BEFORE THE SEATTLE OFFICE OF LABOR STANDARDS

 

In re Sky Chefs, Inc. dba LSG Sky Chefs, COMPLIANCE LETTER NO.
Inc. 15MW025

FINDINGS OF FACT,
DETERMINATION, AND
OFFER TO CONFERENCE

 

 

Ju risdiction

Sky Chefs, Inc. dba LSG Sky Chefs, Inc. has employees who perform work in Seattle,
Washington. The violation occurred on April 1, 2015. The compliance letter was filed on
April 23, 2015, within three years of the incident. The Office of Labor Standards (OLS)
has jurisdiction over the matter under the Wage Theft Ordinance - Seattle Municipal
Code (SMC) Chapter 14.20 and Minimum Wage Ordinance - SMC Chapter 14.19
(Ordinances).

FINDINGS OF FACT AND CONCLUSIONS OLLAW
Railway Labor Act

Sky Chefs, Inc. dba LSG Sky Chefs, Inc. admits it did not pay Seattle employees the
minimum wage under SMC 14.19 but asserts the Ordinance is preempted by the
Railway Labor Act (RLA). Accordingly, Sky Chefs, Inc. dba LSG Sky Chefs, Inc. made
the following two arguments.

First, Sky Chefs, Inc. dba LSG Sky Chefs, Inc. argued that its employees are subject to
a collective bargaining agreement (CBA) known as the Master National Agreement
(MNA), which is governed by the RLA.1 The MNA sets forth employee rights with
respect to wages.2 Sky Chefs, Inc. dba LSG Sky Chefs, Inc. asserted that enforcement
of the minimum wage ordinance would require ?significant interpretation" of the MNA.3
Therefore, the Minimum Wage ordinance is preempted by the RLA, and Sky Chefs, Inc.
dba LSG Sky Chefs is not obligated to pay its employees in compliance with the
Ordinance.

 

1 May 11, 2015 Response to Compliance Letter
2 fo?.
3 Id.

 

 

FINDINGS OF FACT, DETERMINATION AND OFFER TO CONFERENCE 
COMPLIANCE LETTER NUMBER 15MW025

 

mmummth?t




 

However, substantive protections provided by state or local laws are not preempted
under the RLA.4 Per the US Supreme Court, the RLA ?does not undertake
governmental regulation of wages, hours or working conditions.? Rather, it seeks to
provide a means by which agreements may be reached with respect to them.5 Likewise,
the Supreme Court of Washington held that the city of SeaTac's ordinance setting the
city?s minimum wage was not preempted by the RLA. 5 Therefore, federal and state
case law establish that SMC 14.19 is not preempted by the RLA.

Second, Sky Chefs, Inc. dba LSG Sky Chefs, Inc. argued that the Minimum Wage
Ordinance did not apply between April 1, 2015 and January 7, 2018 as the result of
conflict preemption because it was engaged in collective bargaining with the
representative of its employees during that time. 7 Per Sky Chefs, Inc. dba LSG Sky
Chefs, Inc., the RLA prohibits employers from unilaterally changing pay rates except in
the manner prescribed under the However, as addressed above, the Washington
State Supreme Court has held regulations like the RLA are designed to ensure an
equitable bargaining process, rather than to regulate the substantive terms that emerge
from such bargaining? Minimum terms of employment, such as minimum wage, form
the backdrop for negotiations and do not interfere with the bargaining process itself.10
Therefore, the RLA did not preempt SMC 14.19 from April 1, 2015 to January 7, 2018.

As there is no legal basis for Sky Chefs, Inc. dba LSG Sky Chefs' argument that SMC
14,19 is preempted by the RLA, Sky Chefs, Inc. dba LSG Sky Chefs is required to pay
its Seattle employees the minimum wage as established by SMC 14.19.

