2021

OSHA To Issue Emergency Temporary Standard Requiring Employers to Ensure Employees Are Vaccinated Or Tested Weekly

*By Scott Coghlan

On September 9, 2021, the Biden Administration announced a six-point Covid-19 Action Plan that includes measures to vaccinate the unvaccinated to combat the coronavirus. Garnering the most attention, is the administration’s directive to the Occupational Safety and Health Administration (OSHA) to issue an Emergency Temporary Standard (ETS) applicable to private employers with 100 or more employees. The ETS will likely impact 80 to 100 million workers. The Action Plan requires that employers mandate vaccines or require a weekly negative Covid-19 test. Employers also must provide workers paid time off to get vaccinated and recover from vaccine side effects. The Action Plan contained few specifics, and many questions remain unanswered.

Which Employers Does the ETS Cover?

Based on the Administration’s Action Plan, the ETS will cover all private businesses with 100 or more employees. OSHA exempts public employees from coverage. In Ohio, public employers must comply with the Ohio Public Employment Risk Reduction Act (PERRP) which is part of the Ohio Bureau of Workers’ Compensation. PERRP typically adopts OSHA regulations.

It is not known whether OSHA will count the number of employees at an individual work location or on a company-wide basis to reach the 100+ employee threshold. For traditional workplace safety and health regulations, OSHA typically uses a company-wide approach. However, policy considerations may drive the manner in which employers must count their employees. Due to concern about Covid-19 outbreaks in work locations with large numbers of people in close proximity, OSHA could utilize a location-based calculation. Alternatively, OSHA may adopt a company-wide calculation.

When Will OSHA Publish the ETS, When Will It Take Effect And How Long Will It Last?

The Action Plan did not set a deadline for OSHA to publish the ETS. For comparisons sake, on January 21, 2021, the Administration issued an executive order directing OSHA to develop an ETS to protect healthcare workers from contracting the coronavirus. Nearly six months later, on June 10, 2021, OSHA published its Covid-19 Healthcare ETS. However, the Covid-19 Healthcare ETS was very comprehensive covering many topics, including personal protective equipment, engineering controls to reduce to risk of contracting the coronavirus, employee training and health screening. OSHA’s directive to develop the private employer ETS appears more focused in its application and we expect publication in a shorter time period.

The ETS will become effective immediately upon publication in the Federal Register. However, OSHA will likely provide employers with forty-five to ninety days to comply with the temporary standard before OSHA will begin enforcing its provisions. Most vaccines require two-doses. As a result, OSHA will likely delay enforcement to allow for this two-dose regimen.

To enact an ETS, OSHA must demonstrate that workers are in grave danger due to exposure to toxic substances, a physical harm or to a new hazard such that an emergency standard is necessary to protect them. An ETS can remain in place for six months unless it becomes a permanent OSHA standard following a formal rulemaking process and public comment period.

How Much Paid Leave Will Employees Receive To Get Vaccinated And Who Pays For Testing?

The Action Plan states that EFT developed by OSHA will require employers with 100+ employees “to provide paid time off for the time it takes for workers to get vaccinated or to recover if they are under the weather post-vaccination.” The Action Plan does not state the amount of paid time-off employers must provide.

The Action Plan also does not indicate who must pay for the weekly Covid-19 testing (the employer or the employee). The Action Plan states that the ETS will require “any workers who remain unvaccinated to produce a negative test result on at least a weekly basis before coming to work.” Thus, it appears that the burden of production will fall on the employee. The Action Plan also announced that large retailers that sell at-home, rapid Covid-19 tests, such as Walmart, Amazon and Kroger, will sell the test kits at-cost for the next three months. The temporarily reduced test costs may signal that employees will bear the cost of testing. In contrast, OSHA historically requires employers to incur the cost of traditional workplace safety and health measures.

Will Exemptions Exist Under The ETS?

We expect that the ETS will provide for exemptions based on medical conditions or sincerely held religious beliefs. The Action Plan gives no indication that it will provide for other exemptions beyond those required by Title VII and the ADA.

What Should Employers Do Now?

Although many of the detailed requirements of the ETS remain unknown, employers should begin considering how to comply with the general vaccination or testing mandate set forth in the Action Plan, including:

  • 100+ employee threshold: Employers should calculate the number of current workers employed company-wide and at each individual location, including full-time, part-time, temporary, seasonal and remote employees.
  • Documenting employee vaccination status: Employers should consider how they will account for employee vaccine status. The EEOC has indicated that employers can request documentation or other confirmation of Covid-19 vaccination status. However, like all medical information, employers must keep that information confidential and store it separately from employee personnel files.
  • Tracking Test Results: If vaccination is not a condition of employment, employers will have to create a procedure to track the weekly Covid-19 tests for its unvaccinated employees.
  • Responding to requests for medical and religious exemptions: Employers should base medical exemptions on objective medical documentation, keep them confidential, and store that information separately from employee personnel files. Religious exemption requests will prove more difficult to ascertain. Employers generally have no reason to inquire into the religious beliefs of its employees. An employee must base a religious exemption request on a sincerely held religious belief rather than a personal philosophy or objection to vaccination. We recommend legal consultation on religious exemption requests if decision makers are not well versed in this area. Considerations for accommodating these workers include mandatory mask wearing, physical distancing, remote work, etc.
  • OSHA inspections: OSHA performs on-site inspections and “phone/fax” investigations. The later occurs when the agency contacts the employer, describes the safety or health complaint and requests documentation of compliance with the standard, problems found and/or corrective actions taken. Although the ETS enforcement guidelines remain unknown, employers should preparation for inspections. Employers should identify the company representative that will take part in any inspection related to the ETS and review injury and illness logs (OSHA 300, 301 and 300A) for accuracy and to ensure completed hazard assessments readily available for review by the investigator.
*Scott Coghlan, chairs the firm’s Workers’ Compensation Group and regularly advises clients on all workers’ compensation and OSHA related matters. If you have a question about the Ohio BWC’s or OSHA’s response to Covid-19 or any other workers’ compensation or OSHA related questions, please contact Scott at sc@zrlaw.com or (216) 696-4441.

Wednesday, June 3, 2015

The Jenner Effect: OSHA Releases New Best Practices on Restroom Access for Transgender Employees

By Scott Coghlan*

The United States Department of Labor’s Occupational Safety and Health Administration (“OSHA”) released a new best practices guide on June 1, 2015, concerning transgender workers’ use of workplace restrooms.

OSHA’s sanitation standard already requires that all covered employers provide employees with sanitary and available toilet facilities. Generally, OSHA prohibits employers from placing unreasonable restrictions on restroom use, such as restroom facilities that are an unreasonable distance from an employee’s worksite. While many employers provide separate restrooms for men and women, OSHA does not require it. With increasing frequency, employers that provide separate restrooms are facing the issue of which restroom transgender employees should use.

Transgender individuals are those who do not identify with the gender they were assigned at birth – for example, a transgender woman may have male listed as the gender on her birth certificate and have been raised as a boy, but internally identifies as a woman. Transgender individuals may “transition” to live life as the gender they identify with in a number of different ways, including through changes to appearance, name changes, medical procedures, and changes to official identification documents.

OSHA published its new best practices guide, titled “A Guide to Restroom Access for Transgender Workers,” at the request of the National Center for Transgender Equality. With the new guidelines, OSHA seeks to ensure that transgender individuals feel safe and comfortable when using workplace restrooms. OSHA suggests that employers allow employees to use the restroom for the gender with which they identify. Thus, a transgender man should be permitted to use the men’s restroom. OSHA also offered alternative suggestions, including providing a single-occupancy, gender-neutral restroom or multiple-occupant, gender-neutral restrooms with lockable single-occupant stalls. Additionally, OSHA cautions against segregating or singling out transgender employees by requiring those employees to use restrooms that do not conform with their gender identity or by requiring transgender employees to use only specific or gender-neutral restrooms when gender-specific restrooms are available. Finally, OSHA’s new guidelines state that employees should not be required to present medical or legal documentation of their gender identity in order to have access to restroom facilities for the gender with which they identify.

