Today’s Tip: Beware of Multi-State Issues (and Rudolf is a girl?!)

Neil deGrasse Tyson broke the news last week that Santa’s reindeer must be female, since they still have their antlers in the winter. Mind blown: Rudolf is a girl. #girlpower

It seems like should have figured that out earlier. Sometimes things are not as they seem. So let’s play some reindeer games.

Assessing independent contractors status isn’t always as it seems either. Do you pass the IRS Test? Congratulations, but that tells you nothing about whether your relationship meets state law tests. Did you win an unemployment claim on the basis that your contractor was not your employee? Congratulations, but that tells you nothing about whether your relationship has contractor status under federal wage and hour law.

To determine whether an independent contractor relationship is legitimate requires you to look at multiple tests across multiple laws across multiple jurisdictions.

Companies that retain contractors across multiple states should pay particular attention to the differences among multiple states and across multiple laws. The same relationship can be deemed employment under one test and independent contractor under another.

For example, in my home state of Ohio, the analysis of whether a worker is an independent contractor or an employee is subject to a long list of competing legal standards:

  1. Federal Income Tax: Right to Control (IRS factors)
  2. Ohio Income Tax:  Follows IRS
  3. ERISA, ADA, Title VII, ADEA: Right to Control (Darden Test)
  4. Affordable Care Act: Right to Control (Treasury Regs.)
  5. FLSA: Economic Realities Test
  6. NLRA: multi-factor hybrid/right to control test
  7. OH Unemployment (ODJFS): IRS old 20-Factor Test
  8. OH Workers Comp / Construction: Need 10 of 20 old IRS Factors
  9. OH Workers Comp / Other: Ohio Right to Control Test
  10. OH Discrimination (RC 4112): Ohio Right to Control Test

The complexity is similar in every state.  In Illinois, the list is about as long, but with different state law tests and standards:

  1. Federal Tax: Right to Control (IRS factors)
  2. ERISA, ADA, Title VII, ADEA: Right to Control (Darden Test)
  3. Affordable Care Act: Right to Control (Treasury Regs.)
  4. FLSA: Economic Realities Test
  5. NLRA: multi-factor hybrid/right to control test
  6. IL Unemployment: ABC Test
  7. IL Wage Payment & Collection Act: ABC Test
  8. IL Workers Compensation: Various factors, including control, relationship to company’s business
  9. But, if Construction, then Employee Classification Act:
    – Presumption is employee,
    – Then apply ABC Test,
    – Then apply 12-factor test to prove sole proprietorship or partnership is IC

And there are 48 more states just like these (but different).

So bottom line: Just like you can’t make assumptions about your reindeer’s gender based on its name, you can’t make assumptions about your contractor’s status based on what you call the relationship. You’ve gotta check the antlers — or the appropriate law.

© 2020 Todd Lebowitz, posted on WhoIsMyEmployee.com, Exploring Issues of Independent Contractor Misclassification and Joint Employment. All rights reserved.

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Discomfit a Bear? Here’s a Quick Tip To Improve Your Independent Contractor Agreements

In this story from the Illustrated Police News, 1877, we see the courageous exploits of a young lady from Runcorn, England, skillfully discomfiting a bear with her parasol. Now, I question whether this really happened as captioned. The caption says she punched the bear in the eye with her parasol, but this artist’s rendering depicts more of a body blow, so I’m not sure which to believe. But either way, as you can see, the bear was discomfited and this atypical encounter ended well.

In this instance, a parasol was more than a mere umbrella. It served as a defensive weapon.

The lesson here is that objects we take for granted can be used as a defensive weapon with some proper planning. That includes your independent contractor agreements.

Independent contractor agreements should not be generic, off-the-shelf documents. Every agreement is an opportunity to build your defense against a claim of independent contractor misclassification.

Think about all of the factors that go into determining whether someone is an employee or an independent contractor. For a refresher, you can review some earlier posts on Right to Control Tests and Economic Realities Tests. Also here.

On factors where are you do not exert control and do not need to exert control, put that in the contract. Put in the contract that the contractor controls these factors and you have no right to control them.

For example, do you care what time of day the contractor works? Do you care if the contractor retains helpers? Do you care whose tools the contractor uses?

If not, put that in the contract: The contractor decides when to work, whether to hire helpers, and what tools to use. There are dozens more factors like these to consider. The point is to customize your agreement so that it is defensive weapon to help fend off a claim.

