LTC 128-2005 Violation of the Living Wage ordinance by Armor Security
CITY OF MIAMI BEACH
Office of the City Manager
Letter to Commission No. 128-2005
m
From:
Mayor David Dermer and Date: May 16, 2005
Members of the City Commission .
Jorge M. Gonzalez ~ IY'-r /
City Manager ( 1)
VIOLATION OF THE l:: VING WAGE ORDINANCE BY ARMOR SECURITY
To:
Subject:
The purpose of this LTC is to provide you with information relative to the violation of the
City's Living Wage Ordinance by Armor Security pursuant to Contract No. 4-01/02, for
Security Guard Services.
Based on a complaint received in the Procurement Division, the City's Procurement
Director requested and received on March 4, 2005, payroll records submitted by Armor
Security, Inc. Said payroll records covered the period from August 18, 2004 through
February 15, 2005, and reflect how much was paid to each Armor Security employee
assigned to provide security guard services to the City.
The Procurement Director's review of the aforementioned payroll records raised concerns
relative to Armor's compliance to the Living Wage Ordinance. Armor's payroll records
indicate that most ofthe security guards were paid $8.56 per hour without any contributions
towards health benefits. The Procurement Director decided to survey former Armor
Security employees to determine if they were being paid the living wage required by the
Ordinance; that is, either $8.56 per hour plus $1.25 per hour towards health benefits; or
$9.81 per hour without health benefits contributions (see attached questionnaire).
Pursuant to City of Miami Beach Living Wage Ordinance, as codified in Chapter 2, Division
6, Sections 2-407 thru 2-410 of the Miami Beach Code, all service contractors, entering
into a contract with the city shall pay to all its employees, a living wage of no less than
$8.56 an hour with health benefits, or a living wage of not less than $9.81 an hour without
health benefits. For a covered employer to comply with the living wage provision by
choosing to pay the lower wage scale ($8.56/hour) when a covered employer also provides
health benefits, such health benefits shall consist of payment of at least $1.25 per hour
toward the provision of health benefits for covered employees and their dependents.
If the health benefits plan of the covered employer requires an initial period of employment
for a new employee to be eligible for health benefits ("eligibility period") the living wage
provision shall be complied with as follows during the eligibility period:
(1) Provided the new employee will be paid health benefits upon the completion of the
eligibility period, a covered employer or the city may only qualify to pay the $8.56 per hour
wage scale for a term not to exceed the first 90 days of the new employee's eligibility
period, said term commencing on the employee's date of hire.
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Notic:'e of Living Wage Violation to Armor Security
May 16, 2005
Page 2 of 2
(2) If the covered employer's eligibility period exceeds the 90-day term provided in
subsection (1), then the covered employer, commencing on the ninety-first day of the new
employee's eligibility period, must commence to pay a living wage of not less than $9.81 an
hour.
It is important to note that Armor's contract was awarded on March 20, 2002, which is prior
to the amendment to the Living Wage Ordinance that defined "eligibility period" not to
exceed 90 days (the Ordinance when first adopted did not define the employer's eligibility
period). Armor maintains that their eligibility period is one year. Therefore, any Armor
employee who has passed his/her eligibility period (one year), should have being paid
$8.56/hour plus $1.25 contributed towards health benefits or the $9.81/hour without any
contributions towards health benefits. The findings reflect that Armor has paid their
employees who passed their eligibility period, only $8.56 per hour.
All employees who passed Armor Security's eligibility period I and were paid a wage rate of
$8.56 per hour without any contribution towards health benefits, must be paid a minimum
of $1.25 per hour for each hour that he/she worked, pursuant to Contract No. 04-01/02,
must receive wage restitution.
If Armor fails to comply with this notice of corrective action, I or my designee may issue an
order in writing which requests Armor Security to appear at an administrative hearing
before myself or my designee.
If you have any questions or need additional information, please feel free to contact me.
.7 '
C: Murray H. Dubbin
City Attorney
Patricia D. Walker
Qhief Financial Officer
Gus Lopez
Procurement Director
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.Raul Aguila
First Assistant City Attorney
F:\PURC\SAl.L \GUS\L TC\LivinWage&Armor .doc
CITY OF MIAMI BEACH
CITY HALL 1700 CONVENTION CENTER DRIVE M lAM Illh\CII. FLORIDA 3313<)
www.miamibcachfl.gov
Procurementl>ivision
Telephone 305.673.7490
Facsimile 305.673.71151
VIA FACSIMILE (305.598.0393) AND U.S. MAIL
May 9, 2005
Andrew Nierenberg, P.A.
The Atrium at Coral Gables
1500 San Remo Avenue, Suite 125
Coral Gables, FL 33146
RE: NOTICE OF LIVING WAGE VIOLATION TO ARMOR SECURITY, INC.
