What does California require when the people in your training speak more than one language?

Three rules put language in the text of the law. The wage notice a California employer gives at hire has to be written in the language the employer normally uses to communicate employment-related information to that employee (Lab. Code 2810.5(a)(1)). The harassment policy has to be translated where 10 percent or more of the workforce at a facility speaks a language other than English as its spoken language (2 CCR 11023(e)). The state discrimination poster follows a parallel 10 percent rule (2 CCR 11013(d)).

I cover the harassment policy rule in detail in language access in live training, so I will not repeat it here. This page is about the training itself and about the order in which to translate the rest.

Language is a matter of compliance and of respect. A person who cannot follow a session is not a participant. They are an attendance record.

Workplace violence prevention training does. Labor Code 6401.9 requires training material appropriate in content and vocabulary to the educational level, literacy and language of employees (Lab. Code 6401.9(e)(1)), and it requires an opportunity for interactive questions and answers with a person knowledgeable about the employer’s plan (section (e)(2)(F)).

The injury and illness prevention program regulation adds that the employer’s system for communicating with employees on safety and health matters has to be in a form readily understandable by affected employees (8 CCR 3203(a)(3)). The text of 3203 does not name a language, but a communication system that a worker cannot read is not readily understandable to that worker.

A session delivered in English to a team that uses another language does not meet the statute’s description of effective training, whatever the sign-in sheet says. The Q&A needs someone who can answer in the language the employee uses.

The training statute, Government Code 12950.1, sets the hours and the cycle for harassment prevention training. I did not find a language threshold in it for the training itself, and the 10 percent translation rule attaches to the written policy.

That gap is a gap in the statute, not a reason to deliver a session people cannot follow. A policy that is translated and a training that is not leaves a team holding a document they understand and a session they did not. If the policy needs translating at your site, deliver the training in a way those employees can follow, with an interpreter, a translated deck or a session in their language. The Legal Side of Training covers the exposure from both sides.

Start where a misunderstanding costs the most, and where the law is most specific. This is my recommended order for an employer of 10 to 150 people, not a statutory order.

1. Workplace violence and injury prevention training materials. The statute names language, and the hazards are physical
2. The harassment policy and harassment training. The policy has a written threshold, and the training reaches supervisors and employees on the cycle
3. The wage notice and onboarding forms. The wage notice has a written language rule, and these documents are the first things a new employee signs
4. The handbook sections on pay, leave, schedules and reporting a concern. These are the sections people look for when something goes wrong
5. Everything else, in the order your team asks for it. Ask them

Do the first item first, then the second. If a budget limit forces a choice, stop after the top three and finish the rest by quarter.

You can use it to produce a first draft. You should not publish it, for any required training or notice, without a qualified bilingual reviewer. I did not find a statute that bans machine translation. The statutes say the material has to suit the employees’ language and be readily understandable, and unreviewed output can fail that test on a single wrong term.

The same goes for a live session. An interpreter is a person with training in the work, not a colleague who happens to speak the language and has been pulled off the floor. For sessions where an employee may need to describe something difficult and be understood exactly, hire the interpreter.

The Spanish pages on this site are at /es/, for employers who want a starting point in Spanish.

Ask, and write down the answer. I do not assume a language from a neighborhood, a name or a job title. A simple onboarding question is enough, and it should be optional to answer.

Record the answer, add it to your roster and review it once a year. Keep it consistent with the language you use in the wage notice, because that notice is tied to the language you normally use to communicate employment information to that employee.

Then count by site. The 10 percent rule works facility by facility, so a roster that shows languages by location is the one you need.

Brief the interpreter before the session. Send the deck, the vocabulary list and the scenarios a week ahead, and tell them which terms in the material are legal terms that need an exact rendering. A good interpreter will ask about the ones you missed.

Then change the pacing. Interpreted sessions run longer, so plan for about half the content in the same time, and cut material rather than rushing it. Speak in short sentences, pause after each idea and avoid idioms that do not travel. Put the slide on screen in the language the group reads, and check understanding by asking people to restate a step, not by asking whether they have questions.

For a mixed room, run one session with consecutive interpretation or two sessions side by side. I choose by headcount. Below about eight people in the second language, one interpreted session works. Above that, a separate session in their language gives them more time to ask.

Record the language of delivery next to the date, the topic, the trainer and the attendee. The workplace violence statute asks for training records that include the training materials’ contents, and the injury and illness regulation asks for documentation of training. A line showing the language and the interpreter or translator you used is cheap to add and is the first thing I would want to see in a review.

Part 5 of this series sets out the full record and how long to keep it.

Does an employee have to ask for training in their language?

No. The workplace violence statute puts the duty on the employer to use material suited to the employees’ language. An employee does not have to make a request first.

Is a translated slide deck enough?

Not on its own. The workplace violence statute also requires interactive questions and answers with a knowledgeable person. If the person cannot answer in the employee’s language, the Q&A requirement is not met in substance.

Does this apply to suburban employers?

Yes. Many suburban workforces use more than one language, and the rules do not change with the setting. Part 1 of this series sets out why the conditions around them do.