California janitorial employers have specific requirements for preventing sexual violence and harassment in the workplace. These requirements are commonly referred to as California’s Justice for Janitors training requirements and are established through the Property Service Workers Protection Act and the Janitor Survivor Empowerment Act, including AB 547.
For employers, compliance involves more than simply assigning a general sexual harassment course. California requires a specific training process for covered janitorial workers and their supervisors.
Here is how to implement the training step by step.
Step 1: Determine Whether Your Organization Is Covered
Start by determining whether your company is subject to California’s janitorial registration and training requirements.
Covered workers generally include people who predominantly perform janitorial work in California, including full-time, part-time, and temporary janitorial workers. Depending on the working arrangement, covered workers may also include independent contractors or franchisees performing janitorial work.
Employers should also confirm that their janitorial registration with the California Labor Commissioner is current.
Action: Identify every California operation where your company employs or engages workers performing covered janitorial services.
Step 2: Identify the Employees and Supervisors Who Need Training
Create two groups:
- Nonsupervisory covered janitorial workers
- Supervisors of those workers
The distinction is important because California has different trainer requirements for the two groups.
Both groups must receive at least two hours of sexual violence and harassment prevention training every two years.
New covered workers and new supervisors must receive the required training within six months of assuming their positions.
Action: Create a current roster showing each covered worker, whether the person is supervisory or nonsupervisory, their start date or promotion date, and the date of their last qualifying training.
Step 3: Check Each Person’s Training Deadline
Do not treat the training as a one-time compliance event.
Review your roster and determine:
- Who has already completed compliant training
- When that training occurred
- Who is approaching the two-year retraining deadline
- Which new workers or supervisors are approaching their six-month deadline
The employer is ultimately responsible for demonstrating that the required training occurred.
Action: Add each worker’s next required training date to your compliance calendar or HR system.
Step 4: Select the Correct Type of Qualified Trainer
This is one of the most important parts of the process.
For nonsupervisory covered workers, California generally requires the training to be provided by a qualified peer trainer supplied through a qualified organization listed by the California Department of Industrial Relations.
Training for supervisors must be provided by a trainer who meets California’s qualifications for providing sexual harassment prevention training to supervisors.
California permits employers to use a prescribed trainer when a qualified peer trainer is unavailable in the applicable county or available qualified trainers cannot meet the employer’s training needs. Compliance Training Group meets the qualifications to serve as a prescribed trainer and can provide the required in-person Justice for Janitors training using the California-required LOHP training materials.
Action: Before scheduling training, verify that the trainer being used meets the requirements applicable to the employees being trained.
Step 5: Make Sure the Training Uses the Required California Curriculum
Justice for Janitors training is not simply a generic sexual harassment course.
Employers must ensure that the training uses the content developed by the Labor Occupational Health Program at UC Berkeley under the direction of the California Department of Industrial Relations.
The curriculum addresses subjects including:
- Sexual harassment and abusive conduct
- Recognizing sexual violence and harassment
- Responding to harassment
- Reporting procedures
- Retaliation
- Employee rights
- Employer and supervisor responsibilities
- Resources available to victims of sexual violence and harassment
California maintains separate training materials for nonsupervisory workers and supervisors.
Action: Confirm that your training provider is using the current California-required LOHP materials.
Step 6: Deliver the Training In Person and Interactively
California defines this training as in-person, interactive instruction.
Online courses, recorded videos, webinars, and other e-learning tools can be used as supplemental training tools, but they cannot by themselves satisfy the Justice for Janitors training requirement.
Interactive training may include:
- Questions that assess understanding
- Workplace scenarios
- Group discussions
- Skill-building exercises
- Quizzes or knowledge checks
- Discussion of how employees would respond to specific situations
The required two hours do not have to occur in one continuous session. Training can be divided into separate sessions, but each training segment must be at least one hour long.
Action: Schedule either one two-hour training session or two sessions of at least one hour each.
Step 7: Provide Training in a Language and Literacy Level Employees Understand
California specifically requires the training to be provided in a language and at a literacy level understood by the worker or supervisor receiving it.
This is particularly important for employers with multilingual janitorial workforces.
Action: Before scheduling the session, identify the languages needed by the employees attending and confirm that the training can be properly delivered to those workers.
Step 8: Document the Training
Completing the training is only part of compliance. Employers must also be able to prove that the required training occurred.
California requires employers to maintain training documentation including:
- Names of the workers and supervisors trained
- Date of training
- Participant sign-in records
- Signatures at the beginning and completion of training
- Certificates of attendance or completion
- Type of training provided
- Training materials used
- Name of the training provider
- Required employer compliance documentation
Employers must generally maintain these records for at least three years and make them available to the Labor Commissioner upon request.
Action: Create one central compliance file for every Justice for Janitors training session rather than relying solely on employee personnel files or the training provider to maintain the records.
Step 9: Build the Training Into Your Ongoing Compliance Process
The easiest way to fall out of compliance is to treat Justice for Janitors training as a one-time project.
Instead, build the requirement into your normal onboarding and compliance procedures.
Your system should automatically identify:
- New covered workers approaching six months
- Newly promoted supervisors
- Employees approaching their two-year retraining date
- Missing documentation
- Changes in California training requirements
Action: Review your Justice for Janitors training roster at least quarterly rather than waiting until your janitorial registration renewal.
Justice for Janitors Implementation Checklist
Before considering the process complete, confirm that you have:
- Identified all covered janitorial workers
- Identified supervisors of covered workers
- Checked each person’s training deadline
- Selected appropriately qualified trainers
- Confirmed use of the required LOHP curriculum
- Scheduled in-person, interactive training
- Provided training in appropriate languages
- Completed the required two hours of training
- Collected attendance and completion documentation
- Stored the required records for at least three years
- Scheduled the next training deadline
Need Help Implementing Justice for Janitors Training?
California’s janitorial training requirements are more specific than the state’s general workplace sexual harassment training rules. Employers need to pay particular attention to the training format, trainer qualifications, required curriculum, documentation, and recurring deadlines.
Compliance Training Group works with California employers to help them understand and implement workplace compliance training requirements, including sexual violence and harassment prevention training for the janitorial industry.
If you have employees covered by California’s Justice for Janitors requirements, contact Compliance Training Group to discuss your workforce, training deadlines, and available training options.
