Recordkeeping

  • The nondisplacement contract clause requires that "Contractor and subcontractor shall maintain the following records (regardless of format, e.g., paper or electronic) of its compliance with this clause for not less than a period of three years from the date the records were created." 29 C.F.R. Part 9, Appendix A, paragraph (g); FAR 48 C.F.R. § 52.222-17(f).
  • DOL regulatory requirements are set forth in 29 C.F.R. 9.12(f) and at FAR 48 C.F.R. §§ 52.222-17(f), and require the following:
  • The contractor (and subcontractors) shall maintain copies of any written offers of employment or a contemporaneous written record of any oral offers of employment, including:
  • The date, location, and attendance roster of any employee meeting(s) at which the offers were extended, and a summary of each such meeting,
  • A copy of any written notice that may have been distributed, and
  • The names of the employees from the predecessor contract to whom an offer was made.
  • The contractor (and subcontractors) shall maintain a copy of any record that forms the basis for any exclusion or exemption (including any federal agency waiver) claimed under the nondisplacement rules under E.O. 13495 and its implementing regulations.
  • The contractor (and subcontractors) shall maintain a copy of the employee list(s) provided to and received from the contracting agency.

29 C.F.R. § 9.12(f)(2).

  • No particular order or form of records is prescribed for contractors (including subcontractors).
  • A contractor may use records developed for any purpose to satisfy these requirements, provided the records otherwise meet the requirements and purposes of the regulations and are fully accessible.

29 C.F.R. § 9.12(f)(1).

  • The contractor must provide copies of such documentation upon request of any authorized representative of the contracting agency or DOL. 29 C.F.R. § 9.12(f)(4).
  • Additional recordkeeping requirements apply to each contractor who makes retroactive payment of wages or compensation under the supervision of the WHD Administrator pursuant to 29 C.F.R. § 9.24(b), as a remedy for "unpaid wages or other relief due" for violations of 29 C.F.R. Part 9.
  • See 29 C.F.R. § 9.12(f)(2)(iv) and § 9.24(b), and FAR 48 C.F.R. § 52.222-17(g)(4) for additional information regarding those requirements.


Consulting Services We Provide

  • Review public works preconstruction contracts
  • Monitor DIR contractor/subcontractor certified payrolls
  • Audit labor classification for each worker employed
  • Review DIR pre-DAS 140/142 submissions
  • Review CAC training fund contributions form CAC-2
  • Review DIR Fringe Benefits Statement PW-26
  • Monitor DIR wage determinations
  • Audit fringe benefits allowances
  • Review DIR holiday payment requirements
  • Audit DIR travel & subsistence requirements
  • Caltrans Labor Compliance
  • County of Sacramento Labor Compliance
  • City of Los Angeles Labor Compliance
  • Los Angeles Unified School District Labor Compliance
  • Federal Davis-Bacon Project Monitoring
  • Federal DBE Implementation & Review
  • Federal FAA AIP Goal Setting
  • DIR & Davis-Bacon Training
  • DIR Civil Wage Penalty Review
  • Local-Hire Review (e.g., San Francisco)
  • Skilled and Trained Workforce

Give us a call to discuss your labor compliance requirements.

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