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California Labor Guidance

Free plain-English summaries of opinion letters, administrative policies, and interpretive notices from California's labor agency, with the current status and the official source on every page.

278 documents · Updated July 6, 2026
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Meal periods for fuel carriers subject to federal safety regulations

A law firm asked whether drivers who transport hazardous fuel and must stay with or near their trucks under federal hazmat regulations can be given an "on-duty" paid meal period instead of an off-duty…

Opinion Letter June 9, 2009

Alternative workweek schedule during summer months

A law firm asked whether an employer could adopt an alternative workweek schedule of four 9-hour days plus one 4-hour day only during summer months, reverting to a standard five 8-hour day schedule th…

Opinion Letter March 23, 2009

Compensability of time spent obtaining a federally mandated TWIC port-security card

A union attorney asked whether Shell refinery workers required to obtain a federal Transportation Worker Identification Credential (TWIC) to access secure port areas must be paid for the time spent en…

Opinion Letter November 25, 2008

Whether pre-employment state-mandated security officer training time is compensable

A trade association for licensed security guard companies asked whether members must pay applicants for the state-mandated classroom training (up to 40 hours) required to become a registered security …

Opinion Letter August 29, 2007

Resident employees at 24-hour care facilities: sleep time and lodging charges

A residential care facility asked the DLSE whether "resident employees" who live on-site but aren't required to stay there must be paid for sleep time, and how much the facility may charge them for ro…

Opinion Letter April 23, 2003

Travel time pay for an employee working alternating worksites

An employer asked whether an employee who alternates weeks between two work locations must be paid for the roughly 1.5-hour daily commute to the more distant site. The DLSE explained that an ordinary …

Opinion Letter April 22, 2003

Hours worked: split shift

An attorney asked how long an unpaid break can last before it stops counting as a meal period and instead becomes a "split shift" requiring extra pay. DLSE explained that it has long treated any bona …

Opinion Letter December 11, 2002

Wage requirements for camp counselors

An operator of educational overnight programs (including historic-ship stays and island camps) asked whether its counselors qualified for Labor Code section 1182.4's minimum-wage/overtime exemption fo…

Opinion Letter December 9, 2002

Semimonthly pay periods for nonexempt salaried employees

An employer paid non-exempt salaried employees semimonthly and listed a flat 86.67 "averaged" hours per pay period on wage statements rather than the actual, varying hours worked. DLSE held this viola…

Opinion Letter May 17, 2002

Hours worked: time spent traveling on an out-of-town business trip

A non-exempt employee asked whether he was entitled to pay for time spent flying to and from a mandatory out-of-town training class, after his employer's staff manual denied pay for travel outside nor…

Opinion Letter February 21, 2002

Hours worked: public transit employees who start and end shifts at different locations

A union and a regional transit district jointly asked whether bus and light-rail operators who are required to end a shift at a different location from where it began must be paid for the time spent t…

Opinion Letter January 29, 2002

Compensation for employee's stand-by time

An attorney asked, on behalf of a U.S. DOL certifying officer reviewing an alien employment certification, whether a "senior line operator" job requiring 24-hour on-call availability (with a cell phon…

Opinion Letter March 22, 2001

Whether meal periods during which employees are restricted to their employer's premises constitute hours worked

A union attorney asked whether an employer (Chevron Marketing) could lawfully require employees to remain on its premises during unpaid lunch breaks. DLSE said no: under every IWC wage order, any time…

Opinion Letter January 12, 2001

Compensability of resident apartment managers' on-call time

A law firm asked DLSE whether resident apartment managers must be paid for time spent "on-call" carrying a beeper. DLSE explained that Wage Order 5's special rule for employees required to reside on t…

Opinion Letter December 28, 1998

Uniform-changing time as hours worked, and the effect of a CBA

A law firm asked DLSE whether theme-park employees must be paid for time spent walking to a wardrobe facility, waiting in line, and changing into and out of required uniforms before and after their sh…

Opinion Letter December 23, 1998

Sleep shifts and hours worked under IWC Order 5: residential care facility

An administrator of a residential care facility for developmentally disabled adults asked whether overnight hours, during which employees on 12-hour shifts are required to be present but are permitted…

Opinion Letter November 9, 1998

Work recesses under IWC Order 8-80, paragraph 3(E)

A produce-packing employer asked whether releasing employees from duty for unscheduled work recesses (while waiting for delayed produce deliveries) could be unpaid time under paragraph 3(E) of IWC Wag…

Opinion Letter September 11, 1998

Charging job applicants for required training is unlawful; training time is hours worked

A law firm asked whether a telemarketing employer could charge a training fee (waived after five days of employment) to job applicants who had to complete the employer's own training class to be consi…

Opinion Letter September 11, 1998

Ambulance crew sleep-period exclusion from hours worked requires at least five uninterrupted hours

The Labor Commissioner corrected an earlier answer to a recurring question under Wage Orders 5-98 and 9-98: for ambulance drivers and attendants on 24-hour shifts who agree in writing to exclude a reg…