OSHA’s guidelines do not place any legal requirements on employers to follow them. However, employers should keep in mind that the Equal Employment Opportunity Commission (the “EEOC”) and other agencies have interpreted Title VII’s prohibition of gender discrimination to extend to discrimination based on gender identity and transgender status. Recently, the EEOC ruled that prohibiting a transgender person from accessing restrooms for his or her gender identity constituted direct evidence of discrimination, even though the transgender person had not undergone any medical procedure to “transition.” Additionally, several states already have laws in place concerning transgender individuals’ rights to access restrooms corresponding to their gender identity.

*Scott Coghlan practices in all areas of workplace safety law. For more information about OSHA’s new best practices guide and OSHA in general, please contact: Scott Coghlan | sc@zrlaw.com | 216.696.4441

Wednesday, May 6, 2015

OSHA Reveals a New Version of the “It’s the Law!” Workplace Poster

By Scott Coghlan*

The Occupational Safety & Health Administration (“OSHA”) recently released a new version of its “Job Safety and Health – It’s the Law!” poster, which informs employees of their rights and employers of their legal obligations concerning workplace safety. OSHA requires covered employers to display the poster in a conspicuous place where employees can see it. Covered employers include almost all private-sector employers.

The poster, which is available to download for free from OSHA’s website, informs employees of their rights and reminds employers of their obligations to provide a safe workplace. While employers are not required to replace an older version of the poster with the new version to meet their legal obligation to display a poster, OSHA made changes in the new version. The most important change is that employers are now required to report each work-related fatality, hospitalization, amputation, and loss of an eye to OSHA.

The poster informs employees of their rights regarding workplace safety and health. The poster also informs employers of their legal obligations concerning workplace safety and health. In particular, the poster has been updated to include employers’ notification obligations. The poster is also available in several other languages, including Chinese, Korean, and Spanish. While OSHA does not require employers to display the poster in any languages in addition to English, it does encourage them to put up a poster in Spanish. OSHA requires copies of the poster to be at least 8.5” by 14” and in size 10 type. To download a free copy of the poster and review OSHA’s requirements concerning display of the poster, employers should visit OSHA’s website at:

www.osha.gov/publications/poster.html.

*Scott Coghlan practices Workers’ Compensation Law. He has extensive experience counseling employers as to workplace safety and related issues. For more information about OSHA’s new poster or workers’ compensation law, please contact: Scott Coghlan | sc@zrlaw.com | 216.696.4441

Monday, December 22, 2014

OSHA Announces New Reporting Requirements For Severe Injuries – Effective January 1, 2015

By Scott Coghlan*

As of January 1, 2015, employers must report to OSHA all work-related fatalities, in-patient hospitalizations and amputations, including the loss of an eye. Previously, employers were only required to report work-related fatalities and the hospitalization of three or more employees resulting from a single incident.

Under the new regulation, 29 C.F.R. 1904.39, employers must report to OSHA any work-related fatality within 8 hours of the death. This requirement applies to any fatality occurring within 30 days of the work-related incident attributed to the death.

Each in-patient hospitalization resulting from a work-related incident must be reported within 24 hours of the hospitalization. This requirement applies to all in-patient hospitalizations occurring within 24 hours of the precipitating work-related incident. “In-patient hospitalization” is defined as the formal admission to the in-patient service of a hospital or clinic for care or treatment. Excluded from the definition is hospitalization for observation and/or diagnostic testing.

Similarly, any amputation, including the loss of an eye, resulting from a work-related incident must be reported within 24 hours of the amputation. All amputations and eye losses must be reported if they occur within 24 hours of the work-related incident. “Amputation” is defined as the traumatic loss of a limb or other external body part that has been severed, cut off or amputated (completely or partially). Fingertip amputations without bone loss, medical amputations made necessary due to irreparable damage and amputations that have since been reattached are included as reportable. Conversely, avulsions (forcible tearing away of a body part by trauma or surgery), enucleations (removal of the eye), deglovings (peeling away of soft tissue to expose bone), severed ears or broken/chipped teeth are excluded from the definition.

Employers can report the above matters to OSHA in three ways: (1) in person to the OSHA Area Office nearest to the site of the accident; (2) by telephone to the OSHA Area Office nearest to the site of the accident or the OSHA toll-free central telephone number, 1-800-321-OSHA (1-800-321-6742); or (3) by electronic submission using the fatality/injury/illness reporting application located at www.osha.gov.

*Scott Coghlan practices Workers’ Compensation Law. He has extensive experience counseling employers as to workplace safety and related issues. For more information about OSHA’s new reporting requirements or workers’ compensation law, please contact: Scott Coghlan | sc@zrlaw.com | 216.696.4441

Wednesday, November 20, 2013

OSHA Compliance Deadline Approaching: Employers Must Train Employees on the Revised Hazard Communication Standard by December 1, 2013

*By Scott Coghlan

Recently, the Occupational Safety and Health Administration (“OSHA”) revised its Hazardous Communication Standard (“HCS”). The revised HCS introduces new labeling requirements for hazardous chemicals in the workplace and standardized Safety Data Sheets (formerly called Material Safety Data Sheets). The revised HCS will be implemented in phases from December 1, 2013 to June 1, 2016. For the first compliance deadline, December 1, 2013, employers must make sure that their employees are trained on the new labels and Safety Data Sheets.

Hazardous Chemical Label Training Requirements

The revised HCS defines labels as “an appropriate group of written, printed or graphic information elements concerning a hazardous chemical that is affixed to, printed on, or attached to the immediate container of a hazardous chemical, or to the outside packaging.” Beginning on June 1, 2015, employers must comply with new labeling requirements for all hazardous chemicals utilized in the workplace.

A detailed OSHA Brief on the new labels can be found at:

https://www.osha.gov/Publications/OSHA3636.pdf.

While employers are not required to comply with the new labeling requirements until June 1, 2015, they are free to start using the new labels before that date. However, employers must train their employees on the new labels before December 1, 2013.

As a part of the new hazardous chemical label training, employers must train their employees on the following information included in the new labels: (1) the product identifier, which may be in the form of the chemical’s name or a code or batch number; (2) the signal word identifying the severity of the hazard posed by the chemicals, being either “Danger” for the most severely hazardous and “Warning” for the less severely hazardous chemicals; (3) the OSHA designated pictograms; (4) the hazard statement or statements, which identify the hazard posed by the chemical and in some instances the degree of hazard; (5) the precautionary statement or statements, which explain recommended safety measures to protect individuals from the hazards posed by the chemicals; and (5) the name, address, and phone number of the manufacturer, distributor, or importer of the chemical.

Before December 1, 2013, employers must also train their employees on how the employee will use the new labels and how the various elements on each label work together. As examples of the types of information that needs to be conveyed to employees in this training, OSHA explains that employers should: (1) explain how employees can use label information to make sure that chemicals are properly stored; (2) explain how to use the labels in emergency situations and for information on first aid; (3) explain that there will be various pictograms on chemicals that pose multiple hazards and how the pictograms will correspond to hazard classes; and (4) explain that in instances where multiple precautionary statements apply to a chemical, the statement with the most protective information will be on the label.

Safety Data Sheet Training Requirements

Safety Data Sheets provide more in-depth information on hazardous chemicals than the labels. Under the revised HCS, chemical manufacturers, distributors, and importers must ensure that they provide Safety Data Sheets for all hazardous chemicals. A detailed OSHA Brief on the content of the Safety Data Sheets can be found at: https://www.osha.gov/Publications/OSHA3514.pdf. Employers are required to make sure that the Safety Data Sheets for all hazardous chemicals in the workplace are readily available to their employees. OSHA recommends keeping the Safety Data Sheets in binders or on computers that are easily accessible to workers in the work area and keeping back-up copies available.

Before December 1, 2013, employers must train their employees on the new format of the Safety Data Sheets and explain how they relate to the new labels. Employers must train employees on each of the 16 sections included in the Safety Data Sheets and explain the type of information that will be found in each of the sections.

Employers who have not done so already, need to train their employees on the new hazardous chemical labels and Safety Data Sheets before the December 1, 2013 compliance deadline. Employers should contact counsel to make sure that they are properly training their employees under the revised HCS as required by OSHA and to keep up-to-date on the future compliance deadlines which will be implemented in phases until June 1, 2016.

