On April 12th at 1:00 pm, we will be doing one of our most-attended webinars this year, ” Workplace Violence/Active Shooter Training – What Employers Need to Know”. As you already know, this is a very hot topic and highly litigious area for all employers. For more details, see our website at www.strattonagency.com of contact an HR Representative at 925-556-4404 for more details.
Effective January 1, 2017, Cal/OSHA will be utilizing a broader definition of “Repeat” violation under California’s Health and Safety Code. This is significant for California employers because if Cal/OSHA finds a Repeat violation, the employer could initially be subject to a penalty of up to $70,000, and up to $124,709 or more when Cal/OSHA updates its penalties as required by federal OSHA. According to OSHA, the purpose of the greater penalty for Repeat violations is to encourage an employer’s ongoing compliance with safety and health standards at all of its locations without requiring OSHA to engage in separate compliance actions at each location. Because Cal/OSHA has always previously limited Repeat violations to a single worksite reoccurrence, and because of the forthcoming increased penalty structure, California employers will need to develop a more strategic response to any citations they receive.
In its 2013 Federal Annual Monitoring and Evaluation (FAME) Report, federal OSHA found that California’s enforcement of Repeat violations was lower than the federal average and noted that the policy used by the state was different and less protective than that applied by federal law. As a result, Cal/OSHA was directed to amend California Code of Regulations Title 8, Section 334(d), to be consistent with the definition of a Repeat violation as used by Federal OSHA.
Currently, a Repeat violation is defined in section 334(d), as a violation where an employer has corrected, or indicated correction of, an earlier violation for which a citation was issued and, upon a subsequent inspection within three years, Cal/OSHA finds that the employer has recommitted the same violation. For employers with fixed establishments, section 334(d) currently limits Cal/OSHA’s authority to issue a repeat citation to the cited establishment, which means that both the underlying and the subsequent violation must have occurred at the same work site or address.
Now, however, California employers will be subject to a much broader definition of Repeat violation. Specifically, Cal/OSHA amended section 334(d) by:
- Expanding the “look back” period of a Repeat violation from three years to five years.
- Defining a Repeat violation as a substantially similar violation.
- Increasing the geographic scope of a Repeat violation to any violation in the state.
Cal/OSHA Will Now Look Back Five Years
The current three-year look-back period of a Repeat violation begins to run on the date of the conduct giving rise to the violation. But, if the employer appeals the citation, the appeal prevents the citation from becoming final, and a final citation is necessary for a Repeat violation to be found. As the three-year clock runs from the date of the conduct, the employer could minimize its chance of a Repeat violation by appealing every citation issued.
Cal/OSHA’s amendment eliminated an employer’s incentive to appeal solely to shorten or exhaust the look-back period. Now, the starting time for calculating the period begins at either:
- the date of the final order affirming the existence of a previous violation cited in the underlying citation;
- the date on which the underlying citation becomes final by operation of law; or
- the date of final abatement of the violation cited in the underlying citation.
Cal/OSHA also expanded the window of time for a Repeat violation from three years to five years, which is a policy change that federal OSHA made in 2010.1
Cal/OSHA Will Now Consider Substantially Similar Violations
Cal/OSHA currently defines a Repeat violation as occurring when the employer has corrected, or indicated correction of an earlier violation, for which a citation was issued, and upon a later inspection is found to have committed the same violation again.
Cal/OSHA amended the rule to broadly allow it to find a Repeat violation for a violation of a “substantially similar” regulatory requirement. This change places Cal/OSHA directly in line with federal OSHA. The “substantially similar” standard is the language used by federal OSHA but is not officially defined by Cal/OSHA. Federal OSHA also does not have a regulatory definition of “substantially similar” but the term has been interpreted in policy documentation and numerous citation appeal decisions. As the term is undefined, employers will have some opportunity to influence the interpretation of what constitutes substantially similar violations supporting a Repeat violation in California, but this may be one area where the state adopts the federal interpretation. The greater scope naturally increases the frequency at which a Repeat violation could be issued.
Cal/OSHA Will Now Consider Statewide Violations
The current rule defining the geographic scope of Repeat violations is that the later citation must involve the same factory, store, or other fixed establishment that was previously cited. But, for field sanitation standards, a Repeat violation is any subsequent violation state-wide, on the theory that farm labor contractors work up and down the state during a short span of time and, thus, violations at different sites in California are akin to Repeat violations.
