Part 4: Legal Compliance & Employment Law

Часть 4: Юридическое соответствие и трудовое право

A Comprehensive Guide to US Employment Law for International HR Professionals

1. Introduction to US Employment Law Введение в трудовое право США

Overview of the US Legal System

The United States employment law system is notably complex, especially for international HR professionals. Unlike many countries that have a single, comprehensive labor code, US employment law consists of multiple federal statutes, state laws, local ordinances, and common law principles.

Key Difference from Russian Law:

Russia operates under the Labor Code of the Russian Federation (Трудовой кодекс Российской Федерации), a comprehensive document that covers most employment matters in one place.

United States has no single labor code. Instead, employment law comes from:

  • Multiple federal statutes (each addressing specific issues)
  • 50 different state laws (which can vary significantly)
  • Local city and county ordinances
  • Court decisions (common law)
  • Administrative agency regulations

Federal vs. State Laws Федеральные и государственные законы

Understanding the relationship between federal and state employment laws is crucial:

Level Scope Key Principle
Federal Laws
Федеральные законы
Apply to all employers nationwide (subject to size thresholds) Set the minimum standard that all states must follow
State Laws
Законы штатов
Apply only within that specific state Can provide MORE protection than federal law, but not less
Local Laws
Местные законы
City or county-specific Can be more restrictive than state or federal law

Employment-At-Will Doctrine Доктрина "По усмотрению работодателя"

The United States follows the Employment-At-Will doctrine, which is radically different from most countries:

🇺🇸 United States: Employment-At-Will

Unless there is a contract stating otherwise:

  • Employer can terminate employee at any time, for any reason (or no reason), with or without notice
  • Employee can quit at any time, for any reason, with or without notice
  • No severance pay is required by law (in most cases)
  • Notice periods are NOT legally required
🇷🇺 Russia: "Just Cause" Requirement

Under the Labor Code of the Russian Federation:

  • Employer must have "just cause" to terminate (Article 81)
  • Specific notice periods are required (2 months for redundancy)
  • Severance pay is mandatory in many cases
  • Strong employee protections during probation periods
  • Trade unions must be consulted for certain terminations
💡 Practical Implication for Russian HR Professionals:

The at-will doctrine means US employers have significantly more flexibility in termination decisions than Russian employers. However, this freedom is limited by anti-discrimination laws, which are much more extensive in the US than in Russia.

In practice, most professional employers still provide notice and severance as a business courtesy and to avoid wrongful termination claims.

Employer Size Thresholds Пороги размера работодателя

Many US employment laws only apply to employers with a certain number of employees:

Number of Employees Laws That Apply
1+ • FLSA (wage/hour laws)
• OSHA (workplace safety)
• Immigration laws (I-9)
• Workers' compensation
• Unemployment insurance
15+ • Title VII (discrimination)
• ADA (disability discrimination)
• GINA (genetic information)
• Pregnancy Discrimination Act
20+ • ADEA (age discrimination)
• COBRA (health insurance continuation)
50+ • FMLA (family/medical leave)
• ACA (Affordable Care Act) employer mandate
• EEO-1 reporting requirements
100+ • WARN Act (mass layoff notice)
• Enhanced EEO-1 reporting

Enforcement Mechanisms Механизмы правоприменения

US employment laws are enforced through multiple channels:

1. Administrative Agencies Административные агентства
  • EEOC (Equal Employment Opportunity Commission) - Discrimination claims
  • DOL (Department of Labor) - Wage/hour, FMLA, OSHA
  • NLRB (National Labor Relations Board) - Union issues, protected concerted activity
  • USCIS (US Citizenship and Immigration Services) - I-9 compliance
  • State agencies - Often handle the same issues as federal agencies
2. Private Lawsuits Частные иски

Employees can sue employers directly in court for violations. The US is highly litigious:

  • Individual lawsuits
  • Class action lawsuits (multiple employees together)
  • Attorney contingency fees (lawyers work for percentage of award, not hourly)
  • Jury trials are common in employment cases
3. Criminal Prosecution Уголовное преследование

Rare, but possible for serious violations:

  • Willful OSHA violations causing death
  • Obstruction of justice
  • Immigration fraud
Potential Penalties for Violations:
  • Compensatory damages: Lost wages, benefits, emotional distress
  • Punitive damages: Additional penalties to punish employer (can be millions)
  • Attorney's fees: Employer often must pay employee's legal costs
  • Reinstatement: Ordering employer to rehire employee
  • Injunctions: Court orders requiring specific actions
  • Fines: Civil and criminal penalties
  • Imprisonment: In extreme criminal cases

2. EEOC & Protected Classes Комиссия по равным возможностям трудоустройства и защищенные классы

What is the EEOC?

The Equal Employment Opportunity Commission (EEOC) is the federal agency responsible for enforcing federal anti-discrimination laws. It was established by Title VII of the Civil Rights Act of 1964.

EEOC Responsibilities:
  • Investigating discrimination charges filed by employees
  • Attempting mediation between employers and employees
  • Filing lawsuits against employers (when appropriate)
  • Issuing guidance and regulations
  • Providing education to employers and employees
Comparison with Russia:

Russia does not have a single agency equivalent to the EEOC. Labor disputes are primarily handled through:

  • Labor Inspectorate (Трудовая инспекция) - Oversees labor law compliance
  • Courts - Handle individual discrimination claims
  • Prosecutor's Office - Can investigate serious violations

The EEOC is much more proactive and powerful than Russian equivalents.

Protected Classes Защищенные классы

US federal law prohibits employment discrimination based on specific protected characteristics. Understanding these is fundamental to US HR compliance:

Protected Class Federal Law Employer Coverage Key Points
Race
Раса
Title VII (1964) 15+ employees Includes color, hair texture, protective hairstyles
Color
Цвет кожи
Title VII (1964) 15+ employees Distinct from race (can discriminate within same race)
National Origin
Национальное происхождение
Title VII (1964) 15+ employees Includes ancestry, ethnicity, accent, language
Religion
Религия
Title VII (1964) 15+ employees Requires reasonable accommodation unless undue hardship
Sex
Пол
Title VII (1964) 15+ employees Includes pregnancy, sexual orientation, gender identity
Age
Возраст
ADEA (1967) 20+ employees Only protects 40+ (no protection for being "too young")
Disability
Инвалидность
ADA (1990) 15+ employees Requires reasonable accommodation; very broad definition
Genetic Information
Генетическая информация
GINA (2008) 15+ employees Includes family medical history
Pregnancy
Беременность
PDA (1978) 15+ employees Amendment to Title VII; requires accommodation
Military/Veteran Status
Военный/ветеран статус
USERRA (1994) All employers Job protection for military service
Citizenship Status
Статус гражданства
INA (1986) 4+ employees Protects authorized workers from citizenship discrimination

What Constitutes Discrimination? Что представляет собой дискриминацию?

Discrimination can take multiple forms under US law:

1. Disparate Treatment Неравное обращение

Intentionally treating someone differently because of a protected characteristic.

Example of Violation:

A hiring manager says, "We need someone younger and more energetic for this role," and rejects a 55-year-old qualified applicant in favor of a 30-year-old.

Why it's illegal: Age (40+) is a protected class, and the decision was explicitly based on age.

2. Disparate Impact Неравное влияние

A seemingly neutral policy that disproportionately affects a protected group.

Example of Violation:

A company requires all applicants to have a college degree for an entry-level warehouse position. This requirement disproportionately excludes Black and Hispanic candidates, and the employer cannot show it's necessary for the job.

Why it's illegal: The requirement has a disparate impact on protected groups and is not job-related.

3. Harassment Домогательство

Unwelcome conduct based on a protected characteristic that creates a hostile work environment.

Example of Violation:

Coworkers repeatedly make jokes about an employee's accent and ask "Where are you really from?" even after being asked to stop. The employee feels uncomfortable and isolated.

Why it's illegal: Creates a hostile work environment based on national origin.

4. Retaliation Ответные меры

Punishing an employee for complaining about discrimination or participating in an investigation.

Example of Violation:

An employee files an EEOC complaint about gender discrimination. Two weeks later, she receives her first-ever negative performance review and is denied a promotion she was previously promised.

Why it's illegal: Retaliation is independently illegal, even if the underlying discrimination claim is not proven.