Notice and Posting

Employers shall display the OLS poster in a conspicuous and accessible location where
any of their employees work, in English and in the primary language of the employee(s)
at the workplace. It display of the poster in the workplace is not feasible, employers may
provide the poster on an individual basis or in electronic format that is reasonably
conspicuous and accessible.?

 

4 Filo Foods, LLC v. City of SeaTac, 183 Wn.2d 770, 35? P.3d 1040, 105? (2015) quoting Hawaiian
Airlines, 512 US. at 25?, 114 2239.

5 Fiio Foods, LLC v. City of SeaTac, 183 Wn.2d 7T0, 35? P.3d 1040, 1057 (2015) quoting Terminai RR.
Ass'n of St. Louis v. Bird. of RR. TrainmenCt. 420, 87 5?1 {1943).

?5 Filo Foods, LLC v. City of SeaTac, 183 Wn.2d 770, 357 P.3d 1040 (2015).

7 March 13, 2018 letter from Don Munro

3 id.

?3 Filo Foods quoting Fort Halifax Packing Co. v. Coyne, 482 US. 1, 19?23, 107 2211, 98 L.Ed.2d 1


?0 Filo Foods quoting Hawaiian Aidines, 512 US. at 257, 114 2239 ?Substantive protections
provided by state law, independent ofwhatever labor agreement might govern, are not preempted by the"
RLA.

1? SMC 14.18.045iB}; SMC 1417202503); SNIC 14.19.045iB); SMC 142002503}.

OF FACT, DETERMINATION AND OFFER TO CONFERENCE 2
COMPLIANCE LETTER NUMBER 15MW025

 






 

On September 28, 2016, Sky Chefs, Inc. dba LSG Sky Chefs, Inc. provided 01.8 with a
photo of the 2016 Labor Standards Ordinances poster in its employee breakroom.?

A preponderance of the evidence does not demonstrate that Sky Chefs, Inc. dba LSG
Sky Chefs, Inc. Solutions failed to comply with the notice and posting provision of the
Ordinances.13

Minimum Wage
1. 2015

Effective April 1, 2015 through December 31, 2015, Schedule 1 employers shall pay
each employee an hourly minimum wage of at least $11.00. Schedule 1 employers
have more than 500 employees."4

Sky Chefs, Inc. dba LSG Sky Chefs, Inc. Solutions is a Schedule 1 employer with
approximately 9,000 employees in the United States."5 Between April 1, 2015 and
December 31, 2015, Sky Chefs, Inc. dba LSG Sky Chefs, Inc. paid its lowest wage
Seattle workers $10.90 or less.13- ?7 Therefore, Sky Chefs, Inc. dba LSG Sky Chefs, Inc.
violated the Minimum Wage ordinance.

2. 2016

Effective January 1, 2016, Schedule 1 employers shall pay each employee an hourly
minimum wage of at least $13.00. The employer may pay $12.50 an hour if the
employer?s medical benefits plan is a silver or higher level essential health benefits
package as defined in 42 U.S.C. Section 18022, or an equivalent plan that is designed
to provide benefits to are actuarially equivalent to 70 percent of the actuarial value of
the bene?ts provided under the plan, whichever is greater.18

Sky Chefs, Inc. dba LSG Sky Chefs, Inc. offers a medical benefits plan to employees
that meets the silver level plan requirements under 42 U.S.C. section 18022. Four

 

?2 Under current enforcement priorities, OLS provides employers with 30 days to come into compliance
with the notice and posting provisions of the Ordinances. Therefore. OLS will only ?nd a violation of these
provisions if a Respondent subject to an investigation does not come into compliance.

?3 

?4 SMC 14.19010.