*Scott Coghlan, the chair of the firms’ Workers’ Compensation Group, has extensive experience in all aspects of OSHA and workers’ compensation. For more information about OSHA compliance, please contact Scott at 216.696.4441 or sc@zrlaw.com.

Monday, June 17, 2013

EMPLOYMENT LAW QUARTERLY | Spring 2013, Volume XV, Issue i

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Non-Compete Agreements and Separation Agreements — Are They Incompatible?

By Helena Oroz*

Does a separation agreement nullify an earlier covenant not to compete? It depends. In Try Hours, Inc. v. Douville, 2013 WL 139584 (January 11, 2013), the Ohio Sixth District Court of Appeals recently held that a one year non-compete agreement was not superseded by a separation agreement between the two parties. Try Hours, a national trucking company focused on the expedited freight industry, was the plaintiff-employer in the case. Try Hours hired the defendant, Bryan Douville (“Douville”), in 2010 as its director of operations. Douville signed an employment agreement that contained a non-compete and non-solicitation clause. The clause provided that Douville could not work for any company within the United States in direct competition with Try Hours for a period of one year after his employment with Try Hours ended. Finding Douville was not a good fit for the organization, Try Hours terminated his employment in October 2011.

At the time of Douville’s discharge, the parties entered into a separation agreement that included an integration clause. The integration clause stated that the separation agreement constituted the entire agreement between the parties and that “no prior or subsequent oral Agreements, representations or understandings shall be binding upon the parties and such shall be null and void and shall have no effect.” Douville, believing that the separation agreement freed him from his obligation to abide by the non-compete agreement, began work at a competitor.

Try Hours brought suit alleging that Douville violated the non-compete agreement, and sought a preliminary injunction to enjoin Douville from working for the competitor. The trial court granted Try Hours' motion for preliminary injunction. On appeal Douville asserted: (1) the separation agreement effectively nullified the original employment agreement; (2) that the grant of the preliminary injunction was error; and (3) that the duration and scope of the injunction was unreasonable.

The court first determined the separation agreement did not supersede the employment agreement between the parties. Douville argued that the integration clause contained within the separation agreement was ambiguous as to whether the separation agreement was meant to supersede the employment agreement. The court found the separation agreement merely limited the rights of Douville to bring a claim against Try Hours stemming from his employment. Furthermore, the court found that the integration clause only excluded oral agreements. Therefore, the court reasoned that since the non-compete clause was a written agreement it should not be superseded by the separation agreement’s reference to “subsequent oral Agreements.”

The court then looked to determine whether a preliminary injunction should have been granted in favor of Try Hours. Try Hours argued that the competitive nature of the freight trucking industry required that its sensitive company information be kept confidential. It asserted that information such as the company’s drivers’ names, customer list, pricing information, and quality and service scores was crucial to Try Hours’ performance and was therefore confidential. Try Hours was especially protective of its drivers’ information, arguing that the demand for quality expedited freight truck drivers far exceeded the actual number of such drivers. The court agreed with Try Hours and found that this sensitive information was indeed confidential, especially in light of the fact that Douville’s job at PFM included securing truck drivers to haul expedited freight, which placed him in direct competition with Try Hours.

Douville argued that the injunction placed an undue hardship on him as it prevented him from procuring employment in an industry in which he had worked for 11 years. The court, however, determined that the “direct competition” language of the non-compete agreement limited his ability to work in the freight industry only. The court reasoned that while Douville would experience some hardship throughout the duration of the injunction, he must demonstrate more. The court noted that Douville was still free to seek employment with any trucking company not engaged in the expedited freight business. The court also determined that the non-compete agreement’s provision prohibiting Douville from working for any expedited freight trucking company across the United States was appropriate as the trucking industry is a multistate industry. Finally, the court determined that the one year duration of the restriction period was a reasonable amount of time. As such, the court reaffirmed Try Hours’ injunction.

This case presents two important lessons for employers. First, employers should craft carefully separation agreements that do not accidentally supersede any prior non-compete or other agreements. Second, employers should draft non-compete agreements narrowly (in both scope and duration) and consider the degree of hardship to the employee. Both of these concepts will help employers achieve their objectives as to departing employees.

*Helena Oroz practices in all areas of employment litigation and has extensive experience helping employers draft, enforce, and otherwise advise clients about non-compete agreements. For more information about this ever changing area, please contact Helena (hot@zrlaw.com) at 216.696.4441.



PUBLIC SECTOR EMPLOYERS: “Which Hat Is He Wearing?”

By Jonathan J. Downes*

Everyone knows the First Amendment protects free speech, but no right is absolute. Public employee speech is no different.

The First Amendment protects a public employee’s speech if he or she speaks as a citizen about matters of public interest. When that public employee speaks in his or her official capacity regarding his or her official duties or matters not of public interest, that employee is not insulated from discipline. Does this same rule apply to a public employee who is also a union official criticizing or challenging decisions or policy of an employer?

The U.S. Court of Appeals for the Ninth Circuit (which covers much of the west coast) recently decided how First Amendment free speech protections apply to a union “no-confidence vote.” The case is Ellins v. City of Sierra Madre, 710 F. 3d 1049 (9th Cir. 2013).

John Ellins, a police officer for the City of Sierra Madre, California, led a no-confidence vote of the police officers’ union against the Chief of Police, Marilyn Diaz in 2008. According to Ellins, the union initiated the vote due to Diaz’s “lack of leadership, wasting of citizens’ tax dollars, hypocrisy, expensive paranoia, and damaging inability to conduct her job.”

In 2009, Ellins submitted an application to Diaz for a certification that, under the City’s Memorandum of Understanding with the police officers’ union, would have entitled him to a five percent raise. When Diaz delayed approving his application, Ellins filed suit, claiming that the failure to process his application was in retaliation for his exercise of free expression and association and his union activities related to the “no confidence” vote.

The district court ruled in favor of the City and Diaz, holding that Ellins had not established a claim of First Amendment retaliation. In addition to failing to establish the other elements of his claim, Ellins failed to establish that he spoke as a private citizen in leading the no-confidence vote.

The Ninth Circuit reversed on this issue, rejecting the City’s position that Ellins conducted the no-confidence vote as a police officer, not as a citizen. The Court found that Ellins’ conduct was in his capacity as a union representative, noting that there is an “inherent institutional conflict of interest between an employer and its employees’ union.” Therefore, the Court held that a reasonable jury could find that Ellins’ speech, made as a representative and president of the police union, was made in his capacity as a private citizen.

The Court also concluded that the concerns raised by the no-confidence vote addressed the Chief’s leadership and other department-wide matters. The Court found that “these departmental problems were of inherent interest to the public because they could affect the ability of the Sierra Madre police force to attract and retain officers.”

*Jonathan J. Downes, an OSBA certified specialist in labor and employment law, practices in the firm’s Columbus, Ohio office and has extensive experience representing public sector employers. If you have any questions about the above or any other union/employee issue, contact Jonathan (jjd@zrlaw.com) at 614.224.4411.



FireYou? Ok!...I Think

By B. Jason Rossiter*

The prevalence of social media increases by the minute. Every day millions of people login to their Facebook, Twitter, LinkedIn, and other social networking accounts and post their thoughts to the world. Sometimes, these broadcasted postings include an employee’s disdain for his or her job or, in many cases, his or her boss.

The increase in social media activity by employees has led to the development of new programs and applications designed to track such activity, including “FireMe!” FireMe! is a new Twitter application developed to alert users of the likelihood of termination as a result of what they post. FireMe! was developed by Ricardo Kawase, a PhD student in Hannover, Germany, with the goal of raising awareness about the danger of public online data. FireMe! scans a user’s Twitter accounts for keywords such as “kill,” “boss,” and “job,” as well as any combination of foul language to identify problematic tweets concerning the workplace. It also notifies users about tweets that may jeopardize the user’s employment.

Employers may be tempted to utilize this or similar applications to identify employees tweeting about the workplace. If an employer knows an employee’s twitter account name, they can log onto the FireMe! website, enter the employee’s twitter account, and a ranking will appear, indicating how “likely” that Twitter user is to be fired for the content of their tweets.