Cal/OSHA eliminated the difference between field sanitation and other industries and removed the geographical restrictions that currently limit a Repeat violation to a specific facility or store. In other words, in determining whether to cite the employer for a Repeat violation, Cal/OSHA will consider any violation in the state as opposed to violations at a specific location. Thus, for example, if Cal/OSHA finds a violation at a facility in Los Angeles, and if the employer has facilities in Sacramento and San Francisco, the agency will determine whether citations for substantially similar violations were issued at the facilities in those two cities.
Implications for Employers
Starting in 2017, California employers can no longer focus solely on the financial implications of settling a citation or contesting it. Employers will have to be more strategic in their response. Because the Repeat classification and increased penalties are not directly limited to Serious violations, employers will even have to consider their acceptance or appeal of General and Regulatory citations.
Employers can initially focus even more attention on preventing workplace safety violations through comprehensive programs. However, if an employer receives a citation, it should carefully evaluate whether simply paying the citation is the best strategy and also should immediately determine whether it is in compliance with other standards that are “substantially similar” to the one for which it was cited at all of its California facilities. This increased focus will raise the cost of abatement for employers that do decide to accept a citation because they will need to ensure abatement at all of their locations to avoid future Repeat violations with their substantial penalties. Overall, this change will undoubtedly lead to more litigation over Cal/OSHA citations as employers will need to manage their citation history to avoid future Repeat violations occurring over a five-year period.
National research indicates that health care workers are at a substantially higher risk of workplace violence than the average worker in another industry. According to the federal Occupational Safety and Health Administration (OSHA), from 2002 to 2013, the rate of serious workplace violence incidents (those requiring days off for an injured worker to recuperate) was more than four times greater in healthcare than in private industry on average.1 Patients are the largest source of violence in healthcare settings, followed by visitors or co-workers, and surveys show that many incidents go unreported.
On October 21, 2016, the California Occupational Safety and Health Standards Board (Standards Board) unanimously passed a new General Industry Safety Order entitled “Workplace Violence Prevention in Health Care” (Standard).2 The Office of Administrative Law approved the Standard on December 8, 2016. The Standard is codified at Section 3342 of Title 8 of the California Code of Regulations.
Although Senate Bill 1299 only required a standard for hospitals, the Standards Board went further and the standard applies to any “health facility,” which is defined very broadly to mean “any facility, place, or building that is organized, maintained, and operated for the diagnosis, care, prevention, or treatment of human illness, physical or mental, including convalescence and rehabilitation and including care during and after pregnancy, or for any one or more of these purposes, for one or more persons, to which the persons are admitted for a 24-hour stay or longer.”3
The Standard also applies to home health care and home-based hospices, emergency medical services and medical transports, drug treatment programs and outpatient medical services to those incarcerated in correctional and detention settings. The Standard will not apply to certain state-run health facilities.
The Standard Broadly Defines “Workplace Violence”
“Workplace violence” means any act of violence or threat of violence that occurs at the work site. The term workplace violence shall not include lawful acts of self-defense or defense of others. Workplace violence includes the following:
1. The threat or use of physical force against an employee that results in, or has a high likelihood of resulting in, injury, psychological trauma, or stress, regardless of whether the employee sustains an injury;
2. An incident involving the threat or use of a firearm or other dangerous weapon, including the use of common objects as weapons, regardless of whether the employee sustains an injury;
3. Four workplace violence types:
- “Type 1 violence” means workplace violence committed by a person who has no legitimate business at the work site, and includes violent acts by anyone who enters the workplace with the intent to commit a crime.
- “Type 2 violence” means workplace violence directed at employees by customers, clients, patients, students, inmates, or visitors or other individuals accompanying a patient.
- “Type 3 violence” means workplace violence against an employee by a present or former employee, supervisor, or manager.
- “Type 4 violence” means workplace violence committed in the workplace by someone who does not work there, but has or is known to have had a personal relationship with an employee.
Workplace Violence Prevention Plan
Healthcare employers covered by the Standard are now required to establish, implement and maintain an effective workplace violence prevention plan (Plan), which must be in effect at all times and in every unit, service or operation. The Plan must be in writing, be specific to the hazards and corrective measures for the unit, service, or operation, and be available to employees at all times. The written Plan may be incorporated into the employer’s written IIPP or maintained as a separate document.