Opinion Letter May 29, 1998

Reporting time pay: employees sent home for poor performance

An employer asked whether it could pay telephone solicitors only for actual hours worked when it sent them home early because their pledge or conversion rates fell below the "house average." DLSE answ…

Opinion Letter August 25, 1997

Meal-period compensation for on-premises health care workers after the 1993 hours-worked change

A member of the public asked DLSE whether a hospital must pay a respiratory therapist for meal periods spent on the premises without being allowed to leave. DLSE explained that under Bono Enterprises …

Opinion Letter July 12, 1996

Bono Enterprises meal-period rule does not require pay for on-premises health care meal breaks

A law firm asked the Labor Commissioner to confirm that, in the health care industry specifically, an employer need not pay for a meal period merely because the employee must stay on the premises, so …

Opinion Letter November 1, 1995

Electronic (paperless) time recording is lawful if retrievable and printable on request

An attorney asked whether an employer's proposed phone-based, paperless time-recording system, which posted printouts for four days before recycling them and relying solely on the computer database, c…

Opinion Letter July 20, 1995

On-call time, travel time, and vehicle expenses for beeper-dispatched service technicians

An attorney asked whether on-call vending-machine repair technicians who carry a beeper and drive their own cars between calls are owed pay for on-call waiting time, travel time to and between calls, …

Opinion Letter February 16, 1994

Time spent donning required protective gear is compensable under California's broader 'hours worked' test, unlike the federal Portal-to-Portal Act standard

A meat-packing employer asked whether time its employees spend putting on USDA- and Cal/OSHA-required lab coats, head coverings, gloves, and ear plugs (plus optional comfort items like aprons and boot…

Opinion Letter February 3, 1994

Overtime paid on a voluntary back-to-back shift doesn't offset the next day's regular-shift premium

A law firm asked DLSE whether an employer could count premium pay voluntarily paid for a back-to-back overnight shift toward the overtime owed for the employee's regular shift the next day, given the …

Opinion Letter December 9, 1993

Pre-employment training time is compensable; only narrow skills-testing 'try-out' time is not

California's Employment Development Department asked DLSE about a firm requiring job applicants — including veterans seeking on-the-job training benefits — to complete unpaid "hiring procedure" traini…

Opinion Letter November 29, 1993

On-call beeper time is compensable based on the employer's 'control,' a different and broader test than the federal FLSA standard

A law firm representing a rural hospital asked DLSE to clarify when beeper-based on-call time, where employees must respond within 20 minutes but are not required to stay on the premises, counts as co…

Opinion Letter March 31, 1993

Employers must pay for mandatory safety-orientation training and certification, for both current employees and job applicants

Counsel for a general contractor asked whether workers could be required to complete, on their own time and at their own expense, an 8-hour industry safety orientation program needed to badge into ind…

Opinion Letter January 19, 1993

Part-time hospital nurses with a schedule distinct from full-time nurses can form a separate 'identifiable work unit' eligible for its own alternative workweek

A hospital's counsel asked DLSE whether full-time and part-time nurses working the same department and shifts, but differing in scheduled hours and benefits, could be treated as separate groups for pu…

Opinion Letter February 28, 1992

Absent a specific agreement stating a different number of hours, the workday defaults to eight hours for reporting-time-pay purposes

An employer's counsel asked whether a company that does not schedule daily hours of work could pay only the two-hour minimum reporting-time pay under Wage Order 7-80 rather than more. DLSE explained t…

Opinion Letter January 30, 1992

Wearing a pager alone does not make a meal period compensable, but responding to a page during the meal period makes the whole period compensable

Labor counsel asked DLSE to clarify its policy on paying employees for time spent wearing a "beeper" or pager, including during meal periods. DLSE explained that simply requiring an employee to wear a…

Opinion Letter January 28, 1992

Temporary registry nurses hired for a hospital's full alternative workweek can be included in it without daily overtime; those hired for less than the full week cannot

Counsel for a health-care employer asked DLSE whether temporary nurses supplied by a staffing registry could be placed into a hospital's existing alternative workweek (such as a 3/12 or 4/10 schedule)…

Opinion Letter January 21, 1992

48-hour weekend 'on duty' shifts for non-resident workers get no overtime exemption, and lump-sum weekend pay doesn't satisfy the hourly-rate requirement

A retirement facility's counsel asked what overtime rules apply to two weekend-only workers who would be "on duty" from Friday afternoon to Sunday afternoon, a total of 48 hours, and whether they coul…

Opinion Letter November 1, 1991

Truck drivers who split their day between CHP-regulated and unregulated duties: only the unregulated hours count toward daily/weekly overtime

Employer counsel wrote to confirm DLSE's enforcement policy on overtime for truck drivers who spend part of the day performing duties regulated by the California Highway Patrol under Title 13 of the C…

Opinion Letter November 1, 1991

Time worked beyond an adopted alternative-workweek schedule, even below the 10/12-hour straight-time cap, requires premium overtime pay

