June 2025
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July 2025
La Rosa advised employers to conduct internal I-9 audits annually, ideally with the help of counsel or a trained HR prof- essional. “The worst time to find out you’ve been doing it wrong is when ICE is standing in your lobby.”
Common Pitfalls in the Pallet Sector
La Rosa identified several immigration com- pliance vulnerabilities common in the pallet and wood packaging industries:
High turnover and informal hiring: “Some companies rely on word-of-mouth referrals or hire people without proper documen- tation checks. That’s risky,” she said.
Lack of training: HR staff often don’t receive adequate training on how to complete and store I-9s properly.
Record retention issues: Employers must retain I-9s for a specific period, but many toss them too early, or keep them too long without reason. “Just because you’re a small business doesn’t mean you’re not subject to enforcement. ICE audits mom-and-pop shops too,” she noted. "There’s no safe harbor.”
Reform and the Uncertain Path Forward
While immigration reform continues to stall in Congress, La Rosa noted that states like California are taking matters into their own hands. New labor laws now place additional pressure on employers to ensure not only legal hiring practices but also the safe and equitable treatment of immigrant workers.
“There’s growing concern around retal- iation,” she said. “If a worker complains about conditions or pay and is then threatened with immigration-related con- sequences, that’s a huge red flag.”
One area to watch is the increasing enforcement of state labor laws in parallel with federal immigration audits. “The days of flying under the radar are over,” La Rosa said.
What Employers Can Do Now
Immigration enforcement is ramping up across multiple fronts, and La Rosa emphasized that “employers need to be proactive, not reactive.” Here are five con- crete steps pallet businesses can take now to reduce risk and prepare for possible audits or visits:
1. Prepare for an I-9 Audit or Investigation
“Make sure your I-9 forms are ready,” La Rosa said. “It’s often the first thing they ask for.” She advised companies to review their I-9 files regularly, ensure all sections are complete, and that documentation is properly stored — ideally separate from general HR files. Employers should also conduct internal audits or engage third-party consultants to review forms and correct technical issues.
2. Maintain a Centralized Database of Employee Information
Keeping a secure, up-to-date database can save time and reduce panic in the event of enforcement action. La Rosa recommended documenting each employee’s immigration status, employment authorization dates, and copies of related documents (such as work permits or visa approvals). “It’s better to be over-prepared than scrambling to pull files while an agent is standing in your lobby,” she noted.
3. Establish and Train on Enforcement Protocols
Develop clear written protocols for how to respond to site visits by ICE or other federal agents. These should cover who is authorized to speak with agents, how to verify warrants, and what steps to take if asked for access to non-public areas or employee records. “Training your staff is essential,” La Rosa said. “They should know what to do before anyone knocks on the door.”
4. Use Signage Strategically
Posting signs that designate “Private — No Entry Without Permission” in non-public work areas is both a legal and practical defense. “Unless an officer has a valid warrant, you do not have to allow them into private areas,” La Rosa explained. These signs reinforce that boundary and help avoid misunderstandings during a tense interaction.
5. Evaluate Sponsorship Options Thoughtfully
While not appropriate for every position, sponsoring a valued employee for legal status — through H-2B, TN, or green card processes — can be a strategic investment. “It’s a longer game,” La Rosa said, “but for the right employee, it can be worth it.” She urged companies to consider this only after weighing legal costs, wait times, and the employee’s fit within the long-term business plan.
Finally, she stressed the need to challenge internal assumptions. “Don’t assume you can’t hire someone because of their immigration background,” she urged. “Talk to a professional. The paperwork may seem complicated, but don’t close the door without understanding what’s possible.”
By acting now, at the local level, with good advice, La Rosa believes pallet companies can meet urgent labor needs and become part of a more inclusive and resilient workforce strategy.