The Plan must include the following:
- Names or job titles of the persons responsible for implementing the Plan;
- Effective procedures to obtain the active involvement of employees and their representatives in developing, implementing, and reviewing the Plan, including their participation in identifying, evaluating, and correcting workplace violence hazards, designing and implementing training, and reporting and investigating workplace violence incidents;
- Methods the employer will use to coordinate implementation of the Plan with other employers whose employees work in the same health care facility, service, or operation, to ensure that those employers and employees understand their respective roles as provided in the Plan;
- Effective procedures for obtaining assistance from the appropriate law enforcement agency during all work shifts;
- Effective procedures for the employer to accept and respond to reports of workplace violence and to prohibit retaliation against an employee who makes such a report;
- Procedures to ensure that supervisory and non-supervisory employees comply with the Plan;
- Procedures to communicate with employees regarding workplace violence matters;
- Procedures to develop and provide training to employees that addresses workplace violence risks employees are reasonably anticipated to encounter on the job;
- Assessment procedures to identify and evaluate environmental and community-based risk factors for each facility, unit, service, or operation, which shall include a review of all workplace violence incidents that occurred in the facility, service, or operation within the previous year, whether or not an injury occurred;
- Procedures to identify and evaluate patient-specific risk factors and assess visitors or other persons who are not employees;
- Procedures to correct workplace violence hazards in a timely manner; and
- Procedures for post-incident response and investigation.
The Standard describes in great detail the procedures that must be addressed within each of these topics.
At least annually, the employer is required to review the effectiveness of the Plan and correct any problems. The annual review must include employees and their representatives and address the employees’ respective work areas, services and operations. The Standard sets out numerous additional items the employer must consider when reviewing the Plan, including, among other things, staffing, sufficiency of security systems and job design and equipment.
Violent Incident Log
Healthcare employers will be required to record in a “violent incident log” every incident, post-incident response, and workplace violence injury investigation with descriptive details. The employer must review the log as part of its annual review of the Plan.
The log must contain, at a minimum, the following items:
- The date, time, specific location, and department of the incident;
- A detailed description of the incident;
- A classification of who committed the violence;
- A classification of circumstances at the time of the incident;
- A classification of where the incident occurred;
- The type of incident;
- The consequences of the incident; and
- Contact and other information about the person completing the log.
As with the Plan, the Standard describes in the detail the specific information that must be included for each item.
The Standard requires healthcare employers to provide training to employees designed to address the workplace violence risks that employees are reasonably anticipated to encounter in their jobs. The employer must have an effective procedure for obtaining the active involvement of employees and their representatives in developing training curricula and training materials, participating in training sessions, and reviewing and revising the training program.
The Standard requires that training be conducted at various times, including:
- when the Plan is first established and when an employee is newly hired or newly assigned to perform duties for which the training was not previously provided;
- when new equipment or work practices are introduced; and
- when a new or previously unrecognized workplace violence hazard has been identified.
The Standard requires the initial training to address the workplace violence hazards identified in the facility, unit, service or operation, and the corrective measures the employer has implemented. The initial training also must include:
- An explanation of the employer’s Plan, including the employer’s hazard identification and evaluation procedures, general and personal safety measures the employer has implemented, how the employee may communicate concerns about workplace violence without fear of reprisal, how the employer will address workplace violence incidents, and how the employee can participate in reviewing and revising the Plan;
- How to recognize the potential for violence, factors contributing to the escalation of violence and how to counteract them, and when and how to seek assistance to prevent or respond to violence;
- Strategies to avoid physical harm;
- How to recognize alerts, alarms, or other warnings about emergency conditions such as mass casualty threats and how to use identified escape routes or locations for sheltering, as applicable;
- The role of private security personnel, if any;
- How to report violent incidents to law enforcement;
- Any resources available to employees for coping with incidents of violence, including, but not limited to, critical incident stress debriefing or employee assistance programs; and
- An opportunity for interactive questions and answers with a person knowledgeable about the employer’s workplace violence prevention plan.
Annual refresher training also is required for employees performing patient contact activities as well as their supervisors.
In addition, employees assigned to respond to alarms or other notifications of violent incidents or whose assignments involve confronting or controlling persons exhibiting aggressive or violent behavior must be provided training on numerous topics prior to initial assignment and at least annually thereafter, including strategies to prevent physical harm, aggression violence predicting factors and characteristics of aggressive and violent patients and victims.
