Archive for March, 2010

The Fair Labor Standards Act is Amended to Require Reasonable Break Times for Breastfeeding Moms

Wednesday, March 31st, 2010

Massive amounts of media attention have been paid to health care reform and the key points contained within the Patient Protection and Affordable Care Act; however, various provisions within that nearly one thousand page document have stayed under the radar screen, like the tiny provision amending the Fair Labor Standards Act (”FLSA”).

The FLSA amendment found in 29 U.S.C. 207 (r)(1) requires employers covered under the FLSA to provide a reasonable break time for an employee to express breast milk for her infant child. “Reasonable break time,” however, has not been defined. Under the amendment, employers must provide such breaks for up to one year after the child’s birth, but do not need to compensate for any time spent on the break. Employers also must furnish employees with “a place, other than a bathroom, that is shielded from view and free from intrusion from co-workers and the public” for expressing breast milk during the breaks.

Employers of fewer than 50 employees may be excused from providing breaks for breastfeeding, but only if doing so would create an “undue hardship.” Under the new amendment, “undue hardship” is defined as a hardship that causes significant difficulty or expense and is measured by the size, financial resources, nature, or structure of the employer’s business.

Although many states already have their own laws pertaining to expressing breast milk, employers in states that do not, such as Massachusetts, must now make sure they provide reasonable breaks for expressing breast milk and secure a private place for this to occur. Employers that are in states that have these laws in place, like Connecticut and Vermont, must adhere to whichever law is most favorable to the employee.

Obama Makes Two Pro-Union Appointments to the NLRB

Saturday, March 27th, 2010

Today, President Obama appointed two pro-union attorneys, Craig Becker and Mark Pearce, to the National Labor Relations Board. Obama made these appointments unilaterally, using what is known as a recess appointment, which is an appointment made while Congress is not in session and does not require Congress’ assent. Brian Hayes, a third nominee and member of the GOP, was left behind to be voted on by Congress.

These recess appointments do not bode well for employers. Becker, a controversial pro-union advocate, most recently was employed as Associate General Counsel for the Service Employees International Union and prior to that worked as an attorney for the AFL-CIO. Pearce also is a pro-union attorney. With these appointments, the NLRB will now have a 3-1 Democratic majority. Because these appointments were made during a Congressional recess, the terms for these appointees will end in 2011 whereas appointments with Congressional approval last five years.

Failing to Engage in the Interactive Process Costs Company Big Bucks

Thursday, March 18th, 2010

Recently, the Massachusetts Commission Against Discrimination awarded $100,000 in emotional distress damages in addition to an award of back pay to a Complainant who resigned from her job after she alleged no one would accommodate her disability (coronary artery disease). In MCAD et al. v. Codman & Shurtleff, Inc., an MCAD hearing officer concluded that the company had sufficient notice of a need for accommodation and, then, despite that notice, failed to engage in the interactive process. Because of that failure, the Hearing Officer determined that Complainant was justified in quitting her job.

In this case, Complainant claimed she had made several requests for a reduction in her workload both to Human Resources and her supervisor. On one occasion, she told the Human Resources Manager that if her workload was not reduced, she would “suffer a heart attack and die.” When her workload was not reduced, she requested a leave of absence for cardiovascular distress, which was granted. Complainant took a total of three leaves of absence for this condition. Following her leaves, Complainant continued to request that she have a lighter workload and, ultimately, when that did not happen, she quit.

Thereafter, Complainant sued for disability discrimination, asserting that her former company had failed to engage in the interactive process with her and, thus, compelled her resignation. In its defense, the company claimed that it had no notice of her disability and, because of that, the duty to engage in the interactive process was never triggered. The company also asserted that it had nevertheless accommodated Complainant by providing her with three leaves of absence.

The Hearing Officer disagreed with the company’s position and, instead, found that Complainant’s statement to Human Resources and subsequent leaves of absence was sufficient to put the company on notice of a need for accommodation. The Hearing Officer further found that after Complainant’s “numerous requests to revise her job duties and three medical leaves resulting in large part from the stress of the job,” Complainant had no other avenue but to quit her job because Respondent refused to engage in a dialogue about the ways it might try to alleviate her burdensome workload.

Although the result in this case is frustrating because there is obviously no requirement that an employer change the nature of the job or remove essential job duties in order to accommodate someone with a disability, the case itself serves as a good example of how crucial it is to have an interactive dialogue with an employee in which different accommodations are discussed, regardless of whether or not the employee’s initial request for accommodation seems unreasonable. Indeed, perhaps in this case there was no accommodation that ultimately would have worked for this Complainant short of changing her job altogether; nevertheless, the act of engaging in the process itself is what might have saved this company from a large judgment.