Then go a step further and put in the contract that you have no right to control these decisions. Remember, the Right to Control tests generally focus on whether you have the right to control something, even if you don’t actually exercise that right.

If you use your agreement to memorialize the good facts—those that support independent contractor status—then you can turn that agreement into a defensive weapon.

The agreement might not help if confronted with a bear in Victorian England (“here, read this contract while I run!”), but it may help to discomfit an independent contractor misclassification lawsuit.

© 2020 Todd Lebowitz, posted on WhoIsMyEmployee.com, Exploring Issues of Independent Contractor Misclassification and Joint Employment. All rights reserved.

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Say Say Say: How Not to Bungle an Independent Contractor Relationship

Remember the 1983 song, Say Say Say, by Paul McCartney and Michael Jackson? “Say, say, say what you want. But don’t play games with my affection.”

The songs asks for some straight talk. Be direct. Say what you mean. Or as Michael says, “What can I do girl, to get through to you. Cause I love you, baby (baby).”

1983 was a memorable year for me for music. I had a cassette called CHART ACTION 1983 that was one of my favorites. It included songs from Dexy’s Midnight Runners, Adam Ant, the Stray Cats, Bonnie Tyler, and Golden Earring.

But it didn’t have Say, Say, Say, and that was fine by me because I don’t really like the song. If it was on CHART ACTION 1983, I’d have skipped it, but the old fashioned way: forward, forward more, a little more, oops too far, rewind, rewind, forward, got it. Hungry Like the Wolf.

“Say say say what you want” would have been good advice for a Pennsylvania agency that offered interpreter and transcription services. The agency tried to run its business with an independent contractor model, but failed to say say say the right things in its agreements.

A Pennsylvania court ruled that the agency had misclassified its interpreters as independent contractors. Under PA unemployment law, the interpreters were actually employees. (“You know I’m crying oo oo oo oo oo.”)

Let’s look at where the agency went wrong.

Bad facts, tending to support employee status: The interpreters had a set of policies and procedures they had to follow, including wearing name badges. The agency did the scheduling.

Good facts, tending to support contractor status: The interpreters are not supervised, reimbursed for their expenses, or provided benefits, training, equipment, or name badges. An interpreter could refuse work at any time.

Totally unnecessary bad fact: The interpreters had to sign a non-compete agreement. That’s evidence of employment because it restricts the interpreter’s ability to work for others as an entrepreneur would do. But it turns out that, in reality, the agency didn’t care if the interpreters worked for others, and many of the interpreters did work for others.

Even worse, the non-compete included language referencing an “existing contract of employment.” Oops. Poor choice of words when you’re trying to prove there was no employment relationship. I would bet that the agency just pulled this non-compete language off the internet, without having considered the legal implications. The court focused a lot of attention on the non-compete when ruling that the interpreters were really employees.

The non-compete was a self-inflicted wound. That misstep is a good example of why you can’t just pick template agreements off the internet and expect that they’ll be sufficient.

More bad facts were on the website: Another problem for the agency was its website, which described the extensive training provided to interpreters, referred to them as “new hires,” and indicated they were all required to undergo a final performance evaluation. These facts all suggest an employment relationship.

Pennsylvania unemployment law applies a two-part test for determining whether someone is an employee or an independent contractor. To be an independent contractor, the service had to prove that it did not exercise control (a Right to Control Test) and that the interpreters were “customarily engaged in an independently established trade, occupation, profession or business.”

This could have been done correctly. Because of the independent nature of an interpreter’s work, the agency probably could have set up legitimate independent contractor relationships. This case is a classic example of how a proactive legal review could have saved the day.

If the agency had asked a lawyer for help in setting up the business the right way, this case could have gone the other way. The agency could have eliminated the non-compete agreement (which it didn’t enforce anyway), modified the website to eliminate “new hire” language and to de-emphasize training, cut back on the specific training provided, and changed the name tag requirement to a more generic requirement to provide identification.

So to the song I say say say: You may have hit #1 in the U.S. that October, but I’m not the one who really loves you.

© 2020 Todd Lebowitz, posted on WhoIsMyEmployee.com, Exploring Issues of Independent Contractor Misclassification and Joint Employment. All rights reserved.

