Who is LETF and Why Should You Care?

Based on a number of recent appeals filed by our office for citations issued by Cal/OSHA’s Labor Enforcement Task Force (LETF) Unit, we thought it might be helpful to explain what and who LETF is. LETF is a coalition of various state and local agencies that include Cal/OSHA, the CA Labor Commissioner, the Contractor’s State License Board and the Employment Development Department. LETF falls under the umbrella of the Department of Industrial Relations. The LETF’s mission is to “combat the underground economy”. The underground economy is a reference to employers who operate without the proper licensing and workers’ compensation coverage, engage in possible tax evasion, engage in wage theft, and have general unsafe work conditions (which is where Cal/OSHA comes in).

Cal/OSHA’s LETF Unit shares information and resources with the LETF, and assists in joint inspections with other LETF agencies throughout the state. Notably, any inspection by the LETF that includes Cal/OSHA will likely result in citations issued by Cal/OSHA. Further, Cal/OSHA’s LETF Unit sometimes conducts inspections on its own, without other agencies present. In short, Cal/OSHA’s LETF Unit operates as any other Cal/OSHA district office would, but with a much wider reach.

Because of its specific mission, many employers do not experience an LETF inspection. However, in the last six months, we have seen an increased number of citations stemming from Cal/OSHA’s LETF Unit. Interestingly, the most recent inspections coming through our office have focused heavily on exposed rebar hazards. However, LETF’s scope is certainly not limited to that type of violation. In fact, the LETF’s most recent legislative report stated that Cal/OSHA uses its inspection and permit data, as well as contacts with local Agricultural Commissioner’s office and the U.S. Dept. of Agriculture’s office to identify employers for inspection. That same report showed an increase in inspections from 194 in 2021 to 483 in 2022 (data for 2023 is not yet available). So, while there is often a construction-oriented focus for LETF (see link to Public Works Projects below), Cal/OSHA LETF also has agricultural employers specifically in mind.

It can be overwhelming to have multiple agencies inspecting at the same time, requesting a multitude of documentation. As such, it is easy to forget that even if you are compliant with wage/hour, workers’ comp. coverage, and other licensing, Cal/OSHA’s LETF Unit is looking for Title 8 violations, regardless of the overall mission stated on the LETF website. In other words, all potential safety issues are ripe for inspection and citation. 

For more information on LETF and Cal/OSHA’s LETF Unit, see the links below.

 DIR LETF website: https://www.dir.ca.gov/LETF/LETF.html

Cal/OSHA LETF website: https://www.dir.ca.gov/dosh/letf-unit.html

LETF Legislative Reports: https://www.dir.ca.gov/letf/LETF_Legislative_Reports.html

DIR Public Works Projects: https://www.dir.ca.gov/public-works/publicworks.html

As always, feel free to reach out to our office if you have questions about LETF or any other Cal/OSHA issue. Stay safe, and Happy New Year!