The EEOC Process Процесс EEOC

Understanding the EEOC complaint process is essential for HR professionals:

Step-by-Step EEOC Charge Process:
  1. Employee Files Charge
    • Must file within 180 days of incident (300 days in states with their own agency)
    • Can file online, by mail, or in person
    • Employee describes alleged discrimination
  2. EEOC Notifies Employer
    • Employer receives copy of charge within 10 days
    • Employer has 30 days to submit Position Statement
  3. Investigation
    • EEOC may request documents, interview witnesses, visit worksite
    • Can take 6 months to 2+ years
    • Mediation may be offered
  4. EEOC Determination
    • Cause Finding: EEOC believes discrimination occurred
    • No Cause Finding: EEOC doesn't find sufficient evidence
    • No Determination: EEOC closes without conclusion
  5. Right to Sue Letter
    • Employee receives letter allowing them to file lawsuit
    • Can be issued at various points in process
    • Employee has 90 days to file lawsuit after receiving letter
✓ Best Practices When Receiving an EEOC Charge:
  • ✓ Take it seriously—do NOT ignore
  • ✓ Immediately consult legal counsel
  • ✓ Preserve all relevant documents
  • ✓ Do NOT retaliate against the employee
  • ✓ Do NOT destroy evidence or delete emails
  • ✓ Conduct thorough internal investigation
  • ✓ Prepare detailed Position Statement with evidence
  • ✓ Consider mediation if appropriate
  • ✓ Train managers on retaliation prevention
Potential Costs of EEOC Violations:
  • Back pay: Lost wages from date of violation to present
  • Front pay: Future lost wages if reinstatement not feasible
  • Compensatory damages: Emotional distress, medical expenses
  • Punitive damages: Up to $300,000 per claimant (depending on employer size)
  • Attorney's fees: Can exceed actual damages
  • Legal defense costs: $50,000-$200,000+ even if employer wins
  • Reputational damage: Public settlements, media coverage
  • Injunctive relief: Required policy changes, training, monitoring

3. Title VII of the Civil Rights Act Раздел VII Закона о гражданских правах

Overview of Title VII

Title VII of the Civil Rights Act of 1964 is the cornerstone of US anti-discrimination law. It was passed during the Civil Rights Movement and represents a fundamental shift in American employment practices.

Title VII Prohibits Discrimination Based On:
  • Race Раса
  • Color Цвет кожи
  • Religion Религия
  • Sex Пол (including pregnancy, sexual orientation, gender identity)
  • National Origin Национальное происхождение
Applies To:
  • Hiring and firing
  • Compensation and benefits
  • Promotions and demotions
  • Training opportunities
  • Work assignments
  • Discipline
  • Any other term or condition of employment
Historical Context:

Before Title VII, it was legal in the US to:

  • Advertise jobs as "whites only" or "men only"
  • Refuse to hire someone because of their religion
  • Pay women less than men for the same work
  • Segregate employees by race

Title VII made all of these practices illegal and transformed American workplaces.

Race and Color Discrimination Расовая дискриминация и дискриминация по цвету кожи

Race and color are distinct protected classes:

Race Color
Common ancestry, ethnic characteristics Pigmentation, skin tone, complexion
Example: African American, Asian, Caucasian, Native American Example: Light-skinned vs. dark-skinned within same racial group
Recent Developments: CROWN Act Закон CROWN

Multiple states have passed the Creating a Respectful and Open World for Natural Hair (CROWN) Act, which prohibits discrimination based on hairstyles associated with race:

Protected Hairstyles:
  • Braids, locs, twists
  • Afros, bantu knots
  • Natural hair textures
Example of Violation:

An employer's grooming policy states "hair must be straight and professional-looking" and refuses to hire a Black applicant who wears locs.

Why it's illegal: This policy has a disparate impact on Black applicants and targets hairstyles associated with race.

Prohibited Conduct:
  • Racial slurs or "jokes"
  • Displaying Confederate flags or other racially insensitive symbols
  • Asking about race during interviews
  • Steering applicants to certain positions based on race
  • Segregating employees (even if "voluntary")

National Origin Discrimination Дискриминация по национальному происхождению

National origin discrimination is particularly relevant for international HR professionals and immigrant workers.

What's Protected:
  • Ancestry or ethnicity (e.g., Russian, Mexican, Chinese)
  • Physical, cultural, or linguistic characteristics associated with national origin
  • Accent or limited English proficiency (unless it materially interferes with job performance)
  • Citizenship status (in certain circumstances)
  • Marriage or association with someone of a particular national origin
Example of Violation:

A manager tells an employee with a Russian accent, "Speak English properly or don't speak at all. This is America." The employee's accent does not interfere with their ability to perform their job duties.

Why it's illegal: Harassment based on accent/national origin, creating hostile work environment.

Permissible Conduct:

An employer requires English fluency for a customer service role where clear communication is essential. The requirement is applied equally to all applicants and is job-related.

Why it's legal: Business necessity; the requirement is directly related to essential job functions.

English-Only Rules Правила "только английский язык"

Religious Discrimination & Accommodation Религиозная дискриминация и приспособление

Religious discrimination has unique requirements under Title VII, including a duty to accommodate.

What's Protected:
  • All aspects of religious observance, practice, and belief
  • Sincerely held religious beliefs (traditional and non-traditional)
  • Moral or ethical beliefs held with sincerity of religious views
Duty to Accommodate Обязанность по приспособлению

Employers must provide reasonable accommodation for religious beliefs unless it would cause undue hardship.

Common Accommodations Examples
Schedule Changes • Time off for Sabbath observance
• Breaks for prayer
• Avoiding work on holy days
Dress/Grooming • Hijabs, turbans, yarmulkes
• Religious jewelry (crosses, etc.)
• Beards, uncut hair
Job Duties • Exemption from certain tasks
• Swap assignments with coworkers
• Lateral transfer
Workplace Environment • Private space for prayer
• Accommodation for religious dietary needs
• Opt-out from company events with religious elements
Example of Proper Accommodation:

An employee who observes the Sabbath from Friday evening to Saturday evening requests not to work during those hours. The employer adjusts the schedule so the employee works Sunday through Thursday instead.

Why it's compliant: Reasonable accommodation provided without undue hardship.

Example of Violation:

An employer has a "no hats" policy for customer-facing employees. A Sikh employee requests to wear a turban as part of his religious practice. The employer refuses, saying "no exceptions to the policy."

Why it's illegal: Failure to provide reasonable religious accommodation; company image preference is not undue hardship.

Sex Discrimination Дискриминация по признаку пола

Sex discrimination under Title VII has expanded significantly since 1964 and now includes:

  • Gender/sex (male, female)
  • Pregnancy, childbirth, and related conditions
  • Sexual orientation (as of Bostock v. Clayton County, 2020)
  • Gender identity/transgender status (as of Bostock v. Clayton County, 2020)
Common Forms of Sex Discrimination:
Stereotyping:

"We need a man for this physically demanding role" or "Women are better at nurturing, so they're better for childcare positions."

Why it's illegal: Sex-based stereotypes, even if statistically accurate on average, cannot be applied to individuals.

Pregnancy Discrimination:

An employer doesn't hire an obviously pregnant applicant, thinking "She'll just go on leave immediately anyway."

Why it's illegal: Pregnancy Discrimination Act requires treating pregnancy the same as any other temporary medical condition.

LGBTQ+ Discrimination:

An employee transitions from male to female. The employer terminates her employment, saying customers will be "uncomfortable."

Why it's illegal: Discrimination based on gender identity is sex discrimination (Bostock decision).

Pregnancy Accommodation Приспособление беременности

The Pregnant Workers Fairness Act (PWFA), effective June 2023, requires employers to provide reasonable accommodations for pregnancy, childbirth, and related conditions:

Examples of Required Accommodations:
  • Additional bathroom breaks
  • Seating or ability to sit while working
  • Temporary reassignment of duties (e.g., no heavy lifting)
  • Schedule changes for prenatal appointments
  • Temporary leave for recovery from childbirth

Sexual Harassment Сексуальное домогательство

Sexual harassment is a form of sex discrimination. There are two types:

1. Quid Pro Quo "Услуга за услугу"

When job benefits are conditioned on sexual favors.

Example:

A supervisor tells an employee, "Go out with me this weekend, or I'll make sure you don't get that promotion."

Why it's illegal: Classic quid pro quo harassment; employer is automatically liable.

2. Hostile Work Environment Враждебная рабочая среда

Unwelcome sexual conduct that is severe or pervasive enough to create an abusive work environment.

Example:

Coworkers regularly make sexual jokes, display pornographic images on their computers, and make comments about female employees' bodies. Management is aware but does nothing.

Why it's illegal: Creates hostile work environment; employer knew or should have known and failed to act.

What Constitutes Sexual Harassment:
  • Unwanted sexual advances or requests for sexual favors
  • Sexual jokes, comments, or innuendos
  • Displaying sexually explicit materials
  • Unwanted touching or physical contact
  • Comments about someone's body or appearance
  • Questions about sexual activity or preferences
✓ Sexual Harassment Prevention Requirements:
  • ✓ Written anti-harassment policy
  • ✓ Multiple reporting channels
  • ✓ Regular training (often required by state law)
  • ✓ Prompt investigation of complaints
  • ✓ Appropriate discipline for harassers
  • ✓ Protection against retaliation
  • ✓ Documentation of all steps taken
Recent High-Profile Title VII Settlements:
  • $175 million - Sexual harassment class action (agriculture industry)
  • $54 million - Race discrimination class action (retail)
  • $20 million - Pregnancy discrimination (manufacturing)
  • $14 million - Religious discrimination (healthcare)

These cases demonstrate that Title VII violations can result in massive liability.