PURSUANT TO CONTRACT NO. 4-01/02, FOR SECURITY GUARD SERVICES
Dear Mr. Nierenberg:
Pursuant to verifying compliance of the above referenced contract with the City of Miami Beach
Living Wage Ordinance, as codified in Chapter 2, Division 6, Sections 2-407 thru 2-410 of the
Miami Beach Code (hereinafter, the "Ordinance"), this office requested and received, on March
4, 2005, payroll records submitted by your client Armor Security, Ine. Said payroll records
covered the period from August 18, 2004 through February 15, 2005, and reflect how much was
paid to each Armor Security employee assigned to provide security guard services to the City.
Our review of the aforementioned payroll records raised concerns relative to your client's
compliance to the Ordinance. Said payroll records indicate that most of the security guards
were paid $8.56 per hour without any contributions towards health benefits. We therefore
decided to survey former Armor Security employees to determine if they were being paid the
living wage required by the Ordinance; that is, either $8.56 per hour plus $1.25 per hour
towards health benefits; or $9.81 per hour without health benefits contributions.
Based on the information received, this Office has determined that Armor Security IS In
violation of the Ordinance. As such, Armor Security is required to pay wage restitution, at its
expense, to each affected employee, by June 6,2005. Specifically, all employees who passed
Armor Security's eligibility period, and were paid a wage rate of $8.56 per hour without any
contribution towards health benefits, must be paid a minimum of $1.25 per hour for each hour
that he/she worked, pursuant to Contract No. 04-01/02, must receive wage restitution.
The aforementioned wage restitution must cover the period from March 20, 2002 through April
30, 2005. Documentation which confirms that wage restitution was made to each affected
employee must be submitted to this Office by June 10, 2005.
If Armor fails to comply with this notice of corrective action, the City Manager or the City
Manager's designee may issue an order in writing which requests Armor Security to appear at
an administrative hearing before the City Manager or his designee.
Notice of Living Wage Violation to AnnoT Security
May 9, 2005
Page 2 of2
Please be advised that for violations of the City's Living Wage Ordinance, the City may access
the following:
(1) Damages in the sum of $500.00 for each week for each employee found to have not been
paid in accordance with the Ordinance; and/ or
(2) Suspend or terminate payment; and/ or
(3) Declare Armor Security ineligible for future service contracts for three years or until all
penalties and restitution have been paid in full, whichever is longer.
Additionally, Armor Security shall not discharge, reduce the compensation, or otherwise
discriminate against any covered employee for making a complaint to the City, or otherwise
a85erting his or her rights under the Ordinance, participating in any of the City's proceedings or
using any civil remedies to enforce his or her rights under the Ordinance.
Should you have any questions, I may be reached by phone: 305.673.7490; or fax: 305.673.7851;
or email: guslopez@miamibeachfl.gov.
C: Jorge M. Gonzalez
City Manager
'Patricia D. Walker
Chief Financial Officer
Murray Dubbin
City Attorney
Raul Aguila
Assistant City Attorney
Lou Nodarse, Vice President
Armor Security
Fax: 305.598.0393
CITY OF MIAMI BEACH
1700 CO!1vention Center Dr, Miami Beach, FL 33139
www.miamibeachfl.gov
Procur<Sillent Division
Telephone (305) 673-7490
Facsimile (305) 673-7851
ATTENTION CURRENT OR FORMER ARMOR SECURITY GUARDS
It has been brought to my attention that security guards employed by Armor Security who have
worked under the City's contract with Armor Security may not have been paid the required living
wage rate and/ or made contributions towards health benefits.
If the City determines that Armor Security is in violation of the City's Living Wage Ordinance, the
City may impose sanctions against Armor Security including but not limited to, wage restitution for
each affected employee. In other words, if you were not paid the City's living wage rate of $8.56
per hours plus $1.25 per hour towards health benefits; or $9.81 per hour without health benefits,
you may be entitled to wage restitution. It is therefore, very important that you complete the
following questionnaire:
Name:
Phone Number:
Start Date of Employment with Armor Security:
Start Date of Working as a Security Guard on Miami Beach:
Hourly-Wage Rate Paid: $
Contributions by Armor towards health benefits (if any): $_/hourly or $
or $~/monthly.
fbi-weekly
Did Armor contribute towards health benefits:
Yes
No
Should you need additional information or clarification, I may be reached by phone: 305.673.7490;
fax: 305.673.7851; or e-mail: guslopez@miamibeachfl.gov.
IMPORT ANT NOTE: Retaliation and discrimination barred. A covered employer (i.e. Armor
Security) shall not discharge, reduce the compensation, or otherwise discriminate against any
covered employee for making a complaint to the city, or otherwise asserting his or her rights under
this division, participating in any of its proceedings or using any civil remedies to enforce his or her
rights under this division. Allegations of retaliation or discrimination, if found true in a proceeding
under paragraph (b) or by a court of competent jurisdiction under paragraph (c), shall result in an
order of ~stitution and reinstatement of a discharged covered employee with back pay to the date
of the violation or such other relief as deemed appropriate.