?5 May 20, 2015 email from Brandy Chambers

15 Sky Chefs, Inc. dba LSG Sky Chefs, Inc., LSG Sky Chefs Supply Chain Solutions payroll records

17 The Sky Chefs, Inc. Customer Service Center SER #261 Local Wage Supplement states employees
designated as either Lead personnel, assigned to perform certain tasks, or performing specialized tasks
requiring special training will be paid a speci?ed amount per hour above their hourly wage rate. As
employees' hourly wage should have been at least $11.00 an hour in 2015 under SMC 14.19, the
differential should be paid in addition to $11.00. Thus, the lead pay was not included in calculating back
wages. Conversely, because shift differentials are not tied to employee's hourly wage. the shift differential
was not subtracted from the amount paid in determining back wages owed.

?3 14.19010

FINDINGS OF FACT, DETERMINATION AND OFFER T0 CONFERENCE 3
COMPLIANCE LETTER NUMBER 15MW025

 

@m?deI-bWM?h




 

Seattle employees receive the benefit. For the four employees receiving medical
benefits, $12.50 is the correct hourly rate for 2016 for the pay periods in which Sky
Chefs, Inc. dba LSG Sky Chefs. Inc. paid towards their medical benefits. For employees
opting out of coverage, Sky Chefs, Inc. dba LSG Sky Chefs, Inc. is required to pay
employees a minimum of $13.00 an hour in 2016.

Sky Chefs, Inc. dba LSG Sky Chefs, Inc. paid 53 employees less than $11 per hour
between January 1, 2016 and January 7, 2016. Effective January 8, 2016, Sky Chefs,
Inc. dba LSG Sky Chefs, Inc. increased its minimum rate to $12.50 an hour, 50 cents
below the minimum wage for employees who do not receive medicai bene?ts. Sky
Chefs, Inc. dba LSG Sky Chefs, Inc. began paying the increased rate of $12.50 per
hour to employees on March 17, 2016.19 On April 14, 2016, Sky Chefs, Inc. dba LSG
Sky Chefs, Inc. provided 60 employees with lump sum retroactive payments designed
to compensate for the pay differential from their prior rate and $12.50 per hour for the
period from January 8, 2016 to March 17, 2016.20

In 2016, Sky Chefs, Inc. dba LSG Sky Chefs, Inc. thus paid employees $12.50 or less
per hour. All wages of less than $12.50 per hour, and all wages of $12.50 per hour for
employees who were not receiving medical benefits were below the minimum wage
required by SMC 14.19. Therefore, Sky Chefs, Inc. dba LSG Sky Chefs, Inc. is in
violation of the Minimum Wage ordinance.

A preponderance of the evidence demonstrates that Sky Chefs, Inc. dba LSG Sky
Chefs, Inc. failed to comply with the minimum wage provision of the Minimum Wage
ordinance, SMC14.19.030, in 2015 and 2016.

Willful Resistance of the Director

An employer who willfully resists, prevents, impedes, or interferes with the Director in
the performance of the Director?s duties shall be subject to a civil penalty of not less
than $1,000 and not more than $5,000.21

Throughout the investigation, Sky Chefs, Inc. dba LSG Sky Chefs, Inc. consistently
missed deadlines imposed by OLS or provided incomplete or inaccurate responses to
requests for information. On August 28, 2015, OLS requested interviews with an
employee most familiar with Sky Chefs Seattle operations.22 After repeated inquiries
about when and with whom the interview would be scheduled, Sky Chefs, Inc. dba LSG
Sky Chefs, Inc. finally made Eric Williams available on November, 4, 2015, over two
months after the initial request.23

 

?9 Sky Chefs, Inc. dba LSG Sky Chefs, Inc, LSG Sky Chefs Supply Chain Solutions Payroll Records
20 8f8i2016 Email from Don Munro; Payroll Records



23 Email 10 with RP

23 Id.

FINDINGS OF FACT, DETERMINATION AND OFFER TO CONFERENCE 4
COMPLIANCE LETTER NUMBER 15MWO25

 