Employers beware, though. The National Labor Relations Board (“NLRB”) already has held on numerous occasions that Section 7 of the National Labor Relations Act (“NLRA”) protects employee postings on the internet. The NLRA protects employees in “circumstances where individual employees seek to initiate or to induce or to prepare for group action, as well as individual employees bringing truly group complaints to the attention of management,” even if that action takes place online. 

The NLRB has taken the position that, in general, so long as an employee’s online posting is related to the terms and conditions of his or her employment, it is considered protected speech and the employee cannot be fired for it. The NLRB also has routinely struck down employer policies prohibiting employee statements that could damage the company, defame any individual, or damage any person's reputation. However, online postings of threats of violence against co-workers, supervisors, or company property generally are not protected and an employer typically may terminate an employee for such conduct.

Ultimately, the determination of whether a social media post constitutes protected activity under the NLRA requires an individualized inquiry. The slightest difference in wording can mean the difference between a lawful and an unlawful termination. As social media continues to play a larger role in employees’ lives, enterprising individuals and companies will continue to develop tools such as the FireMe! application. However, employers should cautiously decide whether to utilize such tools. In addition, employers may want to consider using such tools for constructive purposes. Employees may take to Twitter and other social media outlets to vent workplace-related frustrations of which an employer is simply unaware. Employers can then take steps to remedy these issues, leading to a happier and more productive workplace.

*B. Jason Rossiter practices in all areas of employment litigation. He has extensive experience helping employers navigate through social media and related employment issues. For more information about this ever changing area, please contact Zashin & Rich at 216.696.4441.



Do the Math: Unpaid Interns Don’t Equal Free Labor 

By David R. Vance*

According to the National Association of Colleges and Employers, 55% of students in 2012 graduated with some internship experience on their resume. While unpaid internships can benefit students and employers, employers must ensure any such internship comply with both federal and state wage and hour laws. Failure to do so may result in a lawsuit with a potentially large damage award.

In 2010, the Deputy Wage and Hour Administrator for the United States Department of Labor (“DOL”) told the New York Times, “If you’re a for-profit employer or you want to pursue an internship with a for-profit employer, there aren’t going to be many circumstances where you can have an internship and not be paid and still be in compliance with the law.” Since then, unpaid interns have filed numerous class action lawsuits claiming that the companies for which they interned violated the Fair Labor Standards Act (“FLSA”) by failing to pay them for their work.

The FLSA does not specifically contain an exception for student interns. Rather, the DOL has provided a small exception for “trainees,” and has recognized that student interns may qualify as trainees. If an intern is considered a “trainee” under the FLSA, employers are not required to pay the intern minimum wage or overtime. In order to constitute a trainee, unpaid interns must satisfy the six factors set out by the United States Supreme Court in Walling v. Portland Terminal Co., 330 U.S. 148 (1947).

After Walling, the DOL released Fact Sheet number 71 which applies the six factors to unpaid interns. According to the DOL, if all of the following requirements are met, the intern does not constitute an employee under federal law:

  • The training, even though it includes actual operation of the facilities of the employer, is similar to that which would be given in a vocational school;
  • The training is for the benefit of the trainees or students;
  • The trainees or students do not displace regular employees, but work under close supervision;
  • The employer that provides the training receives no immediate advantage from the activities of the trainees or students and, on occasion, the employer’s operations may even be impeded;
  • The trainees or students are not necessarily entitled to a job at the conclusion of the training period; and
  • The employer and the trainees or students understand that the trainees or students are not entitled to wages for the time spent in training.

While many courts look to these factors to determine whether an unpaid internship is proper, the United States Court of Appeals for the Sixth Circuit, which covers Ohio, does not. Instead, the 6th Circuit uses the “primary benefit test” articulated in Solis v. Laurelbrook Sanitarium & Sch., Inc., 642 F.3d 518 (6th Cir. Tenn. 2011). The primary benefit test determines “whether an employment relationship exists in the context of a training or learning situation [by ascertaining] which party derives the primary benefit from the relationship. Solis at 529. According to the Sixth Circuit, if an employer derives the primary benefit, then an employment relationship exists, and the FLSA and other pertinent laws apply.

Unpaid internships at non-profit organizations are generally permissible because the FLSA includes exceptions for volunteers who perform services for state or local government agencies and those who volunteer at food banks. The Wage and Hour Division of the DOL also has recognized other exceptions for interns working at religious, charitable, civic or humanitarian non-profit organizations who freely volunteer their time without any expectation of compensation.

To help ensure compliance with the FLSA, employers should have interns sign a written agreement when their internship commences. This agreement should make clear that the intern is not entitled to wages or a permanent position upon completion of the program. Companies also should rotate interns through different departments, have specific goals for interns, and closely supervise interns so that the experience is truly educational.

Employers and students alike can benefit from internship programs. However, employers must carefully navigate through FLSA and DOL rules and regulations (as well as applicable state laws) to ensure that a mutually beneficial experience does not become a very costly lawsuit.

*David R. Vance practices in all areas of employment law and has extensive experience representing employers in wage and hour matters as well as advising employers about internship programs. If you have any questions about the FLSA or wage and hour issues affecting your workplace, contact David (drv@zrlaw.com) at 216.696.4441.



Enough is Enough: How Much Time Must an Employer Give an Employee as a Form of a Reasonable Accommodation Under the ADA?

By Emily A. Smith*

An employee ventures into his or her manager’s office and requests medical leave for a disability. The employee produces a note from his or her doctor that supports the employee’s request, so the employer grants the employee’s request for leave. The employee’s leave expires and the employee subsequently submits another request. The employer once again grants the employee’s request. This scene replays itself over again and again and again, like a scene out of Groundhog Day. The employer is left stranded, wondering “When is enough, enough?”

The Americans with Disabilities Act (“ADA”) does not mandate that employers grant employees indefinite leaves of absence. However, the ADA provides employers little assistance in determining how much leave is reasonable in situations like the one described above. Are employers’ hands tied when an employee makes repeated requests for leave?

The Eleventh Circuit recently provided some clarity in Santandreu v. Miami Dade County, 2013 U.S. App. LEXIS 5542 (11th Cir. 2013). In this case, Juan Santandreu alleged that his employer failed to provide reasonable accommodations for his disability. Santandreu worked as an engineer in the Miami Dade County Water and Sewer Department (“Miami Dade”). He went out on medical leave in January 2006 due to an “illness.” Santandreu then requested four extensions of his leave, each request coming just as the previous request was set to expire. In all, Santandreu requested, and Miami Dade granted, leave from January 2006 through May 4, 2007.

On May 1, 2007, Miami Dade sent Santandreu a letter advising him that he was to return to work on May 5, 2007. He did not return to work but advised Miami Dade on May 15, 2007, that his leave of absence should be extended until July 25, 2007. Miami Dade informed Santandreu he had exhausted all available leave and would be terminated if he did not return to work. Miami Dade subsequently sent Santandreu a Disciplinary Action Report (“DAR”), and Santandreu voluntarily resigned in lieu of receiving or opposing the DAR. Santandreu then attempted to rescind his resignation, and Miami Dade denied his request.

Santandreu filed suit against Miami Dade, claiming disability discrimination and retaliation in violation of the ADA. At trial, Miami Dade moved for judgment as a matter of law. The trial court granted the motion, finding that Santandreu had failed to show that additional leave would have enabled him to return to work in a reasonably definite period of time. The trial court also found that the DAR did not constitute retaliation because Santandreu had voluntarily resigned before the DAR became part of his record.

On appeal, the Eleventh Circuit affirmed the decision of the trial court. The court first rejected Santandreu’s argument that Miami Dade should have provided additional leave or transferred him to a vacant position. The court noted that Santandreu bore the burden of identifying an accommodation and demonstrating that the accommodation allowed him to perform the essential functions of his job. It further noted that the ADA does not require an employer to provide leave for an indefinite period of time when an employee is uncertain about the duration of his leave. The court found that Santandreu never demonstrated he could return to work within a reasonable time. Even after fifteen months of leave, he did not know when his doctor would allow him to resume working. Therefore, because Santandreu could not show that he could perform the essential functions of his job in the reasonably immediate future, his request for additional leave was not a request for a reasonable accommodation. For similar reasons, the court found that Miami Dade was not required to transfer Santandreu to another position. Since his medical condition prevented him from performing any work, he was not qualified for any alternate position.

