With June gloom bearing down on us here in Southern California, it may not feel like it outside, but July is right around the corner.  As written about previously here, many local city and county minimum wage requirements will increase on July 1, 2019.  California employers should review a few items to ensure the increase in minimum wage does not catch them off guard.  Here are five reminders to start the process of ensuring compliance with the July 1 deadline:

1. Ensure the company understands which city and county they are located within.

Many of the cities and counties provide resources to help companies determine if they are located within the city’s or county’s jurisdiction.  For example, the City of Los Angeles provides this resource.

2. Ensure employees who travel and work in other cities and counties are being paid the appropriate minimum wage.

Many of the local ordinances that require a higher minimum wage than the state minimum wage set forth when the city or county law will cover an employee who works within its jurisdiction.  For examples, Santa Monica and the City of Los Angeles assert jurisdiction over employees who work within their jurisdiction for two hours a week:

  • Santa Monica:  Law applies to any employee working a minimum of two hours within Santa Monica in a given week (even if employer is located outside of Santa Monica).
  • City of Los Angeles: Ordinance applies to “[a]n employee … who performs at least two hours of work in a particular week within the City of Los Angeles….”

Employers should review the various jurisdictions that their employees may travel into to ensure compliance with those requirements.

3.Ensure pay stubs reflect the increased minimum wage.

The DIR provides an example of a pay stub for an hourly employee the meets all of the required items under Labor Code section 226:

 

Ensure that all employees earning minimum wage who are covered by an local minimum wage increase on July 1, 2019 are updated to reflect the increased minimum wage amounts.

4. Update posters to ensure the compliant posters are being used in the workplace.

Many local cities and counties have issued updated posters to reflect the increased minimum wage as of July 1, 2019.  Employers should review to ensure they are using the most current versions of the posters as of July 1, 2019.  Here are a few links to cities and county posters in Southern California:

County of Los Angeles required notices:

City of Los Angeles required notices:

Pasadena’s required notices:

Santa Monica’s required notices:

  • July 1, 2019 Legal notice (English) (Spanish) (note that employers in Santa Monica are required to post both English and Spanish notices, even if they do not employ any Spanish speaking employees.
  • Posters in other languages can be downloaded here.

Malibu’s required notice:

City of San Diego’s required notices:

5. Update notices to employee who are hired on or after July 1, 2019.

Notices to Employee required under Labor Code section 2810.5 must be issued to all nonexempt employees when they start work.  The wage information section must reflect the higher minimum wage for minimum wage workers as of July 1, 2019.  Accordingly, the overtime rates of pay section of the Notice must also be updated to reflect the higher rates as a result of the higher minimum wage requirements.