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Shout It Like a Helium-Filled Gator: Don’t Limit Your Arbitration Agreements to Work-Related Disputes

Fig. 3. Atmosphere exchange during the experimental procedure without handling the subject

A team of researchers studying the vocalizations of Chinese alligators have won an Ig Nobel Prize for their method. They put the gators in helium-filled tanks and observed variations in their calls.

Sign me up.

I want to write papers with sentences like this one: “High-energy frequency bands in the bellows of the Chinese alligator were shifted towards higher frequencies when the animal vocalized in the heliox condition.”

My writing, for better or worse, is more focused on agreements. Here’s something to remember when writing arbitration agreements.

One of the main benefits of an arbitration agreement is the ability to prohibit class action lawsuits. When using arbitration agreements with employees or independent contractors, don’t forget to include the class action waiver. (There are pros and cons to mandatory arbitration, but we’ll leave that for another day.)

Too often, the scope of arbitration agreements is too narrow. Many agreements require arbitration of work-related or employment-related claims only.

Go broader. Expand your range, but without using helium.

In this case, a group of drivers alleged that a rideshare app company mishandled a data security breach. The drivers tried to bring a class action.

The court instead required them to seek relief one-by-one, in individual arbitration actions. That’s because their agreements required them to arbitrate disputes with the company and prohibited class litigation. The arbitration agreement here was broad enough to cover data breach claims.

Quick side note on what the legal dispute was really about: The drivers argued that the agreements were unenforceable. They pointed to the transportation worker exception in the Federal Arbitration Act (FAA). The FAA generally protects the enforcement of arbitration agreements, but it doesn’t apply to transportation workers in interstate commerce. The dispute was whether drivers who pick up passengers at airports for local rides are acting on interstate commerce because the passengers and their luggage flew in from other states. The district court said no, that these local drives are not interstate commerce, and the Ninth Circuit Court of Appeals agreed.

For our purposes, the lesson here is to be thoughtful about the scope of claims subject to arbitration. Go broader than just work-related claims. A data breach can be an expensive class action to defend if thousands of people are affected. Any single individual arbitration, however, is probably not worth the effort for a plaintiff’s lawyer. The damages for an individual arbitration will be too small to make it worth pursuing.

(The “go broad” concept has limits, and there are some claims that should be carved out of arbitration agreements, so I don’t want to overstate the point.)

Anyway, be creative and thoughtful when drafting agreements. Be sure the scope of covered claims is sufficiently broad. Careful planning can avoid class actions — or just maybe it can win you an Ig Nobel Prize.

Bonus track: Here’s audio of a helium-induced alligator bellow.

© 2020 Todd Lebowitz, posted on WhoIsMyEmployee.com, Exploring Issues of Independent Contractor Misclassification and Joint Employment. All rights reserved.

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Cut Off This, But Not That! Here’s Today’s Independent Contractor Tip

In 1877, the Police News reported the story of a dancer’s amputated leg sold at auction. But the story might not be as it seems, says Dr. Bob Nicholson, who studies news clippings from the Victorian era and is a fun follow on twitter.

Cutting off legs might not be a good way to raise money, but cutting independent contractors off from certain privileges may save your busienss money.

Whenever possible, cut off contractors from doing things that link them to your business. They should appear to the public as independent businesses, which hopefully they are.

To prevent contractors from portraying themselves in a way that may make them seem like employees, consider adding a clause like this one to your independent contractor agreements:

Contractor shall not use the Company’s name or logo in any of Contractor’s marketing or publicity materials, on clothing or other attire, on business cards, on a website, on social media, or in any other manner, unless the Company has granted permission in advance, in writing.

Sometimes you need your contractors to display your company logo, such as if they are being sent to customers’ homes for an installation. In those circumstances, consider adding “INDEPENDENT CONTRACTOR” in prominent language on any clothing that includes your company’s logo or name.

Proactive steps like this can help bolster your defense against misclassification claims. For balancing tests like the Right to Control Test and the Economic Realities Test, every good fact helps, and every bad fact hurts. Put as many brick on the good facts side of the scale as you can.

And if things don’t work out, you can always use this neat trick with your parasol to keep away bears.

Thanks again, Dr. Bob!

 

© 2020 Todd Lebowitz, posted on WhoIsMyEmployee.com, Exploring Issues of Independent Contractor Misclassification and Joint Employment. All rights reserved.