Finally, the court found that Miami Dade did not retaliate against Santandreu by issuing him the DAR, because Santandreu voluntarily resigned in lieu of accepting or responding to the DAR. As such, the court found that Santandreu did not suffer an adverse employment action.

While this case does not establish a bright-line test that can be used by employers to determine when an employee’s requests for leave become unreasonable, it does provide some guidance. This case reaffirms that the employee bears the burden of showing a reasonably definite return-to-work date on which the employee will be able to perform the tasks required of him or her upon the employee’s return.

An employer who is faced with a situation like that in Santandreu should err on the side of caution when denying a request for leave. If the employee’s request for leave is reasonable in length and the employee will be able to perform the essential tasks required of him or her at the end of the period of leave, the leave should be granted. However, if the employee continuously requests time off, and has given no indication of returning to work, the employer may carefully consider discharging the employee so long as other reasonable accommodations, such as a transfer, are given serious consideration. Employers also should engage in the interactive process with the employee to ensure that they understand the employee’s condition and whether a reasonable accommodation exists in order to avoid liability under the ADA.

*Emily A. Smith practices at the firm’s Columbus, Ohio office in all areas of employment litigation. Emily has extensive experience in resolving ADA claims and helping employers create and implement medical leave policies and procedures. For more information about ADA compliance, or any other labor and employment issue, please contact Zashin & Rich at 614.224.4411.



The Dukes of Hazzard: OSHA and Workplace Bullying

By Scott Coghlan*

Earlier this year the Occupational Safety and Health Administration (“OSHA”) and the Department of Labor (“DOL”) filed suit against an employer for terminating an employee who reported workplace violence. OSHA argued that the employee’s discharge was tantamount to discharging an employee for complaining about unsafe work conditions. The fact that the alleged unsafe working conditions involved an employee’s fear of workplace violence made this case unusual.

The employee worked for Duane Thomas Marine Construction and its owner, Duane Thomas (“Thomas”). The employee claimed Thomas engaged in workplace violence and created hostile working conditions on several occasions between 2009 and 2011. Thomas allegedly was abusive, made inappropriate sexual comments, yelled, screamed, and withheld the employee’s paycheck.

The employee worked directly for and reported to Thomas. The employee claimed that Thomas’ verbal, mental, and emotional abuse in the workplace had forced her and a coworker to walk off the job. The next day, Thomas requested that the employee (and her coworker) return to work in exchange for Thomas’ promise to stop any workplace bullying or abuse. However, the employee alleged that the workplace bullying and abuse continued despite Thomas’ repeated promises to cease such behavior.

In February 2011, the employee filed a whistleblower complaint with OSHA. After filing this complaint, she alleged that Thomas retaliated against her due to her complaints. Thomas, upon receiving notice of the employee’s OSHA complaint, denied the employee remote access to files, and ultimately discharged the employee. After the employee’s discharge, the OSHA investigation found merit to the employee’s complaint.

This suit seems to indicate a shift in OSHA’s focus from addressing traditional workplace hazards toward protecting the overall health and well-being of employees. The General Duty clause of the Occupational Safety and Health Act of 1970 (“OSH Act”) requires “each employer to furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees.” 29 USCS § 654(a)(1). OSHA has typically used the General Duty clause to enforce safety standards relating to industrial hazards such as high noise levels, chemical exposure, or electrical hazards. However, this case involves one of the first – if not the first – OSHA lawsuit against an employer for workplace bullying.

Historically, OSHA used the General Duty clause to cite hazards not yet addressed by a specific standard. Therefore, it makes sense that OSHA is now trying to combat workplace bullying through this clause because no specific provision in the OSH Act currently prevents bullying in the workplace. However, in order prevail on a general duty clause violation, OSHA must prove four basic elements: (1) the existence of an alleged condition or practice at the employer's workplace, (2) risk, presented by the alleged condition or practice, of event likely to cause death or serious physical harm, (3) employer or industry knowledge that the condition or practice is hazardous and exists or potentially exists at the employer's workplace, and (4) a feasible method by which the employer could have eliminated or materially reduced the alleged hazardous condition or practice.

Importantly, the OSH Act does not require that an employee’s concerns about workplace safety be valid. The alleged atmosphere of abuse and bullying caused by the employer and owner in this case may or may not have actually presented a valid safety hazard. Regardless, the OSH Act makes it unlawful for an employer to terminate an employee for complaining about a workplace safety concern. Employers must be wary not to retaliate against an employee who complains about workplace bullying, violence, or abuse, as it appears OSHA may subject them to a whistleblowing action.

In addition to liability under federal law, employees may also bring civil actions against employers under state law for workplace bullying. A number of theories of liability exist such as negligent hiring, supervision and retention, respondeat superior and failure to warn.

In order to combat workplace bullying and its legal implications, employers should consider workplace violence policies, which include reporting mechanisms for employees to report workplace violence or threats of violence. Employers should also conduct robust investigations of any and all complaints. Finally, employers can limit liability by fully investigating a potential new hire’s references for any patterns or signs of past violent behavior or improper work conduct.

*Scott Coghlan, the chair of the firms’ Workers’ Compensation Group, has extensive experience in all aspects of OSHA and workers’ compensation. For more information about OSHA compliance, please contact Scott (sc@zrlaw.com) at 216.696.4441.



Z&R SHORTS


State Law Update

On May 2, 2013, Maryland governor Martin O’Malley signed Senate Bill 4, making Maryland the ninth state to “ban the box,” removing questions about criminal history from state job applicants and postponing such questions until later in the hiring process. Maryland’s “ban the box” law applies to state applications and prohibits authorities in the judicial, legislative and executive branches of the Maryland State Government from inquiring into an applicant’s criminal history until after the applicant has been interviewed. This law, however, does not prohibit notifications to applicants that certain previous convictions may disqualify an applicant from consideration.

On May 21, 2013, Washington governor Jay Inslee signed Senate Bill 5211 into law, making Washington the latest state to ban employers from requiring or requesting that applicants and current employees disclose their username and password to their personal social media accounts. The law also prohibits an employer from requiring or coercing an applicant or current employee to add a person to the list of contacts or followers associated with the individual’s personal social networking account. However, this new law does not apply to a social network or intranet the employer uses to facilitate work-related information exchange.

On May 25, 2013, Nevada governor Brian Sandoval signed Senate Bill 127 into law, making Nevada the tenth state to prohibit employers from using credit information for employment purposes. The new law will become effective on October 1, 2013. This law prohibits employers from requiring or requesting an applicant or employee to submit credit information as a condition of employment. Employers also may not use or refer to credit information when making employment decisions. The law also prohibits an employer from refusing to hire an applicant or taking an adverse employment action against an employee who refuses to divulge credit information or who has filed a complaint or lawsuit under this law.

Zashin & Rich Continues its Columbus, Ohio Expansion

Zashin & Rich is pleased to announce the addition of Jonathan Downes to its Employment and Labor Group in its Columbus office. Jonathan Downes brings more than thirty years of experience and expertise in representing employers in all aspects of labor and employment law. In 1990, Jonathan co-founded a Columbus labor and employment law firm where he successfully represented public and private employers in all aspects of labor relations and human resource management. In addition to negotiating over 500 labor contracts, Jonathan has represented employers in hundreds of arbitrations, organizing campaigns, and administrative hearings. Jonathan has also defended employers in state courts, appellate courts, the Ohio Supreme Court, and the United States Court of Appeals for the Sixth Circuit.

Wednesday, July 31, 2013 4:20 pm
Stephen Zashin will be part of a panel presenting “Disability and Leaves of Absence: How to Combat the Rise in FMLA & ADA Claims (and Manage the Interplay Between Both) and Increased Policy Targeting by the EEOC” at the American Conference Institute’s 4th Annual Forum on Defending and Managing Employment Discrimination Litigation. For more details, go to AmericanConference.com/Discrimination.

Wednesday, August 21, 2013 8:30 pm
George Crisci presents “Internal Investigations” and “Separation of Employment” at the National Business Institute’s Employment Laws Made Simple in Akron, Ohio. For more details, go to www.nbi-sems.com.

