Wash. Rev. Code » Title 51 · Chapter 51.16
Revised Code of Washington

Wash. Rev. Code § 51.16.190 (2026)

Limitation on collection actions

✓ current as of May 2026
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(1) "Action" means, but is not limited to, a notice of assessment pursuant to RCW 51.48.120, an action at law pursuant to RCW 51.16.150, or any other administrative or civil process authorized by this title for the determination of liability for premiums, assessments, penalties, contributions, or other sums, or the collection of premiums, assessments, penalties, contributions, or other sums.
(2) Any action to collect any delinquent premium, assessment, contribution, penalty, or other sum due to the department from any employer subject to this title shall be brought within three years of the date any such sum became due.
(3) In case of a false or fraudulent report with intent to evade premiums, assessments, contributions, penalties, interest, or other sums, or in the event of a failure to file a report, action may be begun at any time.
(4) Any claim for refund or adjustment by an employer of any premium, assessment, contribution, penalty, or other sum collected by the department shall be made in writing to the department within three years of the date the sum became due.
[ 1987 c 111 s 7; 1985 c 315 s 5; 1977 ex.s. c 323 s 27.]

Notes:

Conflict with federal requirements—Severability—Effective date—1987 c 111: See notes following RCW 50.12.220.
Severability—Effective date—1977 ex.s. c 323: See notes following RCW 51.04.040.
Notes of Decisions
Cited in 5 cases, 1986–2019 · leading case: Dolman v. Dep't of Labor & Indus., 716 P.2d 852 (Wash. 1986).
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Dolman v. Dep't of Labor & Indus., 716 P.2d 852 (Wash. 1986). · cites it 7× “Additionally, RCW 51.16.190 was amended to define "action" to include a notice of assessment as well as a court action.”
Paris Am. Corp. v. McCausland, 759 P.2d 1210 (Wash. Ct. App. 1988). “In Dolman , the court held that the word "action" in RCW 51.16.190(1) was ambiguous. The court construed the word "action" in that statute to include the issuance of a notice of assessment by the Department of Labor and Industries, as well as actions in superior court.”
Floor Decorators, Inc. v. Dep't of Labor & Indus., 44 Wash. App. 503 (Wash. Ct. App. 1986). · cites it 3× “2d 852 (1986), in which our Supreme Court held that the applicable statute of limitations (cited as RCW 51.16.190(1) in Dolman , but later codified as RCW 51.”
Sidis v. Brodie/Dohrmann, Inc., 794 P.2d 1309 (Wash. Ct. App. 1990). “2d 852 (1986) ("action" as used in RCW 51.16.190(1) is ambiguous and "is not a word of art which carries its own definition").”
Steven G. Hopkins v. Dep't Of Labor & Indus. (Wash. Ct. App. 2019). · cites it 3× “4 RCW 51.16.190(1) provides: “Action” means, but is not limited to, a notice of assessment pursuant to RCW 51.”
— Wash. Rev. Code § 51.16.190(1) — 5 cases
Dolman v. Dep't of Labor & Indus., 716 P.2d 852 (Wash. 1986). “Additionally, RCW 51.16.190 was amended to define "action" to include a notice of assessment as well as a court action.”
Paris Am. Corp. v. McCausland, 759 P.2d 1210 (Wash. Ct. App. 1988). “In Dolman , the court held that the word "action" in RCW 51.16.190(1) was ambiguous. The court construed the word "action" in that statute to include the issuance of a notice of assessment by the Department of Labor and Industries, as well as actions in superior court.”
Sidis v. Brodie/Dohrmann, Inc., 794 P.2d 1309 (Wash. Ct. App. 1990). “2d 852 (1986) ("action" as used in RCW 51.16.190(1) is ambiguous and "is not a word of art which carries its own definition").”
Floor Decorators, Inc. v. Dep't of Labor & Indus., 44 Wash. App. 503 (Wash. Ct. App. 1986). “2d 852 (1986), in which our Supreme Court held that the applicable statute of limitations (cited as RCW 51.16.190(1) in Dolman , but later codified as RCW 51.”
Steven G. Hopkins v. Dep't Of Labor & Indus. (Wash. Ct. App. 2019). “4 RCW 51.16.190(1) provides: “Action” means, but is not limited to, a notice of assessment pursuant to RCW 51.”
— Wash. Rev. Code § 51.16.190(2) — 2 cases
Floor Decorators, Inc. v. Dep't of Labor & Indus., 44 Wash. App. 503 (Wash. Ct. App. 1986). “2d 852 (1986), in which our Supreme Court held that the applicable statute of limitations (cited as RCW 51.16.190(1) in Dolman , but later codified as RCW 51.”
Steven G. Hopkins v. Dep't Of Labor & Indus. (Wash. Ct. App. 2019). “4 RCW 51.16.190(1) provides: “Action” means, but is not limited to, a notice of assessment pursuant to RCW 51.”
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