Justice Kennedy found it unnecessary to "reiterate the plurality's persuasive discussion on this point." ( Gade, supra , 505 U.S. at p. 113, 112 S.Ct. 2374.) The plurality similarly observed that although the two opinions disagreed concerning the category of preemption, they agreed on federal OSHA's preemptive scope, based on the language of 29 United States Code section 667. ( Id . at p. 104, fn. 2, 112 S.Ct. 2374.)
II. Discussion
The Court of Appeal held that the UCL and FAL claims are preempted by the federal OSH Act both expressly and through application of the principles of implied preemption. It concluded that Congress has essentially occupied the entire field of workplace safety regulation and enforcement other than workers' compensation and the precise provisions of an approved state plan. It reasoned that "[b]ecause the [federal] OSH Act allows a state to avoid *337federal preemption only if it obtains federal approval of its own plan, it necessarily follows that a state has no authority to enact and enforce laws governing workplace safety which fall outside of that approved plan." In its view, the district attorney's use of UCL and FAL actions based upon violations of approved Cal/OSHA standards was an attempt to govern workplace safety without securing approval by the federal Secretary of Labor.
As the Court of Appeal observed, the federal OSH Act expressly states what is not preempted-state laws governing workers' compensation, a broad category of statutory and common law actions touching on worker safety, and any occupational safety or health issue as to which there is no federal standard. ( 29 U.S.C. §§ 653(b)(4) [workers' compensation and *421other laws related to worker safety], 667(a) [no federal standard].) As the Court of Appeal's analysis further reflects, the federal OSH Act does not expressly describe what state regulation is preempted. This omission does not preclude a finding of explicit preemption; as Justice Kennedy noted in Gade, the high court has "never required any particular magic words" to establish express preemption. ( Gade, supra , 505 U.S. at p. 112, 112 S.Ct. 2374.) But as illustrated by Justice Kennedy's concurring opinion, when a court attempts to discern from a statutory scheme the expression of an intent to displace state law, the analysis may be substantially similar to an implied preemption analysis. Therefore, we will first address whether preemption of the UCL and FAL claims is implied. As will be seen, this analysis also resolves the issue of whether the federal scheme explicitly preempts these claims.
A. No implied preemption of UCL and FAL claims
1. Field preemption
a. The field preempted is narrow
In enacting the federal OSH Act, Congress entered "a field that traditionally had been occupied by the States. Federal regulation of the workplace was not intended to be all **45encompassing, however." ( Gade , supra , 505 U.S. at p. 96, 112 S.Ct. 2374 (plur. opn. of O'Connor, J.); see United Air Lines , supra , 32 Cal.3d at p. 772, 187 Cal.Rptr. 387, 654 P.2d 157 ["Despite a broad authorization to [the federal OSH Act] ..., the act did not foreclose other federal agencies or states from exercising ... jurisdiction" over occupational safety and health].) Unlike some federal statutes, 29 United States Code section 667 does not employ broad language preempting all state regulation, laws, or remedies relating to, concerning, or merely touching on the issue at hand, namely occupational safety and health. (See, e.g., 21 U.S.C. § 360k(a) [except as specifically provided, "no State ... may establish or continue in effect with respect to *338[medical devices] any requirement ... different from, or in addition to, any requirement [under the specific federal law]"; 29 U.S.C. § 1144(a) [ERISA preempts "any and all State laws insofar as they may now or hereafter relate to any employee benefit plan"]; 49 U.S.C. § 14501(c)(1) ["[A] State ... may not enact or enforce a law, regulation, or other provision having the force and effect of law related to a price, route, or service of any motor carrier ... with respect to the transportation of property"]; id ., § 41713(a)(4)(A) ["[A] State ... may not enact or enforce a law ... related to a rate, route, or service of an air carrier"].)
Moreover, various elements of the federal OSH Act convince us that the preempted field is narrow. First, we have seen that when there is no federal standard, there is no preemption. ( 29 U.S.C. § 667(a).) This provision acknowledges that federal authority does not occupy the entire field. Rather, states retain authority freely to apply their own law in the field of occupational safety or health when the Secretary has not promulgated an applicable federal standard.