Thursday, September 12, 2013
Jonathan Downes presents “Employment Law Update for Local Government” for the Ohio Government Finance Officers Association Annual Conference at the Hilton Columbus at Easton. For more details, go to www.ohgfoa.com.

Wednesday, November 13 2013
Jonathan Downes presents “Managing the Discipline Process” for the Ohio Association of Chiefs of Police at the Richfield BCII Facility. For more details, go to www.oacp.org.

Monday, April 22, 2013

Better Late Than Never: The Department of Labor Joins the Ever-Expanding Obamacare Rulemaking Party

*By Patrick J. Hoban

While employers have been busy thinking about "affordability" and "standard measurement periods" to ensure that they comply with the Patient Protection and Affordable Care Act (PPACA), the Department of Labor (DOL) has opened a new front in the PPACA compliance battle. Specifically, the Occupational Safety and Health Administration (OSHA) issued interim final rules addressing employee whistleblower and retaliation claims under PPACA Section 1558 on February 27, 2013 (Interim Rules).

The Interim Rules, which took effect upon publication, prohibit an employer from retaliating against an employee for, among other things, receiving a federal tax credit or subsidy to purchase insurance through a health insurance exchange; reporting a potential violation of the law's consumer-protection provisions (such as the prohibition on denying health coverage to individuals with pre-existing conditions) and/or assisting or participating in a related government proceeding or investigation. Beginning January 1, 2014, the Interim Rules will apply to insurers whether or not they employ the complaining employee. Similar to other rights created by the Fair Labor Standards Act (and enforced by most courts), employees may not waive the rights created under PPACA Section 1558 (i.e., they cannot be released by agreement).

To initiate a claim under the Interim Rules, employees must file a complaint with OSHA within 180 days of an alleged violation and OSHA will investigate the complaint. If OSHA finds reasonable cause for a violation, it will issue an order, including required remedial action. An employer may appeal and request a hearing before an administrative law judge (ALJ) within 30 days and may appeal an ALJ's decision to a Department of Labor "Administrative Review Board." An employer may also appeal a final administrative decision to a federal court of appeals. If there is no final administrative decision within 210 days of the filing of an employee complaint, the employee may initiate an action in federal district court and obtain a jury trial.

A recently issued OSHA fact sheet concerning the Interim Rules lists potentially retaliatory employer actions as including: termination or layoff; "blacklisting;" demotion; denial of overtime or promotion; discipline; denial of benefits; failure to hire; intimidation; threats; and reduction of pay or hours. Claims made under these provisions will be analyzed under the familiar burden shifting standard applied to employment discrimination, and retaliation claims. The Interim Rules provide for remedies including back pay, front pay, compensatory damages, and reinstatement.

As PPACA's full-implementation date of January 1, 2014 draws closer, employers must ensure that they consider this new source for potential liability as they do existing employment laws prior to acting.

*Patrick J. Hoban, an OSBA Certified Specialist in Labor and Employment Law, practices in all areas of private and public sector labor relations. For more information about PPACA or labor & employment law, please contact Pat (pjh@zrlaw.com) at 216.696.4441.

Friday, December 7, 2012

EMPLOYMENT LAW QUARTERLY | Winter 2012, Volume XIV, Issue i

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Good Intentions, Unintended Consequences: Paid Time Off Can Lead to Tax Liability

by Michele L. Jakubs*

Paid Time Off programs (“PTO”) allow employees to earn leave that they later can use for vacations, sicknesses and personal holidays. Under such programs, employees typically earn leave in accordance with factors such as years of service, position, and full or part-time status. PTO programs generally require employees to obtain approval from their employers prior to using their leave (except when advance notice is not possible, as in the case of an illness) and do not permit employees to carry a negative leave balance. Many employers believe PTO programs are less burdensome to administer because the employer does not have to track both “vacation” and “sick” time. However, employers must evaluate their PTO programs to ensure they comply with all applicable state and federal regulations.

When an employee separates from service, the employee often receives his or her unused leave balance in a single lump-sum payment. However, most employers may not know that amounts paid to an employee for unused leave upon separation constitute wages subject to income tax withholding and employment taxes. Employers must treat such payments accordingly.

Allowing employees to sell unused PTO back to the company at the end of the year is also another practice that can create tax problems for the employer and employee. If the employee has the option to either cash-out the PTO or roll it over to the next year, the employer must immediately tax the employee on the entire amount even if the employee actually elects to roll over the unused PTO. Under the federal income tax “constructive receipt” doctrine, the IRS considers the roll over amount received and taxable at the time the PTO is available for a taxpayer to cash out, even if the taxpayer elects to defer his or her receipt of the amount. To avoid this situation, employers should not give employees a choice to cash out or roll over their PTO. The IRS stated that mandatory cash outs do not create a “constructive receipt problem.”

To avoid these and other unintended tax consequences, employers should discuss the design of their PTO plans with a knowledgeable attorney.

*Michele L. Jakubs, an OSBA Certified Specialist in Labor and Employment Law, practices in all areas of employment law and has experience designing employee PTO plans. For more information about paid time off plans and the potential tax consequences, please contact Michele at mlj@zrlaw.com or 216-696-4441.


Family & Medical Leave Act Protects a Pre-Eligibility Request for Post-Eligibility Leave

by Patrick M. Watts

The Eleventh Circuit recently held that the Family & Medical Leave Act (“FMLA”) protects a pre-eligibility request for post-eligibility leave. Pereda v. Brookdale Senior Living Communities, Inc., No. 10-14723 (11th Cir. Jan. 10, 2012).

Brookdale Senior Living Communities (“Brookdale”) operates numerous senior living facilities. Brookdale hired Kathryn Pereda (“Pereda”) in October 2008. Pereda informed management in June 2009 that she was pregnant and would need leave under the FMLA after the birth of her child in November 2009. At the time Pereda requested leave, she was not eligible for FMLA protection because she had not worked the requisite hours (1,250 hours during the previous 12-month period) and had not yet experienced a triggering event, the birth of her child.

Pereda alleged she was a top performer but that Brookdale began harassing her after they learned of her pregnancy. She claimed Brookdale criticized her job performance and placed her on a performance improvement plan with “unattainable goals.” Moreover, Pereda alleged that Brookdale had given her permission to attend pregnancy-related doctors’ appointments but then subsequently disciplined her for attending those appointments. Brookdale terminated Pereda’s employment when she took time off in September 2009.

Pereda filed suit in the United States Court for the Southern District of Florida, alleging FMLA interference and retaliation. The Southern District held that Brookdale did not interfere with Pereda’s FMLA rights because she was not entitled to leave at the time she requested it, and that because she was not eligible for leave she could not have engaged in “protected activity” under the FMLA. Thus, according to the Southern District, Brookdale could not have retaliated against Pereda.

Pereda appealed to the Eleventh Circuit Court of Appeals. The Eleventh Circuit reversed and found for Pereda on both counts. As part of its decision, the Court resolved a question it had left open in a previous case, Walker v. Elmore County Bd. of Educ., 379 F.3d 1249 (11th Cir. 2004). The Walker court held that the FMLA did not protect a pregnant teacher who requested leave which would begin several days prior to her eligibility.

The Pereda court first found that, because the FMLA requires advance notice of a need for future leave, the FMLA protects employees from interference before a triggering event occurs. The Court reasoned that any other outcome would be illogical and “becom[e] a trap for newer employees and exten[d] to employers a significant exemption from liability.” After examining the various elements of the FMLA regulatory scheme, the court concluded that allowing the district court’s ruling to stand would frustrate the purpose of the FMLA.

The court then examined Pereda’s FMLA retaliation claim. The court held that a pre-eligible request for post-eligible leave is “protected activity” because the FMLA “aims to support both employees in the process of exercising their FMLA rights and employers for the absence of employees on FMLA leave.” Thus, Pereda also had stated a potential claim for FMLA retaliation.

The Court narrowed its finding to state that a pre-eligible discussion of post-eligible FMLA leave is protected activity and stated that an employer could still terminate an employee for legitimate reasons. While this case arose in the Eleventh Circuit, all employers must be mindful of employee eligibility for FMLA leave and evaluate all FMLA requests carefully – especially if the employee will become FMLA-eligible in the future.