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Further, OLS sent a request for payroll records to Sky Chefs, Inc. dba LSG Sky Chefs,
Inc. on February 9, 2016. Sky Chefs, Inc. dba LSG Sky Chefs, Inc. did not provide a
response until March 18, 2016, claiming an exemption from the Minimum Wage
Ordinance.
OLS sent another request for information, including payroll records, on April 20, 2016,
with a deadline set for May 9, 2016. Sky Chefs, Inc. dba LSG Sky Chefs, Inc. sent an
incomplete response that did not include payroll records on May 3, 2016. OLS followed­
up with another request on May 19, 2016, imposing a May 27, 2016 deadline. Sky
Chefs, Inc. dba LSG Sky Chefs, Inc. responded on May 31, 2016, still failing to provide
the requested payroll records. OLS did not receive the payroll records until June 3,
2016.
On August 5, 2016, OLS requested evidence to show which Sky Chefs, Inc. dba LSG
Sky Chefs, Inc. employees receive health insurance coverage. Sky Chefs emailed in
response on August 8, 2016, "This will confirm that all of the Sky Chefs employees in
Seattle re.ceive employer-subsidized health benefits." However, subsequent records
received on November 9, 2016, over three months after the initial request, showed that
only 4 of 165 Seattle employees received employer-subsidized health benefits.
OLS sent an additional request for payroll records "from June 2, 2016 to present" on
September 8, 2016, with a deadline on September 14, 2016. Sky Chefs, Inc. dba LSG
Sky Chefs, Inc. did not provide the records until October 5, 2016.

16

A preponderance of the evidence demonstrates that Sky Chefs, Inc. dba LSG Sky
Chefs, Inc. willfully resisted, impeded, and interfered with OLS's investigation in
violation of the Ordinances.

17

DETERMINATION OF VIOLATION

15

18
19
20
21
22
23

The Director has determined that there is sufficient evidence to find that Sky Chefs, Inc.
dba LSG Sky Chefs, Inc. violated SMC Chapters 14.19 and 14.20 with respect to
compensation.
The Director has determined that there is insufficient evidence to find that Sky Chefs,
Inc. dba LSG Sky Chefs, Inc. violated SMC Chapters 14.19 and 14.20 with respect to
notice and posting. Within 15 days of being served with the enclosed finding, the
affected employee may request reconsideration of this determination with OLS by
completing and submitting the enclosed form.

24
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27
28

FINDINGS OF FACT, DETERMINATION AND OFFER TO CONFERENCE 5
COMPLIANCE LETTER NUMBER 15MW025

 1

REMEDIES

2
3
4
5
6
7
8

1. Back Wages and Liquidated Damages
Total gross payments of $210,213.19 are due to employees. This amount includes
$183,677.02 plus 12% annual interest, calculated monthly.24
The Director assesses liquidated damages against Sky Chefs, Inc. dba LSG Sky Chefs,
Inc. in the amount of $109,320.20 under SMC 14.19 and SMC 14.20 for 1.75 times the
wages owed on or after January 16, 2016.25
The total amount due in back wages, interest, and liquidated damages is $319,533.39,
and it breaks into the following gross amounts to current and former Seattle employees:

9
10
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12
13
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16
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18
19
20
21
22
23
24
25
26
27
28

First
Name
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19

Last Name

Back
wages
$2,292.97
$2,089.66
$3,442.42
$233.81
$1,067.52
$131.00
$671.25
$550.79
$9.00
$3.37
$613.80
$1,556.24
$177.31
$2,758.74
$17.59
$1,487.59
$287.18
$251.60
$1,537.28

Interest
$342.31
$243.48
$430.74
$31.02
$55.89
$14.81
$28.13
$26.46
$0.35
$0.64
$23.89
$261.22
$8.77
$421.51
$2.38
$128.43
$55.47
$39.05
$254.60

Liquidated
Damages
$1,384.67
$1,389.97
$1,742.01
$63.61
$1,868.16
$0.00
$1,174.69
$963.88
$15.75
$0.00
$1,074.15
$0.00
$310.29
$1,729.63
$0.00
$2,603.29
$0.00
$0.00
$0.00