4. Americans with Disabilities Act (ADA) Закон об американцах с ограниченными возможностями

Overview of the ADA

The Americans with Disabilities Act (ADA), passed in 1990, is one of the most comprehensive civil rights laws in the United States. Title I of the ADA prohibits disability discrimination in employment.

Key Provisions:
  • Prohibits discrimination against qualified individuals with disabilities
  • Requires reasonable accommodation for disabilities
  • Prohibits medical inquiries and examinations (with exceptions)
  • Applies to employers with 15+ employees
Comparison with Russian Law:

Russia: The Federal Law "On Social Protection of Disabled Persons in the Russian Federation" (Федеральный закон "О социальной защите инвалидов в Российской Федерации") provides some employment protections, but:

  • Requires formal disability classification by Medical-Social Examination (MSE)
  • Quota system for hiring disabled workers (2-4% of workforce)
  • Less emphasis on "reasonable accommodation"
  • Narrower definition of disability

US ADA: Much broader definition of disability, stronger accommodation requirements, no quota system, protects people with past disabilities or perceived disabilities.

Definition of Disability Определение инвалидности

The ADA has a very broad definition of disability. A person has a disability if they have:

  1. A physical or mental impairment that substantially limits one or more major life activities
  2. A record of such an impairment (history of disability)
  3. Is regarded as having such an impairment (perceived as disabled)
Major Life Activities Основные жизненные функции

Include, but are not limited to:

  • Caring for oneself, performing manual tasks, seeing, hearing, eating, sleeping, walking, standing, lifting, bending
  • Communicating, breathing, learning, reading, concentrating, thinking
  • Working, interacting with others
  • Major bodily functions: Immune system, normal cell growth, digestive, bowel, bladder, neurological, brain, respiratory, circulatory, endocrine, reproductive functions
Examples of Disabilities Covered:
Category Examples
Physical Disabilities Blindness, deafness, mobility impairments, cerebral palsy, multiple sclerosis, epilepsy, HIV/AIDS, cancer, diabetes
Mental/Psychological Depression, anxiety disorders, PTSD, bipolar disorder, schizophrenia, intellectual disabilities
Learning Disabilities Dyslexia, ADHD, autism spectrum disorder
Chronic Illnesses Lupus, Crohn's disease, heart disease, chronic pain conditions
Conditions NOT Covered by ADA:
  • Current illegal drug use (past addiction IS covered)
  • Homosexuality or bisexuality (covered under Title VII instead)
  • Gender identity disorders (covered under Title VII instead)
  • Temporary, minor injuries (e.g., broken leg that heals normally)
  • Common personality traits (e.g., poor judgment, quick temper)
  • Compulsive gambling, kleptomania, pyromania

Qualified Individual Квалифицированное лицо

The ADA only protects "qualified individuals with disabilities." A qualified individual is someone who:

  1. Meets the legitimate skill, experience, education, or other requirements of the position
  2. Can perform the essential functions of the job, with or without reasonable accommodation
Essential Functions Основные функции

These are the fundamental job duties—the reason the position exists.

Example:

Position: Truck Driver
Essential Function: Driving a truck safely
Marginal Function: Loading/unloading cargo (could potentially be reassigned)

An applicant who is blind cannot be a truck driver because they cannot perform the essential function of driving, even with accommodation.

Example of Violation:

Position: Office Administrator
An employer refuses to hire a qualified applicant who uses a wheelchair because the position "requires walking to deliver mail to other offices." However, mail delivery is a marginal function that could be reassigned to another employee.

Why it's illegal: Employer must consider reasonable accommodation (reassigning marginal function).

✓ Best Practice: Job Descriptions
  • ✓ Clearly identify essential functions vs. marginal functions
  • ✓ Base essential functions on actual job requirements, not assumptions
  • ✓ Include physical requirements if truly necessary (e.g., "lift 50 lbs")
  • ✓ Review and update regularly
  • ✓ Have employees acknowledge receipt
  • ✓ Use job descriptions consistently in hiring/performance management

Reasonable Accommodation Разумное приспособление

The centerpiece of the ADA is the requirement that employers provide reasonable accommodation to qualified individuals with disabilities, unless doing so would cause undue hardship.

Types of Reasonable Accommodations:
Category Examples
Modifications to Work Environment • Installing ramps, widening doorways
• Adjustable desks, ergonomic chairs
• Reserved parking space
• Improved lighting
Assistive Technology • Screen readers for blind employees
• Voice recognition software
• TTY devices for deaf employees
• Specialized keyboards or mice
Schedule Modifications • Flexible work hours
• Part-time schedule
• Additional breaks
• Leave for medical treatment
Job Restructuring • Reassigning marginal functions
• Changing how tasks are performed
• Breaking down complex tasks
• Modifying training methods
Policy Modifications • Allowing service animals
• Modifying "no food/drink" policies for diabetics
• Changing attendance policies
• Remote work arrangements
Reassignment • Transfer to vacant position (last resort)
• Must be to equivalent position if available
• No requirement to create new positions
• No requirement to bump other employees

The Interactive Process Интерактивный процесс

The ADA requires an interactive process between employer and employee to determine appropriate accommodation. This is a flexible, informal dialogue.

Steps in the Interactive Process:
  1. Recognition of Need
    • Employee requests accommodation, OR
    • Employer observes need for accommodation
    • Request can be verbal or written; no "magic words" required
  2. Gather Information
    • Identify the limitations created by the disability
    • Request medical documentation if disability not obvious
    • Understand essential functions of the job
  3. Explore Accommodations
    • Discuss possible accommodations with employee
    • Consider employee's preference (but not bound by it)
    • Consult JAN (Job Accommodation Network) for ideas
    • Research costs and feasibility
  4. Choose and Implement
    • Select effective accommodation
    • Document decision and reasons
    • Implement promptly
    • Train affected employees if necessary
  5. Monitor and Adjust
    • Check if accommodation is working
    • Be open to modifications
    • Continue dialogue as situation evolves
Example of Proper Interactive Process:

An employee with depression tells her supervisor, "I'm having trouble concentrating and getting to work on time due to my medication side effects."

Employer's Response:

  1. Recognizes this as a request for accommodation
  2. Requests medical documentation confirming limitation
  3. Meets with employee to discuss options: flexible start time, work-from-home 2 days/week, or modified schedule
  4. Agrees to flexible start time (9-10am arrival window) for 90-day trial
  5. Documents the accommodation in writing
  6. Checks in after 30 days to see if it's effective
Example of Violation:

An employee with a back injury requests a standing desk. The employer immediately responds, "We don't have the budget for that. Request denied." No discussion of alternatives, no consideration of low-cost options, no exploration of the employee's needs.

Why it's illegal: Failure to engage in interactive process; didn't explore alternatives (e.g., desktop riser costs $50-100).

Undue Hardship Чрезмерные трудности

Employers are NOT required to provide accommodation if it would cause undue hardship—significant difficulty or expense.

Factors to Determine Undue Hardship:
  • Nature and cost of accommodation
  • Overall financial resources of the facility
  • Number of employees at facility
  • Effect on expenses and resources
  • Impact on facility operations
  • Overall financial resources of employer (all facilities)
  • Type of operation, including composition and structure of workforce
Example of Valid Undue Hardship:

A small nonprofit with 18 employees and an annual budget of $500,000 receives a request for a $75,000 specialized vehicle to accommodate an employee's wheelchair. This represents 15% of the organization's entire budget.

Why it's undue hardship: Significant expense relative to employer's financial resources and size.

Example NOT Undue Hardship:

A Fortune 500 company with billions in revenue denies an accommodation that costs $5,000, claiming "We can't afford it" and "It's not in our budget."

Why it's NOT undue hardship: Cost is insignificant relative to employer's resources; budget constraints alone are insufficient.

Medical Examinations and Inquiries Медицинские осмотры и запросы

The ADA strictly limits when employers can make disability-related inquiries or require medical examinations:

Stage What's Allowed What's Prohibited
Pre-Offer
(Application/Interview)
✓ Ask about ability to perform job functions
✓ Ask applicant to describe/demonstrate how they would perform functions
✓ Conditional job offers
✗ Ask if applicant has a disability
✗ Ask about nature or severity of disability
✗ Require medical examination
✗ Ask about workers' comp history
✗ Ask about prescription medications
Post-Offer
(Before Employment Starts)
✓ Require medical examination
✓ Ask disability-related questions
✓ Condition offer on exam results
(Must be required of ALL entering employees in same job category)
✗ Use information to discriminate
✗ Withdraw offer unless job-related and consistent with business necessity
During Employment ✓ Medical exam if job-related and consistent with business necessity
✓ Voluntary wellness programs
✓ Inquiries related to accommodation request
✓ Fitness-for-duty exams (if job-related)
✗ General health inquiries
✗ Disability-related questions (unless job-related)
✗ Sharing medical info with non-need-to-know personnel
Common Mistake - Interview Questions:

ILLEGAL: "Do you have any disabilities?" or "Have you ever been treated for mental health issues?"