An employer wrote to DLSE describing conflicting guidance from two district offices about premium pay under an alternative workweek schedule of two ten-hour days and two four-hour days. DLSE confirmed…

Opinion Letter October 7, 1991

Owner-operator truck driver pay plans must separately reimburse vehicle operating costs under Labor Code §2804, and extra commute time beyond a customer delivery must be paid

A trucking company's counsel described a proposed pay plan for employee-drivers who own their own trucks, paying an hourly wage plus a share of the broker's revenue, and asked whether commute time aft…

Opinion Letter August 30, 1991

DLSE forwards prior correspondence on the 9/80 alternative workweek schedule and flags possible federal DOL concern about workweek-splitting

An attorney asked DLSE about the 9/80 alternative workweek schedule. DLSE Chief Counsel replied by enclosing copies of correspondence the Division had already sent addressing the 9/80 schedule, statin…

Opinion Letter June 19, 1991

Unpaid 30-minute meal periods are lawful if the employee gets a genuine duty-free opportunity to take them, but employers must pay for reported or known meal-period work

A company employing unsupervised field service technicians asked DLSE whether its practice of an unpaid 30-minute daily lunch period was lawful. DLSE explained that the IWC Orders require a duty-free …

Opinion Letter June 3, 1991

Overtime for temp-agency respiratory therapists placed at multiple hospitals with different workweeks in one week

A staffing agency placing respiratory therapists at various hospitals asked DLSE how overtime applies when the same worker is placed at different hospitals with different adopted workweeks (e.g., 3 da…

Opinion Letter April 19, 1991

Alternative workweek: 'affected employees' can be a regional work unit, not necessarily the whole statewide job classification

An employer asked DLSE whether, for a proposed alternative workweek covering the job classification "collector," the "affected employees" who must be given the required notice and vote had to be all c…

Opinion Letter March 31, 1991

Part-time employees can adopt their own alternative workweek schedule as a recognized subdivision of the work group

Responding to a follow-up on an earlier interpretive bulletin and letter, DLSE clarified that part-time employees are not excluded from adopting an alternative workweek schedule under Wage Orders 4, 5…

Opinion Letter July 6, 1990

Employer-directed travel time is hours worked in California with no federal-style 8-hour cap, unlike under the FLSA

An employer asked whether it complied with California law by paying only 8 hours of normal wages on days when employees were non-working passengers on planes or other transportation for 8 or more hour…

Opinion Letter December 7, 1989

A foreseeable mechanical breakdown is not 'a cause not within the employer's control' excusing reporting-time pay

A citrus packing plant that suffers mechanical breakdowns shutting down its wholly mechanical operation asked whether Wage Order 5(C)(3)'s exception to reporting-time pay -- for interruptions "caused …

Opinion Letter March 8, 1989

Day-of-rest exemption for the "grape industry" during harvest extends to wineries fermenting grapes

A law firm asked DLSE to reconcile the Industrial Welfare Commission's wage orders with Labor Code § 551's day-of-rest requirement, and whether Order 8-80's exemption for the "grape industry" during t…

Opinion Letter May 16, 1988

Time spent changing into required uniforms may be compensable; DLSE adopts the Lindow de minimis test

A hotel chain's counsel argued that time employees spend changing into and out of a required company uniform is de minimis and non-compensable under Lindow v. United States (9th Cir. 1984). DLSE disag…

Opinion Letter May 16, 1988

No cap on daily overtime hours if premium pay is paid; day-of-rest and constructive-discharge limits explained to a state legislator

A member of the California Assembly forwarded a constituent's complaint about excessive required overtime. DLSE responded that no law or regulation caps the amount of daily overtime an employer may re…

Opinion Letter March 21, 1988

Overtime for substitute employees who fill in on a different shift length under an alternative-workweek agreement (Wage Order 5-80)

A law firm asked DLSE how overtime applies to substitute employees who work rotating 8-hour and 12-hour shifts under the alternative-workweek amendments to Wage Order 5-80. DLSE distinguished three si…

Opinion Letter March 21, 1988

Meal periods spent confined to the employer's premises count as hours worked

An attorney asked DLSE to explain its position under Section 11 of the Industrial Welfare Commission orders on employees required to remain on the employer's premises during meal periods. DLSE reaffir…

Opinion Letter January 5, 1988

Workweek overtime and split-shift premium explained for an irregular retail schedule

A retail employer's assistant employee relations manager asked DLSE about overtime owed under a specific weekly work schedule. DLSE explained that IWC Order 7-80 requires overtime after 8 hours in a d…

Opinion Letter December 1, 1986

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These are official interpretive documents from California's labor agency: opinion letters answering questions from employers and workers, administrative policies, and interpretive notices. They show how the agency applies wage-and-hour and workplace law to real situations, but they are guidance, not statutes or court decisions, and the agency can supersede or withdraw them. Every page above shows the document's current status, when that status was last verified, and a link to the official source.

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