This case also serves as a reminder to employers that an employee need not utter the words “I am disabled” in order to trigger any obligations on the company’s part. Because of that, it is important that supervisors, who are often the company’s first line of defense, are trained so they know how to spot those situations where an interactive dialogue is warranted.

Royal & Klimczuk attorneys routinely offer this and other types of supervisory training, so if you are interested in arranging for any trainings, please contact any of the attorneys at Royal & Klimczuk.

COBRA Subsidy Could be Extended Again

Monday, March 15th, 2010

Last week, the United States Senate approved a tax extender package, which contains provisions that would extend the COBRA subsidy to December 31, 2010. The Act also would extend emergency unemployment benefits and allow for certain tax breaks.

The Senate bill is slated to go to a committee for further debate and consideration, which obviously will delay its ultimate enactment. We will keep you posted on any developments.

Connecticut House of Representatives approves bill allowing employees to bypass CHRO

Wednesday, March 10th, 2010

On February 16, 2010, we reported that the Connecticut General Assembly was considering legislation that would allow employees to file discrimination and harassment claims directly in state court instead of having to first file their claims with the Commission on Human Rights and Opportunities as is currently required. Yesterday, the House Labor and Public Employees Committee approved the legislation, House Bill 5206 – An Act Providing an Individual an Earlier Release from the Jurisdiction of the Commission on Human Rights and Opportunities to File a Civil Action in Superior Court. The Committee has referred the bill directly to the Judiciary Committee, which has until March 29, 2010 to act on the bill.

The CHRO has opposed the legislation, expressing concerns that it will undermine the power of the CHRO and other administrative agencies to enforce the laws that they are meant to enforce. In addition, the bill has inspired an unusual alliance between labor groups and business organizations. These groups have also criticized the bill, pointing out that the CHRO often can streamline resolution of claims, reducing taxpayer expenditures and litigation costs. Furthermore, AFSCME Local 2663 views the bill as contradictory to the core principal of administrative law that if an adequate administrative remedy exists, it must be exhausted before the courts can take jurisdiction over the matter. The Connecticut Trial Lawyers Association, on the other hand, believes the bill is necessary for more complex cases that the CHRO may not be equipped to resolve effectively.

The House has proposed that the bill take effect on October 1, 2010. Stay tuned for additional updates after the Judiciary Committee’s March 29, 2010 deadline for acting on the bill.

COBRA Subsidy Extended One More Month to March 31, 2010

Thursday, March 4th, 2010

Late on Tuesday, President Obama signed the Temporary Extension Act of 2010, a bill that extends the COBRA subsidy to March 31, 2010 and applies retroactively. Extended once previously, the subsidy had been slated to expire on February 28, 2010. The Temporary Extension Act contains various provisions that are intended to clarify portions of the previous law. The Act also extends unemployment benefits.

Massachusetts Identity Theft Regulations Take Effect Today

Monday, March 1st, 2010

After several postponements and amendments, Massachusetts regulations 201 CMR 17, Standards for Protection of Personal Information of Residents of the Commonwealth, went into effect today. These regulations create very specific obligations for businesses that own or license personal information about any Massachusetts resident, regardless of the size of the business or the number of employees that business employs. All businesses are required to be in full compliance with the regulations by March 1, 2010.

The first step business must take to get into compliance with the new regulations is to implement an information security program. This program must be in writing and must outline various steps the business will take to protect personal information, whether that information is stored electronically or in paper documents. The regulations require numerous specific provisions that must be included in the program, such as a secure method of assigning and selecting passwords; encryption of all data containing personal information that is transmitted wirelessly or across public networks; and maintaining reasonably up-to-date firewall and malware protection.

Once they have their program in place, the next step businesses must take is to educate employees who handle personal information about their role in protecting that information. Additionally, businesses that retain third-party vendors such as payroll administrators or document disposal companies must take reasonable steps to ensure those vendors are properly safeguarding personal information.

Royal & Klimczuk, LLC continues to conduct seminars detailing businesses’ obligations under the new identity theft regulations and how businesses can come into compliance with the regulations. Details on these and other seminars can be found at: http://www.rkesq.com/upcomingseminars.html.

For more information about planning for compliance, please contact Amy B. Royal, Esq. or Kimberly A. Klimczuk, Esq. at (413) 586-2288. Amy and Kimberly may also be reached by e-mail at aroyal@rkesq.com and kklimczuk@rkesq.com, respectively.