LEGAL: "Can you perform the essential functions of this job, with or without reasonable accommodation?"

Confidentiality Requirements Требования конфиденциальности
ADA Violation Penalties:
  • Back pay and front pay: Lost wages and benefits
  • Compensatory damages: Pain, suffering, emotional distress, medical costs
  • Punitive damages: Up to $300,000 per claimant (depending on employer size)
  • Injunctive relief: Required accommodations, policy changes, training
  • Attorney's fees: Often exceed actual damages

Notable Recent Settlements:

  • $75 million - Failure to accommodate deaf employees (communications company)
  • $50 million - Disability discrimination class action (retail)
  • $15 million - Failure to accommodate mental health conditions (logistics)

5. Age Discrimination in Employment Act (ADEA) Закон о возрастной дискриминации при найме

Overview of ADEA

The Age Discrimination in Employment Act (ADEA), passed in 1967, protects workers age 40 and older from age-based discrimination.

Key Points:
  • Protects individuals 40 years of age and older
  • Applies to employers with 20+ employees
  • Covers hiring, firing, promotion, compensation, benefits, and all terms/conditions of employment
  • Also covers apprenticeship programs and employment agencies
Comparison with Russian Law:

Russia: Article 3 of the Labor Code prohibits age discrimination for all ages, but enforcement is limited. Mandatory retirement ages exist for certain professions. Age-based job postings were common until recent years.

United States: Strong enforcement of ADEA; age-based job postings are illegal; mandatory retirement is prohibited for most jobs.

What Constitutes Age Discrimination? Что представляет собой возрастную дискриминацию?

Common Forms of Age Discrimination:
1. Biased Job Postings:

A job posting seeks "recent college graduates," "digital natives," or "high-energy young professionals."

Why it's illegal: Code words that discourage older workers from applying.

2. Stereotyping in Hiring/Promotion:

A hiring manager states, "We need someone who can grow with the company" or "We're looking for fresh thinking" to justify rejecting a 60-year-old candidate.

Why it's illegal: Age-based assumptions; older workers can also "grow with company" and provide fresh thinking.

3. Targeted Layoffs:

During downsizing, employer selects employees for layoff based on "years to retirement" or proximity to pension eligibility.

Why it's illegal: Directly targeting older workers for termination.

4. Age-Based Comments:

Manager frequently tells 55-year-old employee, "Maybe it's time to retire and make room for younger blood," or "Can you keep up with the millennials?"

Why it's illegal: Age-based harassment creating hostile work environment.

5. Denial of Training:

Employer provides professional development opportunities to younger employees but tells older employees "it's not worth the investment at your age."

Why it's illegal: Age-based denial of benefits/opportunities.

Problematic Language to Avoid:
Avoid These Phrases Why They're Problematic
"Overqualified" Often code for "too old"; use specific reasons if not hiring
"Digital native" Implies younger worker; use specific tech skills needed instead
"High energy" / "Dynamic" Can be age-coded; older workers can also be energetic
"Recent graduate" Excludes older applicants; use experience level needed instead
"Young and hungry" Explicitly age-related; illegal in job posting

BFOQ Exception Исключение BFOQ

The ADEA includes a narrow exception for Bona Fide Occupational Qualification (BFOQ). Age can be a BFOQ only when:

  1. Age is reasonably necessary to the normal operation of the business, AND
  2. All or substantially all individuals over the age limit would be unable to perform the job safely and efficiently, OR
  3. It is highly impractical to assess fitness on an individual basis
Valid BFOQ Examples:
  • Mandatory retirement for airline pilots at age 65 (federal regulation, safety concern)
  • Maximum age for hiring police officers/firefighters (some jurisdictions; due to physical demands and pension systems)
  • Actor to play a child (authenticity requirement)

Benefits and the "Equal Cost or Equal Benefit" Rule Льготы и правило "равных затрат или равных льгот"

The ADEA's benefits provisions are complex. General rule: benefits must be equal for all employees, regardless of age.

The "Equal Cost or Equal Benefit" Rule:

For certain benefits (like life insurance) where costs increase with age, employer can either:

  • Provide equal benefits to all employees, OR
  • Spend equal amounts on benefits (which may result in lower benefits for older workers if costs are higher)

Waivers and Releases Отказы от прав

The Older Workers Benefit Protection Act (OWBPA), part of the ADEA, sets strict requirements for waivers of age discrimination claims.

Requirements for Valid Age Discrimination Waiver:
  1. Waiver must be in writing and understandable
  2. Must specifically refer to ADEA rights
  3. Cannot waive future rights or claims
  4. Must be in exchange for valuable consideration (beyond what employee is already entitled to)
  5. Must advise employee to consult an attorney
  6. Must give employee 21 days to consider (individual termination) or 45 days (group termination)
  7. Must give employee 7 days to revoke after signing
Additional Requirements for Group Terminations:

If terminating 2+ employees as part of exit incentive or reduction in force, must provide:

  • Class, unit, or group covered by the program
  • Eligibility factors and time limits
  • Job titles and ages of all individuals eligible or selected
  • Ages of all individuals in same job classification or organizational unit who were NOT eligible or selected
✓ Severance Agreement Checklist for Employees 40+:
  • ✓ Written in plain English, clear and understandable
  • ✓ Specifically mentions "Age Discrimination in Employment Act" and "ADEA"
  • ✓ Provides consideration beyond what employee is already owed
  • ✓ Advises employee to consult attorney
  • ✓ Gives 21 days to consider (or 45 for group)
  • ✓ Gives 7 days to revoke after signing
  • ✓ Includes "tender back" provision (if employee revokes, must return consideration)
  • ✓ If group termination: includes required statistical information
  • ✓ Does NOT waive rights arising after signing date
Common Mistakes with Releases:

Employer gives 55-year-old terminated employee a severance agreement with only 7 days to sign and no revocation period.

Why it's invalid: Doesn't meet OWBPA requirements; waiver is unenforceable; employee can still sue and keep the severance.

ADEA Damages:
  • Back pay: Lost wages from termination to present
  • Front pay: Future lost earnings
  • Liquidated damages: Double damages if violation was "willful" (intentional or reckless)
  • Reinstatement or front pay in lieu of reinstatement
  • Attorney's fees and costs
  • NOTE: ADEA does NOT allow compensatory or punitive damages (unlike Title VII)

Recent High-Profile ADEA Cases:

  • $250 million - Age discrimination class action (technology company)
  • $90 million - Targeted layoffs of older workers (financial services)
  • $11 million - Failure to hire older applicants (retail)

6. Fair Labor Standards Act (FLSA) Закон о справедливых трудовых стандартах

Overview of FLSA

The Fair Labor Standards Act (FLSA), enacted in 1938, establishes minimum wage, overtime pay, recordkeeping, and child labor standards. It is one of the most frequently violated employment laws.

Key Provisions:
  • Minimum Wage: Currently $7.25/hour federal (many states have higher minimums)
  • Overtime: 1.5x regular rate for hours over 40 in a workweek
  • Recordkeeping: Specific requirements for tracking hours
  • Child Labor: Restrictions on employment of minors
  • Coverage: Applies to virtually all employers (enterprise coverage + individual coverage)
Comparison with Russian Law:

Russia: Labor Code sets minimum wage (currently around $200/month), maximum 40-hour workweek, overtime at 1.5x-2x rate, strict regulations on working hours and rest periods.

Key Differences:

  • US has "exempt" employees (no overtime) - Russia has very limited exemptions
  • US overtime is calculated weekly - Russia has daily and weekly limits
  • US allows more flexible scheduling - Russia requires strict time records
  • US minimum wage varies by state - Russia has federal minimum

Exempt vs. Non-Exempt Employees Освобожденные и неосвобожденные работники

The most critical FLSA determination: Is the employee exempt (not entitled to overtime) or non-exempt (entitled to overtime)?

Non-Exempt Employees Exempt Employees
• Must be paid overtime (1.5x) for hours over 40/week
• Can be hourly or salaried
• Must track hours worked
• Entitled to meal/rest breaks (if required by state law)
• Can have pay docked for partial-day absences
• Not entitled to overtime pay
• Must be paid on salary basis
• Must meet salary threshold ($684/week = $35,568/year as of 2024)
• Must meet duties test
• Cannot have pay docked for partial-day absences (with limited exceptions)

White Collar Exemptions - The Three Tests Исключения "белых воротничков"

To qualify for most white-collar exemptions, employees must meet ALL THREE tests:

1. Salary Basis Test Тест на основе оклада

Employee must be paid a predetermined amount each pay period that:

  • Cannot be reduced based on quality or quantity of work
  • Is not subject to reductions for partial-day absences
  • Is guaranteed (except in very limited circumstances)
Salary Basis Violation:

An "exempt" employee's pay is docked $200 because they left 2 hours early on Friday for a doctor's appointment (and their PTO was exhausted).