Reporting Requirements for Certain Hospitals
In addition to the above requirements, the Standard requires general acute care hospitals, acute psychiatric hospitals, and special hospitals to report to Cal/OSHA any incident involving either of the following:
- The use of physical force against an employee by a patient or a person accompanying a patient that results in, or has a high likelihood of resulting in, injury, psychological trauma, or stress, regardless of whether the employee sustains an injury (as that term is defined in Cal/OSHA’s regulations requiring the reporting of other types of injuries or illnesses).
- An incident involving the use of a firearm or other dangerous weapon, regardless of whether an employee sustains an injury.
All reports must be made within 72 hours, except that the report must be made within 24 hours if the incident:
- results in a fatality or an injury that requires inpatient hospitalization for at least 24 hours for other than medial observation or in which an employee suffers a loss of a limb or suffers any serious degree of permanent disfigurement;
- involves the use of a firearm or other dangerous weapon; or
- presents an urgent or emergent threat to the welfare, health, or safety of hospital personnel, which means that hospital personnel are exposed to a realistic possibility of death or serious physical harm.
The Standard describes the information that must be included in the report. Cal/OSHA will implement an online system for employers to report the information. These reports do not relieve the healthcare employer from making reports that may be required by other Cal/OSHA regulations. Employers can expect that these reports will result in a significant number of new non-formal and on-site inspections.
The Standard will require healthcare employers to maintain various records, including records of workplace violence hazard identification, evaluation, and correction, training records, and records of violent incidents. Records must be made available to employees and their representatives, as well as Cal/OSHA, upon request.
Next Steps for Employers
The Standard is effective on April 1, 2017, which means that California healthcare employers have less than four months to get in full compliance with these onerous requirements. Cal/OSHA’s Standard is a first of its kind at the federal and state level, although Federal OSHA is proceeding with a rulemaking and will hold a public hearing on January 10, 2017.
At a minimum, employers covered by the Standard should immediately consider:
- Gathering records of all incidents of workplace violence (with or without injury) from the previous year;
- Reviewing all existing policies, programs, and training addressing elements of workplace violence prevention;
- Conducting the required assessments for each workplace;
- Drafting and implementing a new written Workplace Violence Prevention Plan, which addresses the numerous topics enumerated in the Standard;
- Creating training programs for all employees that effectively advise of any workplace violence risks that may arise in a healthcare environment and in the employees’ particular work area; and
- Establishing a record retention program for training and any incident that could be viewed as an incident of workplace violence, even if no injury resulted.
Employers should also review the significant privacy issues raised by the Standard, and with the advice of privacy attorneys, develop an appropriate policy addressing concerns which may arise in keeping records, reporting incidents to Cal-OSHA, and handling inspections of this Standard.
Should you have any questions, please contact your representative at HR Ideas.
Around the holiday season, a lot of employers want to celebrate in some form and fashion with their employees. Most employers don’t realize their potential liability. Potential liability is almost always there, but some simple recommendations can go along with in limiting their liability including:
- Employers should consider hosting a holiday event outside of the traditional holiday party. A growing trend among many companies is to host corporate luncheons or volunteer events that benefit non-profit organizations. These alternatives can reduce the employer’s potential liability with regard to alcohol-related incidents and harassment complaints.
- Likewise, instead of an employee holiday gift exchange, employers can sponsor a fundraising event for a local charity. Doing so decreases the potential for sexual harassment complaints associated with office gift exchanges. In addition, employers should avoid games, decorations, or other sexually charged traditions that could expose the company to liability.
- As another option to help avoid incidents of sexual harassment, employers may want to consider hosting a holiday party that allows employees to invite their significant other, a plus one, or even children.
- When planning holiday gatherings, employers should select a name for the event that is non-religious to avoid complaints of religious discrimination. Employers should also inform employees that participation in holiday gatherings, be it a corporate party or volunteer event, is voluntary.
- When planning holiday soirees, employers should ensure that employees and guests do not consume excessive amounts of alcohol. Thus, it is strongly recommended that employers supply guests with drink tickets (generally two tickets are standard) or have a cash bar. Likewise, employers are strongly recommended to do the following: (1) close the bar one hour prior to the end of the event, (2) designate supervisors who will not drink at the event to monitor alcohol consumption of employees and guests, (3) and have a system in place to get intoxicated employees and guest(s) home safely, i.e., Uber, Lyft, or other local transportation options.
