Following 2024 legislative reforms to California’s Private Attorneys General Act (PAGA), a manufacturer with multiple California entities sought to evaluate potential wage and hour compliance risks related to meal periods, rest breaks, and final wage payments, and to understand the implications of the revised statutory framework.
CRA’s Labor & Employment experts conducted a detailed review of meal period, rest break, and final pay practices. The team evaluated compliance outcomes across multiple operating entities and employee populations, incorporating employee attestations, waiver information, and collective bargaining agreement provisions where relevant. Analyses were developed at varying levels of detail to identify broad compliance trends, quantify potential exposure, and assess the operational factors contributing to potential violations.
The resulting analyses helped inform remediation efforts and operational changes designed to enhance compliance. The work provided the client and counsel with an empirical foundation for evaluating potential exposure under the revised PAGA framework and assessing the applicability of statutory provisions intended to reduce penalties following corrective action.