Why it's illegal: Cannot dock pay for partial-day absences; this destroys the salary basis and the exemption.

2. Salary Level Test Тест уровня оклада

Employee must earn at least the federal minimum, currently:

  • $684 per week ($35,568 annually) for most exemptions
  • $107,432 annually for highly compensated employee exemption
  • Note: These thresholds change periodically - check current DOL guidance
3. Duties Test Тест обязанностей

Employee's primary duties must meet specific criteria for one of the exemptions.

Common FLSA Exemptions Общие исключения FLSA

Executive Exemption Исполнительное исключение

Primary duty must be:

  • Managing the enterprise or a recognized department/subdivision
  • Customarily and regularly directing the work of 2+ full-time employees
  • Authority to hire/fire or recommendations given particular weight
Qualifies: Store manager who supervises 5 employees, creates schedules, conducts performance reviews, makes hiring recommendations, earns $50,000/year salary.
Does NOT Qualify: "Assistant Manager" with title only; spends 90% of time doing same work as hourly employees; supervises 1 part-time employee; no hiring authority. Despite $40,000 salary, this person is non-exempt.
Administrative Exemption Административное исключение

Primary duty must be:

  • Office or non-manual work directly related to management or general business operations
  • Includes exercise of discretion and independent judgment on significant matters
Qualifies: HR Manager who develops policies, makes independent decisions on employee relations issues, conducts investigations, earns $60,000/year.
Does NOT Qualify: "Executive Assistant" who primarily schedules meetings, makes travel arrangements, and performs clerical tasks, even if earning $45,000 salary. No discretion on significant matters.
Professional Exemption Профессиональное исключение

Learned Professional:

  • Work requires advanced knowledge (intellectual, requiring exercise of discretion and judgment)
  • In field of science or learning
  • Acquired through prolonged specialized intellectual instruction (typically requires degree)
Qualifies: Engineers, lawyers, doctors, accountants (CPA), teachers, scientists

Creative Professional:

  • Primary duty requires invention, imagination, originality, or talent
  • In a recognized field of artistic or creative endeavor
Qualifies: Graphic designers, writers, musicians, actors (performing original work)
Computer Employee Exemption Исключение для компьютерных работников

Primary duty must involve:

  • Application of systems analysis techniques and procedures
  • Design, development, documentation, analysis, creation, testing or modification of computer systems or programs
  • Must earn $684/week salary OR $27.63/hour (if hourly)
Qualifies: Software engineers, systems analysts, programmers doing systems design
Does NOT Qualify: Help desk support, computer repair technicians, employees who use computers but don't design/develop systems
Outside Sales Exemption Исключение для внешних продаж

Primary duty must be:

  • Making sales or obtaining orders/contracts
  • Customarily and regularly away from employer's place of business
  • No salary requirement for this exemption

Common FLSA Violations Распространенные нарушения FLSA

1. Misclassification as Exempt
Example: Employer classifies all "managers" as exempt, even though they spend 95% of time doing the same work as hourly employees and have no real management authority.

Why it's illegal: Job title doesn't determine exemption; must meet duties test.

2. Off-the-Clock Work
Example: Requiring employees to arrive 15 minutes early to set up, but not paying for that time. Or requiring employees to answer emails/calls after hours without compensation.

Why it's illegal: All time "suffered or permitted to work" must be compensated.

3. Unpaid Breaks
Example: Requiring employees to take 30-minute lunch break, but they must remain at desk and answer phones if needed.

Why it's illegal: If employee is not completely relieved of duties, break is compensable.

4. Improper Deductions from Salary
Example: Docking an exempt employee's pay for leaving 3 hours early for a personal appointment.

Why it's illegal: Destroys salary basis; employee becomes non-exempt and entitled to overtime.

5. Failing to Include All Compensation in Overtime Rate
Example: Employee earns $15/hour plus $100/week production bonus. Employer calculates overtime at $22.50 (1.5 x $15) but doesn't factor in the bonus.

Why it's illegal: "Regular rate" for overtime must include non-discretionary bonuses.

6. Comp Time (Private Sector)
Example: Employee works 50 hours one week. Employer says "take 10 hours off next week instead of paying overtime."

Why it's illegal: Comp time in lieu of overtime is ILLEGAL in private sector (allowed in public sector with restrictions).

7. Independent Contractor Misclassification
Example: Employer classifies full-time workers as "1099 contractors" to avoid paying overtime and benefits, but controls their schedule, provides equipment, and supervises their work.

Why it's illegal: These are employees under FLSA economic reality test.

Recordkeeping Requirements Требования к ведению учета

FLSA requires employers to maintain specific records for ALL employees (exempt and non-exempt):

Required Records:
  • Employee's full name and social security number
  • Address, including zip code
  • Birth date (if under 19)
  • Sex and occupation
  • Time and day of week when employee's workweek begins
  • Hours worked each day and total hours worked each workweek
  • Basis on which wages paid (hourly, weekly, piecework, etc.)
  • Regular hourly pay rate
  • Total daily or weekly straight-time earnings
  • Total overtime earnings for the workweek
  • All additions/deductions from wages
  • Total wages paid each pay period
  • Date of payment and pay period covered
Retention Period:
  • Payroll records: 3 years
  • Time cards: 2 years
  • Employment contracts: Duration of contract + 2 years
✓ FLSA Compliance Checklist:
  • ✓ Accurately classify all employees as exempt or non-exempt
  • ✓ Pay at least minimum wage (federal + state, whichever is higher)
  • ✓ Pay overtime at 1.5x regular rate for non-exempt employees
  • ✓ Track all hours worked by non-exempt employees
  • ✓ Include all compensation in regular rate calculation
  • ✓ Do not make improper deductions from exempt employees' salaries
  • ✓ Pay for all "off-the-clock" work
  • ✓ Maintain required records for required retention periods
  • ✓ Post required FLSA notice in workplace
  • ✓ Regularly audit classifications and pay practices
FLSA Violation Penalties:
  • Back wages: Unpaid minimum wage and overtime (2-3 year lookback)
  • Liquidated damages: Equal to back wages (automatic unless employer proves "good faith")
  • Attorney's fees: Employer must pay if employee prevails
  • Civil penalties: Up to $2,000+ per violation
  • Criminal penalties: Up to $10,000 fine and/or imprisonment for willful violations

Recent Major FLSA Settlements:

  • $100 million - Misclassification class action (retail)
  • $40 million - Off-the-clock work (hospitality)
  • $30 million - Unpaid overtime (technology)

FLSA violations can result in massive collective actions with hundreds or thousands of employees.

7. Family and Medical Leave Act (FMLA) Закон об отпуске по семейным и медицинским обстоятельствам

Overview of FMLA

The Family and Medical Leave Act (FMLA), enacted in 1993, requires covered employers to provide unpaid, job-protected leave for specific family and medical reasons.

Key Points:
  • Up to 12 weeks of unpaid leave in 12-month period
  • 26 weeks for military caregiver leave
  • Applies to employers with 50+ employees (within 75-mile radius)
  • Employees must meet eligibility requirements
  • Job protection and benefits continuation required
Comparison with Russian Law:

Russia: Labor Code provides extensive paid leave:

  • Maternity leave: 140 days at 100% salary (70 before birth, 70 after)
  • Child care leave: Up to 3 years (partially paid)
  • Sick leave: Paid based on length of service
  • Strong job protection during leave

US FMLA: Leave is UNPAID (though employees can use accrued paid time off). This is shocking to many international HR professionals, but reflects US approach to minimal statutory benefits.

Eligibility Requirements Требования к участию

Employer Coverage:
  • Private sector: 50+ employees for 20+ weeks in current or preceding year
  • Public agencies: All (regardless of size)
  • Schools: All (regardless of size)
Employee Eligibility (ALL must be met):
  1. Worked for employer for at least 12 months (need not be consecutive)
  2. Worked at least 1,250 hours in the 12 months before leave
  3. Works at a location with 50+ employees within 75 miles
Example - Eligible:

Employee has worked full-time (40 hours/week) for 18 months at a location with 75 employees. Requests FMLA leave for birth of child.

Result: Eligible for 12 weeks FMLA leave.

Example - Not Eligible:

Employee has worked for 14 months but only works 20 hours/week (1,040 hours/year). Requests FMLA leave.

Result: Not eligible; doesn't meet 1,250-hour requirement.