- Prior to the corporate holiday event, employers should review their policies and procedures regarding discrimination and harassment and remind employees, through a memorandum, that all company policies will be in effect during the holiday party.
If you need any assistance or have any questions, please contact you HR Ideas Representative.
Much has been written in the comment section of The Shooter’s Log regarding state versus federal laws. So, this article should provide for lively debate. The Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF) has issued a clarification to language on ATF Form 4473. The clarification covers the use of marijuana in states that have legalized it for recreational or medicinal use versus federal law. In other words, it may be legal in some states, but it is still unlawful federally.
On the revised ATF Form 4473, Question 11e reads, “Are you an unlawful user of, or addicted to, marijuana or any other depressant, stimulant, narcotic drug or any other controlled substance?” This caused confusion for some in that marijuana has been “legalized” in some states.
However, the ATF is focused on federal, not state, law. To avoid further confusion, the ATF has added the following clarification to question 11e, “The use or possession of marijuana remains unlawful under Federal law regardless of whether it has been legalized or decriminalized for medicinal or recreational purposes in the state where you reside.”
The revised ATF Form 4473 will be mandatory for use starting January 16, 2017.
The ATF’s clarification follows a ruling issued by the U.S. Court of Appeals for the Ninth Circuit last August. In that decision, the court ruled marijuana card holders at the state (Nevada) level are barred from gun purchases .
On November 17, 2016, OSHA issued a f inal rule revising and updating its general industry Walking-Working Surfaces standards specific to slip, trip, and fall hazards. The final rule includes revised and new provisions addressing fixed ladders, rope descent systems, and fall protection systems. The rule also establishes requirements on the design, performance and use of personal fall protection systems in general industry. In addition, employers must now train employees on identifying and minimizing fall hazards, using fall protection systems and maintaining, inspecting and storing fall protection equipment.
The final rule allows employers to select the fall protection system that works best for their environment, instead of requiring the use of guardrail systems, which the current rule mandates. Employers now can choose from a range of accepted options, including personal fall arrest, safety new system, ladder safety systems, travel restraint and work position systems. OSHA has permitted the use of personal fall protection systems in construction since 1994 and the final rule adopts similar requirements for general industry.
The final rule codifies a 1991 OSHA memorandum that permits employers to use Rope Descent Systems (RDS) and adds a 300-foot height limit for their use. It also requires building owners to affirm in writing that permanent building anchorages used for RDS have been tested, certified, and maintained as capable of supporting 5,000 pounds for each worker attached.
The final rule also requires that ladders be capable of supporting their maximum intended load and that mobile ladder stands and platforms be capable of supporting four times their maximum intended load. Moreover, each ladder must be inspected before initial use in a work shift to identify defects that could cause injury.
For fixed ladders that extend more than 24 feet, the rule phases in ladder safety or personal fall arrest systems and phases out the use of cages or wells. For portal ladders, employers must ensure that rungs and steps are slip resistant; portable ladders used on slippery surfaces are secured and stabilized; portable ladders are not moved, shifted, or extended while a worker is on them; top steps and caps of stepladders are not used as steps; ladders are not fastened together to provide added length unless designed for such use; and ladders are not placed on boxes, barrels, or other unstable bases to obtain added height.
OSHA drew from requirements in the national consensus standards in crafting the new rule, including ANSI/ASSE A1264.1–2007, Safety Requirements for Workplace Walking/Working Surfaces and Their Access; Workplace, Floor, Wall and Roof Openings; Stairs and Guardrail Systems; ANSI/ASSE Z359.1–2007, Safety Requirements for Personal Fall Arrest Systems, Subsystems and Components; and ANSI/IWCA I–14.1–2001, Window Cleaning Safety Standard.
OSHA anticipates that the changes provided in the final rule will prevent 29 fatalities and 5,842 lost-workday injuries annually.