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Travel, Quarantine and Joint Employees: What Can You Require?

flying shark

Travel looks different now than ever before — especially for this shark. Last month in Myrtle Beach, a large bird plucked a shark out of the water and flew around with it. And best of all, there’s video! (Thanks @RexChapman for always keeping me entertained.)

Travel is different for people now too. Several states require people to quarantine if they travel to certain hot spots. New York, New Jersey and Connecticut require a 14-day quarantine if you return from any of 19 states, including popular summer vacation spots like Florida and South Carolina (Visit S.C.: We’ve Got Flying Sharks!). Other states with mandatory post-travel quarantines are listed here (as of 7/10/2020).

What to do when your employees vacation to a spot that requires post-visit quarantine? And what if temps, employed by a staffing agency, travel to a hot spot and want to return to work? Can you impose the same rules?

Let’s start with employees. Sometimes travel to a hotspot may be appropriate (visit a dying relative, attend funeral, military training). But personal vacation presents a problem. Employees should not be allowed to turn a one-week vacation into a three-week boondoggle.

Decide on a policy, then provide advance notice. You can remind employees of mandatory post-travel quarantine rules and, during a pandemic, you are allowed to ask employees where they are going on vacation. This is a matter of public health and employee safety.

Consider posting a notice that urges employees to avoid any personal travel to a hotspot, advising that they will not be permitted back in the workplace for 14 days (if your state requires). Let them know that if they are unable to work from home, this 14-day period is not an excused absence. Advise employees that normal attendance rules will apply, and two weeks of unexcused absences may subject them to termination. Or let them use and max out vacation and PTO during the 14-day period. Or apply normal attendance rules but cap the discipline at a final written warning.

You can impose different rules for employees who can work from home. Let them work from home. The policy I suggest above is for people who are expected to be onsite to work. The point is that you’re giving them one week off, not three.

You have many options, but be sure to notify employees in advance of the consequences of their voluntary travel decisions. You can require employees to sign the notice when they request vacation time or before they leave.

Can you do the same with your temps who are employed by staffing agencies? You might funnel the notice through the staffing agency but, in principle, yes. This is a matter of public health, and you should not have individuals onsite if your state has ordered that they be quarantined. You can ask your temps where they are going, and you can warn them that you will ask the staffing company to end their assignments if they take a vacation that subjects them to mandatory quarantine.

So if you go to South Carolina and live in selected states, be prepared to lose your job upon returning home. But at least while you’re gone, you may be able to watch flying sharks.

© 2020 Todd Lebowitz, posted on WhoIsMyEmployee.com, Exploring Issues of Independent Contractor Misclassification and Joint Employment. All rights reserved.

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Here’s a Question I Was Asked Three Times This Week (and the Answer)

Zippy sunset Charlevoix

Zippy on vacation

The word “sunset” can be used to signify many things. My personal favorite is the one pictured here. That’s Zippy enjoying the view this past weekend in Charlevoix, Michigan.

Another meaning of Sunset” is to fade out or to discontinue. That’s the meaning I’m after here.

One question came up multiple times this week, with some slight variations. Here it is, along with the answer.

Question:  When the pandemic began, we laid off an employee. We now have some work for that employee, but not as much as before. Can I bring back the employee as an independent contractor?

Answer:  Sunset that idea. Let it fade away. Discontinue that thinking. Probably not.

Any time the same individual receives a W-2 and a 1099 in the same calendar year, red flags go up. It’s a strong indicator of misclassification. If the worker’s work was employment before the pandemic, it’s almost certainly employment now — even if the hours are reduced or the recall is for a limited time.

Remember, the Employee vs. Independent Contractor question is answered by looking at the facts related to the work and how it is performed, regardless of what the parties call the relationship. If you’re bringing back an employee to perform similar work, you should probably be bringing that employee back as an employee.

In the IRS’s handbook for Worker Classification Determinations, the Service instructs its agents that when a worker has received a W-2 and a 1099 in the same year, the agent is to perform a full status review. It’s a likely sign of misclassification. Also, you probably don’t want the IRS to do a full anything.

There may be situations where it’s ok, such as if the laid off worker quickly established her own business, advertised to the public, secured other clients, and wants to bring on your business as a new client. But it’s pretty unlikely all that has happened since March.

The pandemic has given us all enough to deal with. Let’s not add a misclassification claim to the list of concerns.

Remember, it’s ok to bring back an employee as a part-time employee, or for a limited time with a projected end date. But retain the worker’s status as an employee.