Qualifying Reasons for FMLA Leave Квалифицирующие причины для отпуска FMLA

Reason Details Duration
Birth/Care of Child Birth and bonding with newborn child 12 weeks (must be taken within 1 year of birth)
Adoption/Foster Care Placement of child for adoption or foster care 12 weeks (must be taken within 1 year of placement)
Serious Health Condition (Self) Employee's own serious health condition that makes them unable to work 12 weeks
Serious Health Condition (Family) Care for spouse, child, or parent with serious health condition 12 weeks
Military Caregiver Care for covered military servicemember with serious injury/illness 26 weeks in single 12-month period
Qualifying Exigency Military family leave when family member deployed 12 weeks
What is a "Serious Health Condition"? Что такое "серьезное состояние здоровья"?

An illness, injury, impairment, or physical/mental condition involving:

  • Inpatient care (overnight stay in hospital or medical facility), OR
  • Continuing treatment by a healthcare provider, including:
    • Incapacity for more than 3 consecutive days + 2 visits to healthcare provider (or 1 visit + continuing regimen of treatment)
    • Pregnancy/prenatal care
    • Chronic conditions requiring periodic visits (e.g., diabetes, asthma, epilepsy)
    • Permanent/long-term conditions (e.g., Alzheimer's, terminal cancer)
    • Conditions requiring multiple treatments (e.g., chemotherapy, physical therapy for severe injury)
Examples of Serious Health Conditions:
  • Cancer requiring chemotherapy
  • Heart attack with hospital stay
  • Pregnancy complications
  • Back surgery with recovery
  • Severe depression requiring ongoing treatment
  • Flu with complications requiring 4 days absence + 2 doctor visits
NOT Serious Health Conditions:
  • Common cold or flu (if uncomplicated and brief)
  • Routine physical exam
  • Cosmetic treatments (unless complications)
  • Minor injuries (unless complications)

Employee Rights Under FMLA Права работника в соответствии с FMLA

1. Job Protection Защита работы

Employee must be restored to:

  • Same position, OR
  • Equivalent position (same pay, benefits, terms/conditions)
2. Benefits Continuation Продолжение льгот
  • Group health insurance must be maintained during leave
  • Employer pays same share of premium as before leave
  • Employee pays their share (can prepay or pay when due)
3. Intermittent/Reduced Schedule Leave Прерывистый отпуск

For medical conditions, leave can be taken:

  • In separate blocks of time (e.g., one day per week for treatment)
  • By reducing daily or weekly schedule (e.g., working 4 hours instead of 8)
  • As needed for chronic conditions (e.g., migraine flare-ups)
Example of Intermittent Leave:

Employee with rheumatoid arthritis needs unpredictable time off for flare-ups. Certified for intermittent FMLA. Takes 2 days in January, 1 day in February, 4 days in March, etc. Each day counts against 12-week entitlement.

4. No Retaliation Отсутствие ответных мер

It is illegal to:

  • Discourage employee from using FMLA
  • Retaliate for using FMLA
  • Use FMLA leave as negative factor in employment decisions

Employer Requirements Требования работодателя

1. Notice to Employees
  • Post FMLA notice in workplace
  • Include FMLA information in employee handbook
  • Provide written notice of eligibility within 5 days of learning of potential FMLA need
  • Provide rights and responsibilities notice
2. Medical Certification

Employers may require certification from healthcare provider:

  • Use DOL optional form or substantially similar form
  • Can require recertification every 30 days for ongoing conditions
  • Can request second opinion (at employer's expense)
  • Cannot contact employee's healthcare provider directly
3. Designation as FMLA Leave
  • Notify employee within 5 days whether leave will be designated as FMLA
  • Count leave against 12-week entitlement
  • Cannot retroactively designate after return to work
4. Tracking Leave
  • Choose 12-month period method (calendar year, rolling, etc.)
  • Track intermittent leave in smallest increment (hourly if hourly employee)
  • Maintain records for 3 years
✓ FMLA Administration Checklist:
  • ✓ Post required FMLA notice
  • ✓ Include FMLA information in handbook
  • ✓ Train supervisors to recognize potential FMLA situations
  • ✓ Provide eligibility notice within 5 days
  • ✓ Provide rights & responsibilities notice
  • ✓ Request medical certification (if appropriate)
  • ✓ Designate leave as FMLA within 5 days
  • ✓ Continue health benefits
  • ✓ Track leave usage
  • ✓ Restore employee to same/equivalent position
  • ✓ Do NOT retaliate
  • ✓ Maintain confidentiality of medical information

Common FMLA Violations Распространенные нарушения FMLA

1. Interference with Rights:

Manager tells employee, "If you take FMLA leave, I can't guarantee your position will be here when you return."

Why it's illegal: Discouraging use of FMLA; interfering with employee's rights.

2. Retaliation:

Employee returns from FMLA leave for cancer treatment. Within two weeks, receives first-ever negative performance review and is terminated.

Why it's illegal: Timing suggests retaliation for using FMLA; employer must show legitimate reason.

3. Failure to Restore to Equivalent Position:

Employee returns from FMLA and is placed in position with same title/pay but significantly worse shift (nights instead of days).

Why it's illegal: Position not "equivalent" if terms/conditions substantially different.

4. Counting FMLA as Attendance Violation:

Employer's attendance policy includes FMLA absences when calculating points toward termination.

Why it's illegal: Cannot use FMLA leave as negative factor in employment decisions.

5. Failure to Provide Required Notices:

Employee requests leave for surgery. Employer approves "medical leave" but never provides FMLA eligibility notice or designation notice.

Why it's illegal: Employer must provide required notices even if employee doesn't specifically mention "FMLA."

FMLA Violation Penalties:
  • Damages: Lost wages, benefits, other compensation
  • Liquidated damages: Equal to actual damages (unless employer proves good faith)
  • Reinstatement or front pay
  • Equitable relief: Promotion, restoration of leave time
  • Attorney's fees and costs
  • Civil penalties: Up to $180+ per violation (willful/repeat violations)

8. Occupational Safety and Health Act (OSHA) Закон о безопасности и гигиене труда

Overview of OSHA

The Occupational Safety and Health Act, enacted in 1970, ensures safe and healthful working conditions. OSHA (the agency) enforces the Act.

Coverage:
  • Applies to virtually all private sector employers
  • No minimum number of employees
  • Some states have their own OSHA-approved plans
General Duty Clause:

Employers must provide a workplace "free from recognized hazards that are causing or likely to cause death or serious physical harm."

Key OSHA Requirements Основные требования OSHA

1. Recordkeeping Ведение записей

Employers with 11+ employees must:

  • Maintain OSHA Form 300 (Log of Work-Related Injuries and Illnesses)
  • OSHA Form 301 (Injury and Illness Incident Report)
  • OSHA Form 300A (Summary—post annually February 1 - April 30)
  • Retain records for 5 years
2. Reporting Отчетность
  • 8 hours: Report all work-related fatalities
  • 24 hours: Report all work-related inpatient hospitalizations, amputations, or loss of an eye
3. Posting Размещение
  • OSHA "Job Safety and Health—It's the Law" poster
  • OSHA citations (if any)
  • Annual summary (Form 300A)
4. Training Обучение

Various OSHA standards require specific training:

  • Hazard Communication (chemical safety)
  • Personal Protective Equipment (PPE)
  • Bloodborne Pathogens (healthcare)
  • Powered Industrial Trucks (forklifts)
  • Lockout/Tagout (equipment maintenance)

OSHA Inspections Инспекции OSHA

OSHA can conduct workplace inspections with or without advance notice.

Inspection Priorities:
  1. Imminent danger situations
  2. Fatalities and catastrophes
  3. Worker complaints
  4. Targeted inspections (high-hazard industries)
  5. Follow-up inspections
✓ What to Do During OSHA Inspection:
  • ✓ Ask for credentials
  • ✓ Determine reason for inspection
  • ✓ Contact legal counsel immediately
  • ✓ Designate management representative to accompany inspector
  • ✓ Allow employee representative to participate
  • ✓ Take your own photos/notes
  • ✓ Do NOT volunteer information
  • ✓ Review citations carefully—you have right to contest
OSHA Penalties (Increased regularly for inflation):
  • Other-than-Serious: Up to $15,625 per violation
  • Serious: Up to $15,625 per violation
  • Willful: $10,986 to $156,259 per violation
  • Repeat: Up to $156,259 per violation
  • Failure to Abate: Up to $15,625 per day beyond abatement date
  • Criminal: Willful violation causing death can result in imprisonment

9. Background Checks & FCRA Проверка биографических данных и FCRA

Fair Credit Reporting Act (FCRA)

The Fair Credit Reporting Act (FCRA) regulates how employers use background checks and consumer reports in employment decisions.

When FCRA Applies:

FCRA applies when employers use a consumer reporting agency (CRA)—a third party—to obtain background information. This includes:

  • Credit reports
  • Criminal background checks
  • Employment verification
  • Education verification
  • Driving records

Does NOT apply when employer conducts checks directly (e.g., calling references yourself).

