The U.S. Department of Labor (DOL) recently proposed a policy on overtime that may impact custodial departments. To solicit feedback from businesses, the DOL is offering a 60-day comment period. But some industry professionals feel more time is necessary for the business community to better analyze the potential impact of the proposal on the workforce and operations, and to explore alternatives that might produce better results.

ISSA is encouraging members of the industry to request an extension to the 60-day period. Requests can be filed by clicking here.

ISSA is also encouraging members of the industry to share their concerns about the DOL proposed rule on overtime with the association. They ask that you share how the proposal will impact the following areas:
 • Estimated financial impact on your annual labor costs
 • Any anticipated layoffs of employees
 • Effect on your day to day operations
Send your comments along these lines and other pertinent information to Bill Balek, ISSA, bill@issa.com no later than August 26, 2015.

Background on the DOL Overtime Proposal
Under current FLSA regulations, if you have workers who earn less than $23,660 a year, or $455 a week, and they work 40 hours a week, the DOL considers them “non-exempt” employees, and you're obligated to pay them time-and-a-half for any hours they work over that.

The proposed rule would more than double the salary threshold for employees who are eligible to receive overtime pay, from $23,660 to $50,440.  Moreover, for the first time ever, the DOL is proposing to index the salary test for all exemptions annually based on percentiles of earnings or changes in inflation. This significant change would require employers to review their classification of exempt employees annually to ensure compliance with the salary test.

It is estimated that the proposed revisions to the overtime pay rules would:
 • Directly affect 4.6 million workers in the U.S, and total direct employer costs for Year 1 are estimated to equal $592.7 million dollars. 
 • Cost each small business, on average depending on the number of workers covered by the regulation, $100 to $600 in direct costs and $320 to $2,700 in additional payroll costs to employees in the first year after the promulgation of the proposed rule.
 • Cause each small business to spend one hour of time for regulatory familiarization; one hour per each affected worker in adjustment costs; and five minutes per week scheduling and monitoring each worker expected to be classified as overtime eligible as a result of the proposed rule. 
 • For more information, please see the DOL fact sheet on the proposed changes.