The final rule becomes effective on January 17, 2017. Some requirements in the new rule have compliance dates after the effective date including:
- Ensuring exposed workers are trained on fall hazards and the use of fall protection equipment (6 months),
- Inspecting and certifying permanent anchorages for rope descent systems (1 year),
- Installing personal fall arrest or ladder safety systems on new fixed ladders over 24 feet and on replacement ladders/ladder sections, including fixed ladders on outdoor advertising structures (2 years),
- Ensuring existing fixed ladders over 24 feet, including those on outdoor advertising structures, are equipped with a cage, well, personal fall arrest system, or ladder safety system (2 years), and
- Replacing cages and wells (used as fall protection) with ladder safety or personal fall arrest systems on all fixed ladders over 24 feet (20 years).
If you should have any questions, please contact your HR Ideas Safety Representative.
An amendment to California law expands state prohibitions against “unfair immigration-related practices” related to the hiring of foreign nationals. SB-1001 goes into effective on January 1, 2017.
According to the preamble of the bill, it is “unlawful for an employer to request more or different documents than are required under federal law, to refuse to honor documents tendered that on their face reasonably appear to be genuine, to refuse to honor documents or work authorization based upon the specific status or term of status that accompanies the authorization to work, or to reinvestigate or reverify an incumbent employee’s authorization to work, as specified.” Moreover, the statute gives aggrieved employees and applicants for employment a cause of action with the California Labor Commission’s Office.
SB-1001 expands existing prohibitions against unfair immigration-related practices under California law. First, the new law protects applicants for employment in addition to employees, thereby expanding punishable hiring practices beyond retaliatory acts against employees for attempting to exercise legal rights. Now, document abuse at the point of application for hire is included in punishable activity.
Second, SB-1001 prohibits employers from refusing to honor documents based on specific status or term of status and from attempting to reinvestigate or reverify the work status of a current employee unless by request of the federal government.
Finally, it expands enforcement by creating a new state remedy. Under the new law, aggrieved individuals can file a complaint with the California Labor Commission’s Office, which can penalize employers up to $10,000 per violation. By creating a state remedy, SB-1001 expands California’s previous system of enforcement through the U.S. Department of Justice (OSC) and federal appeals process, which the California Senate called “an overly cumbersome process.”
California employers should be alert of the new restrictions in conducting hiring procedures, including I-9 and E-Verify, and understand that document abuse is no longer limited to instances of “retaliation” against incumbent employees.
The California Assembly Committee on Labor Employment offered the following examples of employer document abuse:
Demanding to see a worker’s U.S. passport;
Asking for an Employment Authorization Document when the worker has already shown a state ID and “unrestricted” Social Security card;
Refusing to accept an EAD because it contains a future expiration date;
Asking to reverify work documents of an employee who presented a Green Card at the point of hire; and
Demanding to see an employee’s renewed driver’s license because the previous license used for the I-9 expired.
Hence, employers should cautiously avoid making document requests or other activities considered “unfair immigration-related practices” under the statute when dealing with new applicants as well as current employees.
If you’re planning to spend any time out in the extreme heat, even just resting, you’re going to want to drink one 16-ounce bottle of water per hour to keep your body hydrated. You should start hydrating well before you spend time in the sun.
That means if you’re out during the hottest parts of the day, between 10 a.m. and 7 p.m., you want to put down nine 16 oz. bottles total!
And if that time is spent outside working, double that number. Be ready to drink two 16-ounce bottles per hour. That’s the amount the Occupational Safety and Health Administration recommends to outdoor workers in extreme heat.
Certain medical conditions, physical conditioning, and age may increase those totals. Some drugs you may be taking may negatively affect your tolerance to heat and your body’s natural cooling system.
Stay away from caffeinated and alcoholic drinks!
Sick leave laws continue to complicate employer’s administration, especially for those with multiple businesses in different cities or states. Last July, California passed a new sick leave law. Today, there are seven (7) states that have their own sick leave law. If that’s not enough, seven (7) ciities in California have passed their own laws including San Francisco, Oakland, Emeryville, Pittsburg, Los Angeles, Santa Monica and San Diego. The laws continues to change and challenge employers. It is expected that California will continue to change this law. Remember, you must comply with both the City and State laws. This means you need to review both laws carefully and create a combined policy built on what is most favorable to the employee. Once the policy is updated, it must be distributed to all your employees, post the new law, and train your management team. We see our employers getting in trouble because their managers are often harassing their employees when they need to take time off under sick leave.
HRI can help you with the policy and training! Just contact us at 925.556.4404 or [email protected]