Blowing the Whistle - OSHA Issues New Regulations and Revises Its Whistleblower Complaint Procedure


by Lois A. Gruhin

The Occupational Safety and Health Administration (“OSHA”) recently issued an interim final rule amending its whistleblower regulations under the Sarbanes-Oxley Act of 2002 (“SOX”). OSHA published its interim rule in the Federal Register on November 3, 2011, and it became effective upon publication.

The Dodd-Frank Wall Street Reform and Consumer Protection Act amended SOX, making significant changes to SOX whistleblower procedures. The new regulations classify subsidiaries of publicly-traded companies as covered employers. Additionally, the regulations protect employees from retaliation, extend the statute of limitations for retaliation complaints from 90 days to 180 days, provide those who complain with the right to a jury trial in some instances, and restrict the ability of individuals to waive or arbitrate whistleblower claims under SOX. The regulations improve OSHA’s procedures for handling SOX whistleblower complaints and make the procedures consistent with OSHA’s procedures for handling other OSHA-administered statutes.

Another significant change pertains to the filing of whistleblower claims. The new regulations permit oral SOX whistleblower complaints. Upon receipt of an oral complaint OSHA prepares a written complaint. OSHA intended this change to be consistent with the Supreme Court’s recent decision in Kasten v. Saint-Gobain Perf. Plastics Corp., 131 S. Ct. 1325 (2011). OSHA will also now accept a complaint filed in any language. Finally, any person can file a complaint so long as the person has the consent of the affected employee.

Perhaps the most significant change for employers is that OSHA may order a company to provide a SOX whistleblower complainant with the same pay and benefits that he or she received prior to termination of employment, or what is referred to as “economic reinstatement.” This “economic reinstatement” differs from “preliminary reinstatement” in that the whistleblower is not obligated to return to work before the complaint is resolved, as he or she could have been under prior SOX regulations. Furthermore, employers do not have the option to choose between economic reinstatement and actual reinstatement. Instead, the interim rule allows OSHA to make the decision as to whether to allow for economic reinstatement, as opposed to decide on a case-by-case basis. The stated purpose for this rule change is to accommodate situations where the evidence indicates that reinstatement prior to the conclusion of administrative adjudication is inadvisable for some reason, such as where the company demonstrates the complainant to be a security risk.

If you would like further information about the whistleblower provisions of SOX and how they may affect your company, please contact us.


California Dreamin’ – Employers Need to Be Aware of Important Changes to California Employment Law

by Jason Rossiter*

Change is a-comin’ to California’s employment laws. Employers who operate in California should be aware of these important changes.

Gender Expression
Gender expression is now a protected class under California’s Fair Employment & Housing Act (“FEHA”). Gender expression refers to a person’s gender-related appearance and be­­havior, whether or not stereotypically associated with the person’s assigned sex at birth. “Sex” is now defined in several anti-discrimination statutes, including the FEHA, to include gender expression. The redefinition aims to protect the rights of transgender people. With this change, employers must allow employees to appear or dress consistently with his or her gender expression.

Wage-and-Hour Related Changes
The following wage and hour changes, a result of the Wage Theft Protection Act of 2011, went into effect January 1, 2012. The new changes require immediate employer action as employers must keep a signed, written acknowledgement for each employee. A template of the notice and acknowledgement is available via the Department of Industrial Relation’s website:
http://www.dir.ca.gov/dlse/Governor_signs_Wage_Theft_Protection_Act_of_2011.html.
  • Employer must provide all employees with:
    • The rate(s) of pay and basis for such rate(s); allowances including meal or lodging, and the regular payday as designated by the employer.
    • The full legal name of the employer, including any “doing business as” names used by the employer, as well as the address of the employer’s main office and the telephone number of the employer;
    • The name, address, and telephone number of the employer’s workers’ compensation insurance carrier;
    • The new regulations also require the employer to furnish new employees with “any other information the Labor Commissioner deems material and necessary;” and,
    • If the above-mentioned information ever changes, all affected employees must receive notice of the change within seven days of the effective date of the change.

  • If an employer has non-California employees working in the state of California, including temporary or daily employees, these employees are entitled to overtime under California’s laws.

  • Additionally, any agreements between employers and employees who receive commissions must be in writing and signed by the employee in question.
    • This writing must “set forth the method by which the commissions shall be computed and paid,” and the employee must receive a copy of his or her signed writing.
Leave-Related Changes
  • California employees are also now entitled to up to six weeks of paid leave each year to donate organs and bone marrow.
    • This is more expansive than federal and prior California law.
    • The new law, California Labor Code sections 1508 through 1512, applies to employers with 15 or more employees.

  • Pregnancy leave policies in California must also now allow for continuation of medical insurance benefits for pregnancy-related disabilities.
No Credit Checks Allowed
  • Employers may no longer use credit checks in the employment application process.
Misclassification Penalties Increase
Employers who misclassify employees as independent contractors face increased sanctions, including:
  • criminal sanctions;
  •  joint-and-several liability for those who advise employers to misclassify; and,
  • civil penalties of up to $25,000 for each infraction.
Employers with California employees, even those with temporary or daily employees, should take note of these significant changes and ensure they are in full compliance so as to avoid significant penalties.

*Jason Rossiter practices in all areas of labor and employment law and has extensive compliance experience. He is licensed to practice law in California, Pennsylvania and Ohio. For more information about these and other changes to California law contact Zashin & Rich at 216-696-4441.


Indiana Becomes First State in Over Ten Years to Pass “Right-to-Work” Law

by Patrick J. Hoban*

Governor Mitch Daniels signed Indiana’s “Right-to-Work” (“RTW”) law on February 2, 2012 – making Indiana the first state in over a decade to do so.  The law prohibits companies and unions from negotiating a contract requiring non-members to pay fees for union representation.

Indiana’s contentious RTW law came after much-heated debate.  In February, 2011, Democratic representatives left the state for five weeks to deny a quorum prohibiting their Republican colleagues from moving forward on RTW legislation.  However, Governor Daniels succeeded in signing the RTW law, making Indiana the 23rd state with RTW laws on its books.

The National Right to Work Legal Defense Foundation launched a task force to defend the law and announced that it will give free legal advice to workers who wish to exercise their new rights.  Current union members will not be able to stop paying dues immediately as the law only applies to contracts enteredinto after March 14, 2012. 

For or Against Right-to-Work Laws
Supporters of the law emphasize that it will attract business and create jobs pointing to research showing employers favor states with RTW laws. They also lodge ideological arguments against compulsory payment for an unwanted service. Specifically, they argue that forcing employees to pay union dues violates their Constitutional right to freedom of association.

Critics argue that Indiana’s new law will fail to provide the benefits promised by legislators.  In addition, critics believe that RTW laws harm workers by encouraging freeloading. The National Labor Relations Act forces unions to intervene on behalf of members when their employers take illegal action, regardless of whether the member pays dues. Critics fear this costly and time-consuming burden will significantly weaken union power.

What Can We Learn from Oklahoma
Oklahoma was the last state to sign a RTW law.  Proponents of the law expected it to bring new companies to Oklahoma and increase job growth. On the ten-year anniversary of its signing, the National Right to Work Committee celebrated what it claimed was a 12.2% growth in employee compensation since 2001 and a 3.2% increase in private sector employment between 2003 and 2010.

However, the Economic Policy Institute (“Institute”) tells a different story. According to the Institute, the number of new companies coming to Oklahoma has decreased by one-third as has the number of manufacturing jobs. The Oklahoma Department of Commerce admits the latter, but emphasizes that the law has increased productivity. However, the Institute points out that this means fewer workers are producing more, an outcome it does not applaud.

On the National Level
President Barack Obama made his stand on RTW laws clear during a Labor Day Speech last year stating “when I hear of these folks trying to take collective bargaining rights away, trying to pass so-called ‘right-to-work’ laws for private sector workers, that really means the right to work for less and less.”  It comes as no surprise that the Republican presidential candidates have a much different attitude. After the Indiana House passed its RTW law, presidential candidate Ron Paul wrote a congratulatory letter to the National Right to Work Committee stating, “every American owes you a debt of gratitude for your leadership and dedication.” According to his official website, Paul has made passing a national RTW act a “centerpiece” of his campaign. While Paul has been the most enthusiastic RTW supporter, Newt Gingrich, Rick Santorum and Mitt Romney have all spoken approvingly of a national RTW law. 

