Employment Relationships – Draft Administrative Policy

Participation for "Employment Relationships - Draft Administrative Policy" has concluded.

Wooden tiles spelling out "FEEDBACK"

In order to be transparent and seek input from the diverse business and labor communities, L&I is currently seeking stakeholder feedback on the draft administrative policy addressing employment relationships.

We are asking the public to review the draft administrative policy by Monday, June 14, 2021.

Feedback can be submitted directly to this page via the “Submit Comments” tab, or using an attached document via the “Upload Documents” tab.

Feedback can also be submitted via the ESRules@Lni.wa.gov email box. Feedback submitted to the email box will be uploaded to this engagement site.

A virtual stakeholder feedback session to discuss the content of the draft administrative policies is being held on Wednesday, March 24, 2021, from 2:00 p.m. to 4:00 p.m. Details on how to participate can be found on the timeline located on the "Review Draft Administrative Policies" page.


In order to be transparent and seek input from the diverse business and labor communities, L&I is currently seeking stakeholder feedback on the draft administrative policy addressing employment relationships.

We are asking the public to review the draft administrative policy by Monday, June 14, 2021.

Feedback can be submitted directly to this page via the “Submit Comments” tab, or using an attached document via the “Upload Documents” tab.

Feedback can also be submitted via the ESRules@Lni.wa.gov email box. Feedback submitted to the email box will be uploaded to this engagement site.

A virtual stakeholder feedback session to discuss the content of the draft administrative policies is being held on Wednesday, March 24, 2021, from 2:00 p.m. to 4:00 p.m. Details on how to participate can be found on the timeline located on the "Review Draft Administrative Policies" page.


Submit Comments

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Participation for "Employment Relationships - Draft Administrative Policy" has concluded.

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(Submitted on 6/8/21 by Rose Gundersen, WA Retail Association)

In addition to my comments offered during the feedback session on March 24, Washington Retail has an additional comment for the highlighted portion under section 10 in the ES.A.14 draft:

10. What governs “successorship” for Minimum Wage Act liabilities?

“Successors” may be liable for Minimum Wage Act obligations held by the previous owners under certain circumstances. Successors hold this liability when the successor has: A) Actual knowledge of the fact and amount of the outstanding citation and notice of assessment, OR B) A prompt, reasonable, and effective means of accessing and verifying the fact and amount of the outstanding citation and notice of assessment from the department.

This provision neither considers the potential of an on-going wage complaint investigation during the sale negotiation when the potential buyer reviews the public website nor does it consider the gap of time between issuance of citations/assessments till the time of posting on L&I’s website for public viewing. Please revise to accommodate this reality as small business buyers may not be that sophisticated to do this level of due diligence.

Thank you.

Stay healthy!

Allison Drake almost 3 years ago
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