FCRA Requirements Требования FCRA

Step 1: Before Obtaining Report
  1. Provide clear disclosure that a background check will be conducted
    • Must be standalone document (not buried in application)
    • Cannot include liability waivers or other information
  2. Obtain written authorization from applicant/employee
    • Can be electronic
    • Should be separate from disclosure
Step 2: If Taking Adverse Action

If you decide not to hire (or to terminate) based in whole or in part on the background check:

  1. Pre-Adverse Action Notice
    • Provide copy of background check report
    • Provide "Summary of Your Rights Under the FCRA"
    • Give reasonable time to respond (typically 5+ business days)
  2. Wait for Response
    • Allow applicant to dispute inaccuracies
    • Consider any additional information provided
  3. Adverse Action Notice (if proceeding with denial)
    • Inform applicant of final decision
    • Name, address, phone of CRA that provided report
    • Statement that CRA didn't make the decision and can't explain it
    • Notice of right to dispute report's accuracy with CRA
    • Notice of right to free copy of report from CRA within 60 days
Common FCRA Violation:

Employer obtains background check without written authorization, finds arrest record, and immediately rejects applicant without any adverse action notices.

Multiple violations: No authorization, no pre-adverse action notice, no opportunity to respond, no adverse action notice.

Criminal History & "Ban the Box" Laws Уголовное прошлое и законы "запрета на флажок"

Many states and cities have enacted "ban the box" laws that restrict when and how employers can ask about criminal history.

Common "Ban the Box" Requirements:
  • Cannot ask about criminal history on initial application
  • Can only inquire after conditional job offer (in some jurisdictions)
  • Must conduct individualized assessment if considering criminal history
  • Cannot consider arrests that didn't result in conviction
  • Cannot consider expunged or sealed records
  • May be prohibited from considering certain types of convictions (e.g., marijuana in states where now legal)
Individualized Assessment Индивидуальная оценка

When considering criminal history, must evaluate:

  • Nature and gravity of offense
  • Time passed since offense or completion of sentence
  • Nature of the job sought
Proper Use of Criminal History:

Bank conducting background check for teller position discovers applicant has 10-year-old conviction for embezzlement. Bank considers nature of offense (financial crime), relevance to position (handles money), time passed (10 years, no subsequent issues), and applicant's explanation. Decides conviction is relevant to job duties and declines to hire, following FCRA adverse action process.

Improper Use of Criminal History:

Employer has blanket policy: "No one with any felony conviction will be hired, regardless of job or circumstances." Rejects applicant with 20-year-old drug possession conviction for warehouse position.

Why it's illegal: Blanket bans likely violate Title VII (disparate impact) and many state/local laws. Must conduct individualized assessment.

Credit Checks Проверки кредитоспособности

Many states restrict use of credit checks for employment:

FCRA Violation Penalties:
  • Actual damages: For proven harm
  • Statutory damages: $100 to $1,000 per violation for negligent violations
  • Punitive damages: For willful violations
  • Attorney's fees and costs
  • FTC enforcement: Civil penalties up to $51,000+ per violation

Recent major settlement: $13 million for FCRA violations (background check company)

10. I-9 & Work Authorization I-9 и разрешение на работу

Form I-9 Requirements

The Form I-9 (Employment Eligibility Verification) is required for ALL employees hired in the United States, regardless of citizenship status.

Who Must Complete I-9:
  • Every employee hired after November 6, 1986
  • US citizens and non-citizens alike
  • Full-time, part-time, temporary, seasonal—all must have I-9
  • Even if employee works one day
For Russian HR Professionals:

The I-9 requirement is unique to the US and reflects immigration enforcement. Unlike Russia's propiska (registration) system, the I-9 is an employer responsibility, not a government registration.

Penalties for I-9 violations can be severe, and ICE (Immigration and Customs Enforcement) actively audits employers.

I-9 Process Процесс I-9

Section 1: Employee Completes (By First Day of Work)
  • Employee provides personal information
  • Attests to citizenship/immigration status
  • Signs under penalty of perjury
  • Must be completed by end of employee's first day of work
Section 2: Employer Completes (Within 3 Business Days of Start Date)
  • Physically examine employee's original documents
  • Verify documents appear genuine and relate to employee
  • Record document information
  • Sign and date
  • Cannot specify which documents employee must present
Acceptable Documents

Employees must present:

  • List A: Documents that establish both identity AND work authorization (e.g., US passport, Permanent Resident Card), OR
  • List B + List C: One document establishing identity (e.g., driver's license) PLUS one establishing work authorization (e.g., Social Security card)
List A
(Identity + Work Authorization)
List B
(Identity Only)
List C
(Work Authorization Only)
• US Passport
• Permanent Resident Card ("Green Card")
• Employment Authorization Document (EAD)
• Foreign passport with I-551 stamp
• Driver's license
• State ID card
• School ID with photo
• Voter registration card
• Military ID
• Social Security card (unrestricted)
• Birth certificate
• Citizen ID card
• Certain Native American tribal documents
Section 3: Employer Completes for Reverification or Rehires
  • When work authorization expires (e.g., EAD expires)
  • When rehiring within 3 years of original I-9

Common I-9 Violations Распространенные нарушения I-9

1. Missing I-9:

No I-9 form on file for employee.

Penalty: $272 to $2,701 per form (increases regularly)

2. Late Section 2:

Section 2 completed 7 days after employee start date (should be within 3 business days).

Penalty: Procedural violation, fines apply

3. Missing or Incomplete Information:

Employee didn't sign Section 1, or employer didn't record document number.

Penalty: Substantive violation, higher fines if not corrected

4. Document Abuse:

Employer tells employee "We only accept US passports" or "Your EAD is expiring in 6 months, we can't hire you."

Why it's illegal: Citizenship status discrimination under INA

5. Failing to Reverify:

Employee's work authorization expires, employer continues to employ without reverifying.

Why it's illegal: Knowingly employing unauthorized worker; severe penalties

E-Verify E-Verify

E-Verify is an online system that compares I-9 information against government databases to verify work authorization.

Who Must Use E-Verify:
  • Federal contractors (in most cases)
  • Employers in certain states (Alabama, Arizona, Florida, Georgia, Louisiana, Mississippi, North Carolina, South Carolina, Tennessee, Utah, Virginia require for all or certain employers)
  • Voluntary for other employers
E-Verify Process:
  1. Employee completes I-9 Section 1
  2. Employer completes I-9 Section 2
  3. Within 3 business days, employer creates E-Verify case
  4. System checks information against SSA and DHS databases
  5. Result: Employment Authorized, or Tentative Nonconfirmation (TNC)
  6. If TNC, employee has right to contest
I-9/Immigration Penalties:
  • Paperwork violations: $272 to $2,701 per form (for substantive violations)
  • Knowingly hiring unauthorized worker: $676 to $27,018+ per worker
  • Pattern or practice violations: $676 to $27,018 per worker + criminal penalties up to 6 months imprisonment
  • Citizenship discrimination: $281 to $5,620 per violation; $2,810 to $22,439 for subsequent or discriminatory pattern
  • Criminal prosecution: Possible for harboring, fraud, etc.

Recent enforcement: ICE I-9 audits have increased significantly; multi-million dollar settlements common

11. State-Specific Laws Законы штатов

Why State Laws Matter

As discussed earlier, state employment laws can provide greater protection than federal law. Some of the most employee-friendly states include:

  • California - Most comprehensive employment protections
  • New York - Strong anti-discrimination and wage laws
  • Massachusetts - Progressive leave and discrimination laws
  • Washington - Comprehensive paid leave, high minimum wage
  • Oregon - Strong worker protections

California Employment Law Трудовое право Калифорнии

California has the most comprehensive employment laws in the US. Key features:

California Fair Employment and Housing Act (FEHA)
  • Applies to employers with 5+ employees (vs. 15 federal)
  • Protects additional characteristics: marital status, military/veteran status, genetic information, gender identity, gender expression
  • Broader definition of disability than ADA
  • Harassment training mandatory for all employers with 5+ employees
California Wage & Hour Laws
  • Daily overtime: Over 8 hours in a day (not just 40/week)
  • Double time: Over 12 hours in a day, or more than 8 on 7th consecutive day
  • Meal breaks: 30 minutes for every 5 hours worked (must be off-duty)
  • Rest breaks: 10 minutes paid for every 4 hours
  • Pay stub requirements: Detailed itemization required
  • Waiting time penalties: If final paycheck not timely, employee gets full day's pay for each day delayed (up to 30 days)
California Leave Laws
  • Paid sick leave: 40 hours per year (minimum)
  • California Family Rights Act (CFRA): Like FMLA but covers more employers (5+) and broader family definition
  • Pregnancy Disability Leave: Up to 4 months, separate from CFRA
  • Paid Family Leave: State-funded wage replacement for family/medical leave
Other California Requirements
  • Non-compete agreements: Generally unenforceable (with narrow exceptions)
  • Salary history ban: Cannot ask about prior compensation
  • Criminal history: Ban the box (cannot ask until after conditional offer)
  • Cannabis testing: Cannot discriminate based on off-duty marijuana use (with exceptions)