What Can Indiana Expect
Organizations disagree as to what the citizens of Indiana can expect. The Indiana Chamber of Commerce estimates that “personal income per capita in 2021 [will] be $968 higher, or $3,872 higher for a family of four, than if a RTW law [had] not [been] enacted.” However, The Economic Policy Institute found that in Oklahoma, wages and benefits are approximately $1,500 lower than comparable (union and non-union) workers in non-RTW states.  Additionally, Oklahoma workers are less likely to get health care or retirement benefits. The Institute also warns that RTW laws have no effect on job growth.

Union members went to federal court on February 22, 2012 asking that Indiana's new right-to-work law not be enforced.  This is the first lawsuit and latest conflict over the divisive legislation.  The long-term impact of Indiana’s RTW legislation remains to be seen.

As the map shows, Indiana was the first in the generally union-friendly “Rust Belt” to pass RTW legislation, and the first nationally to do so in a decade.  The highlighted states represent “Right-to-Work” states:




*Patrick J. Hoban, an OSBA Certified Specialist in Labor & Employment law, practices in all areas of labor & employment law and has extensive experience representing management in labor disputes.  For more information about right-to-work laws, please contact Pat at pjh@zrlaw.com or 216-696-4441.


Writing on the Wall: New Jersey Employers Subject to New Posting and Notice Requirements

by Stefanie L. Baker

The New Jersey Department of Labor and Workforce Development (“NJDLWD”) recently issued new regulations concerning employer posting and notice requirements. These changes come on the heels of New Jersey’s 2010 law requiring employers to maintain and report records under state wage, benefit, and tax laws.

These newly-implemented regulations require an employer to “conspicuously post” a notice of its obligations in an accessible place. Employers can access a sample notice online at the NJDLWD’s website (http://lwd.state.nj.us/labor/forms_pdfs/EmployerPosterPacket/MW-400.pdf). Employers can comply either by posting the notice where other employment-related notices are posted or by posting the notice on the employer's Internet/intranet site, provided the employer has an Internet/intranet site for exclusive use by its employees and to which all employees have access. Along with the posting requirement, employers must also provide every employee a copy of the notification.

Additionally, New Jersey employers must provide employees hired after November 7, 2011 with written copies of the notification upon hire, and all current employees should have received written copies by December 7, 2011. New Jersey employers can comply with the notice requirement by sending copies of the notice via e-mail.

The required postings address employers’ obligation to maintain payroll records, temporary disability insurance records, workers’ compensation records, and Employer’s Quarterly Reports pursuant to the New Jersey Gross Income Tax Act. New Jersey employers should assess whether they are in compliance with these new regulations. Failure to comply with the posting and distribution requirements could lead to a fine of up to $1,000, as well as criminal penalties.


Z&R Shorts

George S. Crisci will present “Social Media in the Workplace” on May 17, 2012, at the Ohio State Bar Association and NLRB Region 8 Annual Labor Law Seminar beginning at 9 AM at Ritz Carlton Hotel in Cleveland, Ohio.  To register, go to www.ohiobar.org.

Monday, May 23, 2011

How many days has it been without an accident? The Department of Labor Launches its OSHA Recordkeeping Advisor

*By Scott Coghlan
 
The Department of Labor recently announced a new web based tool to help employers understand their responsibilities to report and record work-related injuries and illnesses under OSHA regulations.
The OSHA Recordkeeping Advisor helps employers determine quickly whether an injury or illness is work-related or if an exception applies, whether a work-related injury or illness needs to be recorded, and which provisions of the regulations apply when recording a work-related injury or illness. To help employers in making these determinations, the OSHA Recordkeeping Advisor relies on the employers’ responses to a series of preset questions.

The OSHA Recordkeeping Advisor is straightforward and is intended to assist employers in understanding their recordkeeping requirements. While an excellent tool, it is not all encompassing, and should not be considered a substitute for the OSHA Recordkeeping Rules 29 CFR 1904, the OSHA Recordkeeping Handbook, the OSHA Recordkeeping Related Letters of Interpretation or legal advice regarding the same. These documents as well as the new OSHA Recordkeeping Advisor can be found at www.dol.gov/elaws/OSHARecordkeeping.html. If you any questions relative OSHA recordkeeping requirements and how they apply to your company, please contact us.

*Scott Coghlan, the chair of the firms’ Workers’ Compensation Group, has extensive experience in all aspects of safety and health matters and workers’ compensation law.  For more information about OSHA compliance, please contact Scott at 216.696.4441 or sc@zrlaw.com.

Thursday, April 30, 2009

What To Do With the Piggy Flu

*By Pat J. Hoban

Zashin & Rich Co., L.P.A. has received an increasing number of calls from employers asking how to manage the potential for "swine flu" (also referred to as the "N1H1 virus") outbreaks in the workplace. While the effects of the virus have been limited thus far, employers should take steps to limit the effect on their employees and their businesses. This alert provides information designed to assist employers in answering employees' questions, preparing the workplace, and maintaining operations should the current outbreak become more widespread.

 

Resources:

The Occupational Safety and Health Administration ("OSHA") and the Center for Disease Control ("CDC") websites have a wealth of information concerning swine flu. This information is updated regularly and includes specific guidance for employers.
  1. Employers should review regularly OSHA (http://www.osha.gov) and the CDC's (http://www.cdc.gov) websites for updates on the situation.

  2. OSHA's website includes lengthy guidance on preparing your workplace for an influenza pandemic at: http://www.osha.gov/Publications/influenza_pandemic.html.

  3. The CDC website links to Pandemicflu.gov which features guidance on workplace planning at:
    http://www.pandemicflu.gov/plan/workplaceplanning/index.html, which includes checklists for developing your company's health and operational response plans.

  4. The CDC has also provided specific guidance for travel at: http://wwwn.cdc.gov/travel/contentSwineFluUS.aspx.

General Precautionary Steps for Employers:

The resources listed above contain a great deal of information about swine flu transmission, symptoms, and ways to reduce the chance of contracting the virus as well as steps employers should take to maintain operations in the event of a wider outbreak. The following is a summary of some of the more basic steps every employer should consider:
  1. Communicate in writing with employees about the situation, notify them where they can obtain more news and information, and state that the Company is committed to keeping the workplace as healthy and safe as possible. Employers whose employees are represented by a union should contact the union representatives (e.g., directly or through a labor management or plant safety committees) to discuss the Company's plans to address the situation.
  2. Request that employees report immediately to their supervisors if they experience any flu symptoms and require that supervisors notify Human Resources immediately upon any report of flu symptoms.
  3. Review the company's Family and Medical Leave Act and other leave policies and encourage employees to stay at home if they experience any flu symptoms.
  4. Remind employees of the need to maintain a sanitary workplace, to practice good hygiene and to wash hands frequently.
  5. Require employees who believe that they contracted swine flu at work or because of work to complete a First Report of Accident form for workers' compensation purposes.
  6. Ensure that any Company representative does not disclose confidential medical information about any employee.
  7. Consider wage and hour issues if an exempt employee cannot come to work for any portion of a workweek due to swine flu.
  8. Document any actions taken to respond to any actual report of swine flu.
  9. Document any request for any workplace adjustment as a result of an employee who suffers from the swine flu.
  10. Communicate with any cleaning services about additional steps to sanitize the workplace.
  11. Discontinue nonessential travel to locations the CDC identifies as having high illness transmission rates (e.g., Mexico). http://wwwn.cdc.gov/travel/contentSwineFluMexico.aspx
  12. Encourage employees to contact the company's Employee Assistance Program, if any, to deal with any stress that might result from the swine flu.
Information, communication and planning are the best ways for employers to best prepare their employees and their businesses for an expanded swine flu outbreak. If you have any specific questions regarding swine flu information and workplace preparedness, please contact Pat Hoban at 216.696.4441 (pjh@zrlaw.com).