Total
$4,019.95
$3,723.11
$5,615.17
$328.44
$2,991.57
$145.81
$1,874.07
$1,541.13
$25.10
$4.01
$1,711.84
$1,817.46
$496.37
$4,909.88
$19.97
$4,219.31
$342.65
$290.65
$1,791.88

24 While the retroactive pay was designed to bring employees to a minimum of $12.50 per hour, the
amount paid was not consistent. Thirteen employees received no retroactive pay despite working for less
than $12.50 per hour in the designated time period. Likewise, four employees received more retroactive
pay than was due to them at the $12.50 per hour rate, 50 employees received some retroactive pay but
not enough to meet the $12.50 per hour rate, and six employees received retroactive pay at the $12.50
rate. The retroactive pay did not include interest.
25 On January 16, 2016, the Wage Theft Prevention and Labor Standards Harmonization Ordinance (Ord.
124960) went into effect, resulting in increased remedies for workers including liquidated damages up to
twice the unpaid wages.

FINDINGS OF FACT, DETERMINATION AND OFFER TO CONFERENCE 6
COMPLIANCE LETTER NUMBER 15MW025

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2
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5
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8
9
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19
20
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22
23
24
25
26
27
28

20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59

$3,764.11
$310.14
$475.49
$567.72
$130.14
$1,430.83
$3,009.95
$637.16
$1,937.41
$1,276.80
$3,058.65
$544.50
$510.87
$42.19
$2,772.31
$437.02

$579.67
$11.88
$14.73
$88.49
$9.89
$248.75
$429.25
$83.79
$338.61
$197.34
$452.21
$15.54
$14.50
$5.10
$403.35
$55.60

$1,807.58
$542.75
$832.11
$0.00
$195.76
$0.00
$2,056.82
$0.00
$575.00
$0.00
$1,881.14
$952.88
$894.02
$0.00
$2,121.86
$0.00

$6,151.36
$864.77
$1,322.33
$656.21
$335.79
$1,679.58
$5,496.02
$720.95
$2,851.02
$1,474.14
$5,392.00
$1,512.92
$1,419.39
$47.29
$5,297.52
$492.62

$1,524.20
$701.69
$1,604.82
$2 1 979.10
$754.14
$480.61
$1,281.23
$19.85
$1,801.03
$148.58
$787.15
$34.60
$11.60
$3,001.78
$38.68
$1,967.17
$1,382.75
$784.75
$1,041.10
$265.10
$34.69
$984.38
$13.68
$3,768.44

$225.36
$121.10
$270.19
$438.08
$114.40
$18.62
$146.95
$0.30
$254.74
$26.06
$37.86
$4.09
$0.68
$455.79
$1.95
$269.68
$159.21
$74.81
$124.92
$61.25
$4.87
$178.25
$2.00
$568.67

$1,655.80
$0.00
$0.00
$613.73
$0.00
$816.59
$1,941.41
$34.74
$661.04
$0.00
$1,377.52
$0.00
$20.30
$1,682.82
$67.69
$1,839.18
$2,118.91
$323.51
$691.72
$463.93
$0.00
$0.00
$0.00
$2,001.76

$3,405.36
$822.79
$1,875.01
$4,030.91
$868.54
$1,315.82
$3,369.59
$54.89
$2,716.81
$174.64
$2,202.53
$38.69
$32.58
$5,140.39
$108.32
$4,076.03
$3,660.87
$1,183.07
$1,857.74
$790.28
$39.56
$1,162.63
$15.68
$6,338.87

FINDINGS OF FACT, DETERMINATION AND OFFER TO CONFERENCE 7
COMPLIANCE LETTER NUMBER 15MW025

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8
9
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79

80

81
82
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85
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88
89
90
91
92
93
94
95
96
97
98
99