New York Employment Law Трудовое право Нью-Йорка

New York State Human Rights Law (NYSHRL)
  • Applies to all employers (no minimum)
  • Protects: age (18+), race, creed, color, national origin, sexual orientation, gender identity, military status, sex, disability, predisposing genetic characteristics, familial status, marital status, domestic violence victim status
  • Harassment training mandatory (all employers)
New York Wage & Hour
  • Higher minimum wage (varies by region, NYC higher)
  • Strict pay notice requirements
  • Weekly payday requirement for manual workers
  • Wage theft prevention provisions
New York Leave Laws
  • Paid Family Leave: Up to 12 weeks, state-funded
  • Paid sick leave: NYC and other localities require
  • Nursing mothers: Break time and private space required (all employers)

Emerging Trends in State Laws Новые тенденции в законах штатов

1. Salary History Bans Запрет на вопросы о зарплатной истории

Many states/cities prohibit asking about prior salary to address wage gaps:

  • California, Colorado, Connecticut, Delaware, Hawaii, Illinois, Maine, Maryland, Massachusetts, New Jersey, Oregon, Vermont, Washington
  • NYC, Philadelphia, Pittsburgh, and many other cities
2. Marijuana Legalization Легализация марихуаны

States with recreational marijuana are enacting employment protections:

  • Cannot discriminate based on off-duty marijuana use
  • Cannot test for marijuana in pre-employment screening (some states)
  • Exceptions: Safety-sensitive positions, federal contractors
3. Pay Transparency Прозрачность оплаты труда

Growing number of states require salary ranges in job postings:

  • Colorado (2021), California (2023), Washington (2023), New York (2023)
  • Must include compensation range in job postings
  • Aimed at reducing pay gaps
4. Paid Family & Medical Leave Оплачиваемый семейный и медицинский отпуск

States creating paid leave programs (vs. FMLA's unpaid leave):

  • California, Connecticut, Colorado, Delaware, Massachusetts, Maryland, New Jersey, New York, Oregon, Rhode Island, Washington
  • Funded through employee payroll deductions or employer contributions
  • Provide wage replacement (typically 50-90% of wages)
5. Predictive Scheduling Прогнозируемое планирование

Some cities require advance notice of work schedules:

  • Seattle, San Francisco, NYC, Philadelphia, Oregon (statewide)
  • Typically 10-14 days advance notice required
  • Penalties for schedule changes without notice
  • Primarily applies to retail/food service

State Minimum Wages (2024)

Federal minimum wage is $7.25/hour, but many states have higher rates:

State Minimum Wage Notes
Washington $16.28 Highest state minimum wage
California $16.00 Some cities higher (e.g., SF $18.07)
New York $15.00-$16.00 Varies by region; NYC higher
Massachusetts $15.00
Colorado $14.42 Indexed to inflation
Many Southern States $7.25 Federal minimum applies

Note: Rates change annually. Always check current rates.

12. Comparison with Russian Labor Law Сравнение с российским трудовым правом

Fundamental Differences in Legal Philosophy

Understanding the differences between US and Russian employment law helps Russian HR professionals navigate the US system:

Aspect 🇷🇺 Russia 🇺🇸 United States
Legal Structure Single comprehensive Labor Code
Трудовой кодекс РФ
Multiple federal statutes + 50 state laws + local ordinances
Legal System Civil law (code-based) Common law (precedent-based) + statutory law
Employment Relationship Heavily regulated; strong worker protections Employment-at-will; employer flexibility
Termination "Just cause" required (Article 81) At-will (except for illegal reasons)
Notice Period Legally required (2 months for redundancy) Not required (except in limited circumstances)
Severance Pay Mandatory in many cases Not required by law (except WARN Act)
Working Hours 40-hour week maximum; strict daily limits No maximum hours for exempt employees; 40-hour overtime threshold for non-exempt
Overtime 1.5x-2x rate; limited hours; requires employee consent 1.5x rate for non-exempt; no limit on hours; no consent required
Vacation 28 calendar days minimum (paid) No federal requirement; employer discretion
Sick Leave Paid based on length of service and earnings No federal requirement; some states require unpaid (FMLA) or paid sick leave
Maternity Leave 140 days at 100% pay; up to 3 years child care leave 12 weeks unpaid (FMLA); no federal paid leave
Trade Unions Must consult on terminations; collective agreements common Low union membership (10%); limited rights except in unionized workplaces
Written Contracts Required; must include specific terms Not required for at-will employment
Discrimination Law Basic protections in Labor Code; limited enforcement Extensive protections; aggressive enforcement; substantial penalties
Disability Accommodation Limited; quota system for hiring Extensive reasonable accommodation requirement (ADA)
Litigation Risk Labor disputes handled through labor inspectorate and courts; less litigious Highly litigious; contingency fee lawyers; jury trials; class actions

Key Surprises for Russian HR Professionals Ключевые сюрпризы для российских HR-специалистов

1. Minimal Statutory Benefits

Unlike Russia, the US has almost no mandatory benefits:

  • NO mandatory paid vacation
  • NO mandatory paid sick leave (federal)
  • NO mandatory paid maternity leave (federal)
  • NO mandatory severance pay
  • NO maximum working hours

However, many employers provide these voluntarily to attract talent, and some states are beginning to require them.

2. Employment-At-Will is Shocking

The concept that an employer can terminate "for any reason or no reason" is alien to most legal systems. In practice:

  • Employers still fear wrongful termination claims
  • Best practice is to document performance issues
  • Progressive discipline is common (though not required)
  • Most professional employers provide notice/severance as courtesy
3. Anti-Discrimination Law is Much Stronger

While Russia has basic discrimination prohibitions, US enforcement is aggressive:

  • Dedicated federal agency (EEOC)
  • Private right to sue with contingency fee lawyers
  • Substantial damages (including punitive damages)
  • Class action lawsuits
  • Accommodation requirements (religion, disability, pregnancy)
4. Healthcare is Employer-Provided

Unlike Russia's state healthcare system:

  • Most Americans get health insurance through their employer
  • Large employers (50+) must offer health insurance (ACA mandate)
  • Healthcare benefits are a critical part of compensation
  • Very expensive (employer + employee costs can be $20,000+ annually)
5. Complexity and Variation

The lack of a single labor code means:

  • Must track federal + state + local laws
  • Laws change frequently
  • Compliance is extremely complex for multi-state employers
  • Legal counsel is essential

Cultural Differences in Workplace Practices Культурные различия в рабочих практиках

Communication Style
  • US: Direct, informal, first-name basis common even with executives
  • Russia: More formal, hierarchical, use of patronymic names
Work-Life Balance
  • US: Long hours common (especially in professional jobs); "always on" culture; vacation time often not fully used
  • Russia: Defined working hours; longer mandatory vacation; stronger separation of work/personal life
Feedback & Performance Management
  • US: Frequent feedback; annual reviews; emphasis on documentation; "positive framing" of criticism
  • Russia: Less frequent formal feedback; more direct criticism acceptable
Hierarchy & Decision-Making
  • US: Flatter organizations; employee input valued; consensus-building
  • Russia: More hierarchical; top-down decisions

Advice for Russian HR Professionals Working in US

✓ Essential Steps:
  • Invest in training: US employment law is complex; formal training is essential
  • Develop legal relationships: Have employment attorney on retainer
  • Subscribe to compliance services: Laws change frequently; stay updated
  • Document everything: US is litigious; documentation is your best defense
  • Understand "protected characteristics": Very different from Russian law
  • Learn state laws: Don't assume federal law is all you need
  • Embrace at-will with caution: Yes, you have flexibility, but wrongful termination claims are common
  • Prioritize anti-discrimination compliance: This is enforced much more aggressively than in Russia
  • Understand accommodation obligations: ADA and religious accommodation go far beyond Russian requirements
  • Budget for benefits: Healthcare, 401(k), etc. are expected and expensive
  • Join HR professional associations: SHRM (Society for Human Resource Management) is invaluable
  • Adapt communication style: US workplace culture is less formal

Conclusion Заключение

US employment law is vast, complex, and constantly evolving. This chapter has covered the major federal laws and key state law considerations, but it is not exhaustive.

Key Takeaways:
  • Complexity: Multiple layers of law (federal, state, local) create a complex compliance environment
  • Variation: Laws vary significantly by state and even by city
  • Employee-Favorable Trend: Laws increasingly favor employee protection, especially at state level
  • Aggressive Enforcement: EEOC, DOL, state agencies, and private lawsuits create high compliance risk
  • Documentation is Critical: In litigious US environment, thorough documentation is essential
  • Proactive Compliance: Waiting for a lawsuit is too late; invest in prevention
Additional Resources:
  • EEOC: www.eeoc.gov
  • Department of Labor: www.dol.gov
  • SHRM (Society for Human Resource Management): www.shrm.org
  • Job Accommodation Network (ADA resources): askjan.org
  • State labor department websites for state-specific requirements