IA payroll deductions
rosfin 15 Posts
I know state rules vary on payroll deductions for uniform service, laundering etc. for EE - not buying uniforms. I cannot find anything that directly addresses such deductions for uniform service in Iowa. Has anyone run across this particular information?
Unfortunately, Iowa's law is one of the more vague ones.
We cover state wage deduction laws in Chapter 46 of [url=http://store.hrhero.com/50x50]Fifty Employment Laws in Fifty States[/url], and the entry for Iowa does note that there are certain types of deductions that specifically aren't allowed -- for example, costs of personal protective equipment (other than items of clothing or footwear that may be used by an employee during nonworking hours) cannot be deducted from employee paychecks. However, no specific statement is made that restricts deductions of uniform maintenance costs (again, so long as the deduction doesn't take the employee's wage below minimum). From this alone, it seems permissible.
Beyond those specifics, the law notes that deductions are allowed only when the employer is required or [i]permitted to do so by state or federal law[/i] or by order of a court of competent jurisdiction; or the employer has written authorization from the employee to deduct [i]for any lawful purpose accruing to the benefit of the employee.[/i] Well, employers are permitted to deduct for uniform cleaning costs under federal law, so that also seems like it'd be permissible.
Here's where it gets strange. Just to see if I could find some added information, I also checked the Iowa Workforce website. I found a [url=http://www.iowaworkforce.org/labor/wagefaqs.pdf]FAQ[/url] document that gives some information on deductions for the initial purchase of uniforms, which noted that "deducting the purchase price of uniforms from an employee’s paycheck is [b]not[/b] allowed [i]if the uniform identifies the business through a logo or company colors.[/i]" Well, we know that personal protective equipment deductions aren't allowed unless they can be worn during nonworking hours, but this statement in the FAQ is far broader than personal protective equipment. Yet, deductions for the initial purchase of uniforms are allowed under federal law (again, so long as they don't reduce pay below minimum wage). So, as this restriction isn't specifically in the Iowa statute, I think it speaks to the requirement that deductions must be for the benefit of the employee -- and uniforms that identify the business are obviously to the benefit of the employer.
Unfortunately, uniform cleaning costs and maintenance are also generally considered to be for the benefit of the employer, so from this I'm now unsure whether the deductions are permissible or not.
What a mess, right?
I think it probably comes down to a lot of factual questions. Do the uniforms themselves require special maintenance (which includes dry cleaning) to preserve their life? If so, the cleaning costs are more likely to be for the benefit of the employer. On the other hand, if the uniforms are the type that just require standard laundering, and the employer is able to provide employees with the option to participate in a laundry service for their own convenience, then this is something that would be for the benefit of the employee, so it might be permissible.
All in all, I'd err on the side of not making the deduction, and in the meantime you might call up the Iowa DOL to see if they can provide some fact-specific guidance.
I wish I had more solid information on how this law has been interpreted, but I think the safest bet would be to call up the state DOL -- especially since they released and published that FAQ.