And for those looking to get away during the pandemic, I highly recommend finding a beach house on Lake Michigan. Can’t beat these views!

© 2020 Todd Lebowitz, posted on WhoIsMyEmployee.com, Exploring Issues of Independent Contractor Misclassification and Joint Employment. All rights reserved.

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New Joint Employment Decision: Poo Paint or Just Poo?

poo rainbow

Sitting outside this weekend I was thinking about things I wish I had when my kids were toddlers, things that would have helped to keep them occupied. The first things that came to mind were all electronic — iPhone, iPad, Netflix. But then I came upon this. And it’s good that I didn’t know about it a decade ago.

https://www.poopaint.net/home-1

From the website:

Inspiration found in a bathroom stall!
PooPaint allows kids to wipe using toilet paper that feels as if they were playing with a colouring book.
Making potty time into a positive and fun experience!

Yes, my friends, it’s a coloring book for poo, like color by numbers but with only one color — brown. Or maybe for some, a beautiful mahogany. Square 3 is an exact reproduction of Cleveland winters: fill in the whole page, leaving gray at the top for sky.

Anyway, the case I want to talk about today is a joint employment case from the Sixth Circuit Court of Appeals. For potential joint employers, the decision is like potty time with poopaint — “a positive and fun experience!” For workers, it’s just poo.

In this case, a physical therapist assistant named Thomila worked in a nursing home. The operator of the nursing home contracted with a third party to provide staff.  The third party did the hiring, firing, controlled pay, provided benefits, supervised the workers, and scheduled them.

Thomila worked for the third party. At one point Thomila accused her supervisor, also a third party employee, of sexually harassing her. The third party investigated and fired him. So far, so good.

But then the nursing home operator — which apparently liked the supervisor — decided that Thomila was no longer a “good fit” for the nursing home and asked the third party to remove her. It did.

Thomila sued the nursing home operator, claiming that its request to remove her (after she complained of sexual harassment) was retaliation in violation of Title VII. Although she was employed by the third party, she claimed that the nursing home operator was a joint employer and therefore could be liable under Title VII’s anti-retaliation rule.

But the case was thrown out on a motion for summary judgment. The court ruled that the nursing home operator was not a joint employer under the test used for determining joint employment under Title VII.

The test for joint employment under Title VII is whether the alleged joint employer has the ability to:

  • Hire and fire,
  • Discipline,
  • Affect compensation and benefits, and
  • Direct and supervise performance.

(At least, that’s the test in the Sixth Circuit, which includes OH, MI, TN, and KY. You’d think the test would be the same everywhere since this is a federal law, but it sometimes varies a bit.)

Anyway, back to Thomila. The third party controlled all of these things, so the nursing home operator was not a joint employer. Since it was not a joint employer, it has no duty to Thomila under Title VII. The anti-retaliation provisions in Title VII did not apply. Case dismissed.

Thomila tried one other claim too, and this may have been her stronger argument. She alleged that by firing her, the nursing hone operator interfered with her access to employment opportunities. That’s a separate kind of claim. But the court ruled that the nursing home operator was not liable under that claim either, since the third party had offered Thomila other placement opportunities (but all were out of state). On this claim, the decision was 2-1, with the dissenting judge arguing that the interference claim should have been allowed to go forward. The interference claim does not require a finding of joint employment.

The lesson here for employers is that the test for joint employment is technical. The facts matter a lot. The risk of joint employment can be minimized if the relationship is carefully structured so that the third party retains control over the factors listed above. The contract should be drafted carefully, detailing who is responsible for what.

A poorly drafted contract is not worth the paper it’s written on. Kind of like that specific kind of paper advertised here as “Inspiration found in a bathroom stall!” And that should not be the kind of paper you’re looking for when drafting your contracts.

So draft wisely and, for “a fun and positive experience!“, choose your paper carefully.

© 2020 Todd Lebowitz, posted on WhoIsMyEmployee.com, Exploring Issues of Independent Contractor Misclassification and Joint Employment. All rights reserved.

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Not Your Ordinary Haircut: Does Your Sexual Harassment Policy Prohibit Harassment by Contractors?

Harassment policy independent contractor

From the Library of Congress digital collection.

This photo came with the description: “One of a series of images of a man harassing a woman as he cuts her hair.” Tip: don’t try this at home.