$3,623.10
$3,096.85
$1,973.94
$220.44
$287.55
$830.45
$5.50
$2,534.88
$165.26
$3,464.71
$570.99
$4,088.46
$3,805.35
$1,130.70
$2.10
$2,898.41
$13.76
$28.24
$902.60
$161.88
$2,455.97
$774.14
$1,493.92
$96.11
$554.54
$3,298.77

$558.42
$460.50
$317.56
$30.36
$37.97
$108.37
$3.34
$376.70
$4.81
$520.12
$108.43
$615.42
$565.25
$204.14
$0.07
$483.11
$1.86
$2.94
$71.83
$31.80
$304.62
$39.62
$258.11
$10.41
$103.98
$480.95

$2,005.17
$2,028.89
$0.00
$0.00
$0.00
$0.00
$9.63
$1,592.85
$289.21
$2,243.76
$0.00
$2,272.34
$1,917.30
$0.00
$3.68
$1,465.52
$0.00
$49.42
$1,579.56
$0.00
$2,575.55
$1,354.75
$0.00
$0.00
$0.00
$2,104.10

$6,186.69
$5,586.24
$2,291.50
$250.80
$325.52
$938.82
$18.47
$4,504.43
$459.28
$6,228.59
$679.42
$6,976.22
$6,287.90
$1,334.84
$5.85
$4,847.04
$15.62
$80.60
$2,553.99
$193.68
$5,336.14
$2,168.51
$1,752.03
$106.52
$658.52
$5,883.82

$1,889.14
$5.50
$3,511.53
$474.80
$4.59
$1,284.68
$240.06
$158.78
$110.26
$461.05
$436.26
$5,631.33
$56.90
$626.98

$406.21
$3.34
$551.04
$89.10
$0.58
$228.30
$26.90
$28.16
$12.18
$15.03
$13.59
$951.10
$10.45
$82.97

$153.68
$9.63
$1,908.59
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$806.84
$763.45
$0.00
$0.00
$604.59

$2,449.03
$18.47
$5,971.16
$563.90
$5.17
$1,512.98
$266.96
$186.94
$122.44
$1,282.92
$1,213.30
$6,582.43
$67.35
$1,314.54

FINDINGS OF FACT, DETERMINATION AND OFFER TO CONFERENCE 8
COMPLIANCE LETTER NUMBER 15MW025

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9
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20
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23
24
25
26
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100
101
102
103
104
105
106
107
108
109
110
111
112
113
114
115
116
117
118
119
120
121
122
123
124
125
126
127
128
129
130
131
132
133
134
135
136
137
138
139
140

$131.24
$316.52
$133.75
$9.00
$2,606.39
$3,974.60
$492.65
$428.68
$852.99
$1,366.54
$636.94
$881.01
$2,676.27
$1,215.36
$272.69
$1,756.85
$3,652.20
$664.50
$246.11
$1,853.46
$1,545.07
$1,281.80
$1,170.75
$521.80
$575.22
$158.61
$2,432.95
$2,753.46
$2,991.78
$350.82
$2,965.45
$181.19
$240.57
$1,700.87
$527.50
$810.73
$188.00
$36.01
$225.27
$1,589.23
$670.51

$20.30
$7.06
$6.73
$0.35
$377.77
$557.68
$88.67
$42.22
$127.12
$157.56
$59.30
$162.85
$435.61
$135.46
$27.08
$351.37
$550.34
$85.56
$37.43
$264.69
$258.91
$206.47
$150.16
$55.95
$26.38
$29.29
$304.85
$487.98
$499.84
$8.58
$479.83
$99.94
$11.39
$218.01
$88.39
$143.89
$5.05
$7.07
$24.91
$238.44
$59.64

