Kris Carmichael ConsultingPAGA · CAL/OSHA · WORKERS' COMP 510.833.0723

For California employers · 30 to 300 employees

Treating your people right is one job. Proving it is another.

Only the second one has a penalty attached. Kris Carmichael is a former workers' comp claims adjuster who has spent more than 30 years in employers' corner. She builds the record that protects you from PAGA claims, Cal/OSHA citations, and runaway comp costs, and she shows up in person when something goes wrong.

Former WC claims adjuster 30+ years with CA employers On site, 24/7
Employer file
15%THE 15% FILE
  • ✓Payroll audits, with action on what they find
  • ✓Written wage-and-hour policies, delivered to staff
  • ✓Supervisor training on the Labor Code and wage orders
  • ✓Corrective action, documented
BEFORE THE NOTICE

PAGA after the 2024 reform · AB 2288 / SB 92

Two penalty caps. The cheaper one
expires the day a notice arrives.

California's 2024 PAGA reform lets an employer's penalties be capped if it can show reasonable steps to comply. When you take those steps decides which cap you can argue for.

15%

Steps taken before

Reasonable steps in place before a PAGA notice or a personnel records request. This is the proactive path, and almost no one is building for it.

30%

Steps taken after

Reasonable steps taken within 60 days after a notice. This is the path most employers find out about once they've been served.

The trap most owners never seeA letter demanding employee payroll or personnel records (Lab. Code §226, §432, §1198.5) often arrives before any PAGA notice. Once that request lands, the 15% path is closed. It usually comes through your insurance broker's mail, which is one reason Kris watches for it.

The flagship engagement

The 15% File

A documented, dated record of the reasonable steps the statute describes, built before anyone sends you a notice. Kris assembles it with you and keeps it current, and your employment counsel reviews it.

PAYROLL

Audit and act

Periodic payroll audits, and a record of what you fixed afterward. An audit alone doesn't count.

POLICY

Written and delivered

Lawful wage-and-hour policies in writing, with proof your people received them.

SUPERVISORS

Trained

Supervisors trained on the Labor Code and the wage orders that apply to your industry.

ACCOUNTABILITY

Corrective action

When a supervisor gets it wrong, the correction is documented and dated.

The 15% File supports your claim to the lower cap. It does not guarantee one. Kris is not an attorney and does not give legal advice. She works alongside your employment counsel, and when a question is legal, she puts it in front of the lawyer.

Three risks, one advocate

The same weak spots
show up in all three.

A missed meal break, an unreported injury, and a claim reserve nobody challenged tend to come from the same gaps. Kris treats PAGA, Cal/OSHA, and workers' comp as one problem, because for your business they are.

LAB. CODE §2698 et seq.

PAGA

  • The 15% File, built before any notice
  • Exposure snapshot of pay stubs, meal and rest breaks, and policies
  • Rapid triage when a notice or records demand arrives
  • Document assembly for your employment counsel
CAL/OSHA · TITLE 8

Cal/OSHA

  • 24/7 emergency and inspection response
  • "First 60 Minutes" protocol for when an inspector arrives
  • OSHA 300 log and injury-prevention program review
  • Jobsite safety walks and crew training
EXPERIENCE MOD · CLAIMS

Workers' comp

  • X-mod review and correction
  • Challenges to inflated claim reserves
  • Return-to-work programs
  • Catastrophic loss management on scene

Results for clients

What this looks like on paper.

A few outcomes from Kris's client work. Names are withheld; details are available in conversation.

$3.5MCredit won back on a $5 million paralysis claim, by showing another employer on a multi-employer site was responsible.
1.27 → 0.53Experience mod for an auto group after Kris split out a location that was carrying another store's losses.
$172KRecovered from a workers' comp carrier for one client.
$77KSaved by correcting an 11-point error in a client's experience mod.
0Violations. A Cal/OSHA inspection closed with a no-violation letter.
32 yrsHer longest-standing client relationship, a Bay Area dealership.

Past results don't predict future outcomes. Every claim and inspection turns on its own facts.

Fit

Who Kris works with,
and who she doesn't.

A good fit

  • Owner-operated California businesses, roughly 30 to 300 employees
  • Construction, manufacturing, auto dealerships, and other hands-on trades
  • Hourly workforces, several locations or crews, real injury exposure
  • Owners who want a straight answer and will act on it

Not a fit

  • Anyone looking for the cheapest quote and nothing else
  • Businesses that want the paperwork without changing anything
  • Companies already in litigation who need a lawyer, not a consultant (Kris can help you find one)

How an engagement starts

One conversation first.

Every engagement starts with The Read. If it finds no material exposure, you pay nothing, and Kris puts that in writing for your file.

01

The Read

A 45-minute conversation and a one-page written snapshot of where you're exposed across PAGA, Cal/OSHA, and comp.

No charge
02

The 15% File

The documented reasonable-steps record described above, sized to your headcount and number of locations.

Fixed fee
03

Notice response

A notice or records demand just arrived. Kris triages it fast, organizes the documents, and brings in employment counsel. What to do now →

Fixed fee
04

Standing advocate

Ongoing monthly support: keeping the file current, on-site response, claims advocacy, and supervisor training.

Monthly

Free 45-minute exposure review

Call before the letter comes.

Forty-five minutes, no charge, and a written snapshot you keep either way. If something has already arrived in the mail, call today.

Phone · 24/7 for emergencies510.833.0723
OfficeDublin, California · serving the Bay Area and statewide
Book a call with Kris