There are (unfortunately) many ways to harass a woman, most without scissors. Harassment can be by supervisors or fellow employees, but sometimes it comes from independent contractors.

Your company has a sexual harassment policy. Does it prohibit harassment of employees by contractors and other non-employees?

It should. Federal law creates a claim for sexual harassment if the harassment is by another employee, especially a supervisor. But the path toward a sexual harassment claim against a company for conduct by its independent contractors is less obvious. A hostile work environment claim can be asserted if a company knows of — and permits — a work environment that includes harassment by contractors, but a company’s control over contractors and their actions is going to be more limited than its control over its employees.

Your policy should fill the gap.

By creating a policy that takes a stance against harassment by independent contractors and other third parties, your company enhances its position in the event of a claim. Plus, it’s the right thing to do. If you hear of such a claim, investigate it. You may need to do something about it. That may include terminating the relationship with the contractor.

The policy should also say that conduct may be in violation of company policy even if the conduct is not prohibited by law. In other words, you are not conceding that you can control what your contractors do, and you are not conceding that there’s a viable legal claim. But you are taking a position against harassing behavior as a matter of policy.

The caption at the bottom of the photo above is small, but it says, “Getting his hair banged.”  I haven’t the slightest idea what that means, but it sounds bad. I would prohibit that too.

© 2020 Todd Lebowitz, posted on WhoIsMyEmployee.com, Exploring Issues of Independent Contractor Misclassification and Joint Employment. All rights reserved.

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“Who Was That Masked Man?” It Could be Your Independent Contractor.

who was that masked manFrom 1949 to 1957, The Lone Ranger ruled the airwaves. As recounted in the all-knowing wikipedia: “At the end of each episode, mission completed, one of the characters would always ask the sheriff or other authority, ‘Who was that masked man?’ When it was explained, ‘Oh, he’s the Lone Ranger!,’ the Ranger and Tonto would be seen galloping off with the cry, ‘Hi-Yo, Silver! Away!’ catching the attention of one of the townspeople crossing the street.”

Today, the answer to “Who was that masked man?” is likely to be, “Oh, he’s the lone maintenance guy on third shift” or “Oh, that’s Wilbur, our accountant.”

With many states now requiring employees and customers to wear face coverings, should the same be required of your company’s independent contractors? If you require contractors to wear face coverings, is that the type of control that could weigh in favor of employee status?

The practical answer is that, as the nation tries to emerge from the coronavirus pandemic, it’s a good practice to require everyone who works onsite — employees, customers, and independent contractors — to wear face coverings. The use of face coverings can be made mandatory as a condition of entering your facility. That is a site safety measure, not evidence of control that would convert your contractor to an employee.

But what about when the contractor works remotely, perhaps interacting with customers or working independently offsite? In that case, follow common sense and any applicable state and local law. For independent contractors who work on their own or in their homes, it’s probably not necessary to impose any specific face covering requirement. But that doesn’t mean they should freely expose their titillating chins and lips to the adoring masses. In your contracts with independent contractors, it is always wise to require that they comply with all applicable laws when performing any part of the services. That catch-all requirement is going to capture whatever face covering rule applies in that state at that time. The contractor should be required to do whatever the state or local law requires. Different states have different requirements.

What about staffing agency workers who work onsite? Can you safely impose the same face covering requirements on them as with your W-2 employees? Yes, and you should. Anyone working in your facility needs to comply with the applicable state and local work rules. That includes staffing agency workers at your location.

When the popular show’s run ended, Clayton Moore, who played the Lone Ranger, used to make public appearances in his distinctive mask. But in 1979, the Wrather Corp., which owned the rights to the character, sued Moore to make him stop wearing the mask in public. Moore reverted to wearing green-tinted sunglasses with his cowboy outfit, hardly an acceptable substitute for our heroic roughrider.

In 1985, the Wrather Corp. relented and allowed Moore to again don the mask. As he told the Los Angeles Times in 1985, “Playing the Lone Ranger made me more considerate of my fellow man.”

In today’s COVID-19 climate, you can follow the Lone Ranger’s ethos and require face coverings. It’s a small gesture that will make you more considerate of your fellow man.

Hi-yo!

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© 2020 Todd Lebowitz, posted on WhoIsMyEmployee.com, Exploring Issues of Independent Contractor Misclassification and Joint Employment. All rights reserved.

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