$0.00
$553.91
$234.06
$15.75
$2,032.17
$2,374.12
$0.00
$750.19
$0.00
$841.30
$474.55
$0.00
$1,500.61
$2,021.14
$477.21
$203.36
$2,008.42
$0.00
$0.00
$1,718.10
$1,198.39
$1,392.61
$1,196.60
$913.15
$1,006.64
$277.57
$1,267.26
$633.09
$882.49
$613.93
$1,382.56
$317.09
$421.00
$1,646.28
$0.00
$0.00
$329.00
$0.00
$28.40
$0.00
$1,173.40

FINDINGS OF FACT, DETERMINATION AND OFFER TO CONFERENCE 9
COMPLIANCE LETTER NUMBER 15MW025

$151.54
$877.49
$374.54
$25.10
$5,016.33
$6,906.40
$581.32
$1,221.09
$980.11
$2,365.40
$1,170.79
$1,043.86
$4,612.49
$3,371.96
$776.98
$2,311.58
$6,210.96
$750.06
$283.54
$3,836.25
$3,002.37
$2,880.88
$2,517.51
$1,490.90
$1,608.24
$465.47
$4,005.06
$3,874.53
$4,374.11
$973.33
$4,827.84
$598.22
$672.96
$3,565.16
$615.89
$954.62
$522.05
$43.08
$278.58
$1,827.67
$1,903.55

 1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

141
142
143
144
145
146
147
148
149
150
151
152
153
154
155
156

TOTAL

$961.66
$922.33
$976.74
$3,380.17
$1,213.91
$803.72
$782.73
$3,644.64
$628.87
$1,376.99
$236.04
$207.25
$33.84
$2,261.46
$53.32
$242.02
$183,677.02

$43.65
$98.31
$135.92
$492.53
$206.50
$207.13
$202.03
$554.11
$28.53
$247.57
$38.67
$3.75
$4.00
$320.47
$8.43
$47.13
$26,536.17

$1,682.91
$904.56
$566.29
$1,888.98
$0.00
$203.60
$180.99
$2,038'.59
$1,100.52
$505.25
$0.00
$362.69
$0.00
$1,772.29
$0.00
$0.00
$109,320.20

2. Civil Penalties
The Director assesses a civil penalty against Sky Chefs, Inc. dba LSG Sky Chefs, Inc.
of $5,000 under SMC 14.19 and SMC 14.20 for willfully resisting the Director in the
performance of their duties.
The Director assesses a civil penalty for first violation against Sky Chefs, Inc. dba LSG
Sky Chefs, Inc. of $10,500 under SMC 14.19 and SMC 14.20 - $100.00 per employee
for violations that occurred on or after January 16, 2016.
EXPLANATION
I invite you to contact OLS in an attempt to achieve a just and equitable resolution of
this matter through conference and conciliation. Within seven days of your receipt of this
Finding and Order, please contact Investigator Lynnette Jenkins at 206-615-1781 or
Lynnette.jenkins@seattle.gov.
In the event that Sky Chefs, Inc. dba LSG Sky Chefs, Inc. does not contact OLS within
the seven-day period, the Division Director shall issue an order with the amount of
appropriate remedy which may include civil penalties and fines as permitted by SMC
14.19.080 and 14.20.060.

25
26
27
28

$2,688.22
$1,925.20
$1,678.95
$5,761.68
$1,420.41
$1,214.45
$1,165.75
$6,237.34
$1,757.92
$2,129.81
$274.71
$573.69
$37.84
$4,354.22
$61.75
$289.15
$319,533.39

FINDINGS OF FACT, DETERMINATION AND OFFER TO CONFERENCE 10
COMPLIANCE LETTER NUMBER 15MW025

 


mummth?tammqamhwm?tc

.n I 
hawks: I3. 

Date Dylan' Orr
Division Director
Office of Labor Standards
Seattle Office for Civil Rights

 

 

FINDINGS OF FACT. DETERMINATION AND OFFER TO CONFERENCE 11
COMPLIANCE LETTER NUMBER 15MW025