Second, even when there are federal standards, states may "assume responsibility for development and enforcement" of state occupational safety and health standards, provided the state submits and gains approval for a state plan. ( 29 U.S.C. § 667(b).) Under the terms of the statute, an approved state plan "preempts" federal standards. ( 29 U.S.C. § 667(b) [entitled "Submission of State plan for development and enforcement of State standards to preempt applicable Federal standards"]; see also Gade , supra , 505 U.S. at p. 119, 112 S.Ct. 2374 (dis. opn. of Souter, J.) [this heading was "enacted as *422part of the statute and properly [may be] considered under our canons of construction"].) In other words, once the state plan is adopted and approved, state law has the effect of broadly preempting parallel federal law . (See Gade , supra , 505 U.S. at pp. 96-97, 112 S.Ct. 2374 (plur. opn. of O'Connor, J.) [observing that 29 U.S.C. § 667(b)"gave the States the option of pre-empting federal regulation entirely"]; United Air Lines , supra , 32 Cal.3d at p. 772, 187 Cal.Rptr. 387, 654 P.2d 157 [adoption of an approved plan "removes federal preemption so that the state may exercise its own sovereign powers over occupational safety and health"].) In addition, states can provide greater protection if they adopt their own plans with standards and enforcement that are at least as protective as federal law. ( 29 U.S.C. § 667(c)(2).)
We acknowledge that the Secretary of Labor has authority to approve modifications to a state's plan ( 29 U.S.C. § 667(c) ) and "shall ... make a continuing evaluation of the manner in which each State having a plan ... is carrying out such plan." ( Id ., § 667(f).) Notwithstanding these provisions, the federal OSH Act as a whole does not suggest that the preempted field encompasses all means of enforcement not specifically included in the state's *339approved plan. On the contrary, the federal OSH Act encourages states to "assume the fullest responsibility for the administration and enforcement of their occupational safety and health laws." ( 29 U.S.C. § 651(b)(11).) In addition, it directs that the Secretary "shall" approve a conforming state plan or modification, and places administrative limits on the Secretary of Labor's discretion to reject state plans. ( Id ., § 667(d).) And as we have observed, once a state plan is approved, it is federal , not state, law that must give way. ( 29 C.F.R. § 1953.3(a) (2017) [federal approval of a state plan "in effect removes the barrier of Federal preemption, and permits the State to adopt and enforce State standards," including adopting and implementing modifications].) Finally, even if **46any new enforcement method that is related to an existing approved standard should be submitted to the Secretary-a question we need not answer-it does not follow that the new method is preempted until approved. State modifications to an approved plan go into effect immediately, subject to a review by the Secretary. ( 67 Fed.Reg. 60122 (Sept. 25, 2002) ; see also 62 Fed.Reg., supra , at p. 31165 [a modification "takes effect prior to and pending OSHA review of the modification"].)
Third, the federal OSH Act's savings clause ( 29 U.S.C.§ 653(b)(4) ) leads us to infer a narrow field of implied preemption. That provision disclaims any intent to interfere with state law in a broad domain affecting occupational safety and health, whether or not there is an approved state plan. Specifically, notwithstanding the existence of federal standards, not only are state workers' compensation actions not preempted, but state tort claims and criminal prosecutions also survive, although they may be based on duties established by state occupational safety and health standards. (See Pedraza v. Shell Oil Co. (1st Cir. 1991) 942 F.2d 48, 53-54, and cases cited [tort claims not preempted: "[W]e find no warrant whatever for an interpretation which would preempt enforcement in the workplace of private rights and remedies traditionally afforded by state laws of general application"]; State v. Far West Water & Sewer (2010) 224 Ariz. 173, 228 P.3d 909, 919, and cases cited [no preemption of prosecution under state criminal law punishing conduct that is also governed by federal occupational safety and health standards, the existence of some criminal penalties within the federal act itself notwithstanding];
*423People v. Pymm (1990) 76 N.Y.2d 511, 561 N.Y.S.2d 687, 563 N.E.2d 1, 4 [referring to "continued viability of State statutory and common-law duties"].) Indeed, section 653(b)(4) has been interpreted as a uniquely broad savings clause ( In re Welding Fume Products Liability Litigation (N.D.Ohio 2005) 364 F.Supp.2d 669, 687, & fn. 21 ), and broad savings clauses may be seen as an indication that the field preempted is narrow. (See Viva! Internat. Voice for Animals v. Adidas Promotional Retail Operations, Inc. (2007) 41 Cal.4th 929, 944, 63 Cal.Rptr.3d 50, 162 P.3d 569.)
Finally, the provisions we have discussed indicate that the federal OSH Act contemplates a cooperative system of workplace safety regulation, *340not an exclusively federal one. When federal schemes involve cooperation and concurrent jurisdiction, this circumstance also suggests that the scope of preemption was not intended to be broad. ( Olszewski, supra , 30 Cal.4th at p. 816, 135 Cal.Rptr.2d 1, 69 P.3d 927 [" 'Where ... coordinate state and federal efforts exist within a complementary administrative framework, and in the pursuit of common purposes, the case for federal pre-emption becomes a less persuasive one' "].)
b. The UCL and FAL claims do not fall within this narrow field of preemption
Laws of general application are not ordinarily preempted by the federal act. ( Gade , supra , 505 U.S. at p. 107, 112 S.Ct. 2374 (plur. opn. of O'Connor, J.); id . at p. 114, 112 S.Ct. 2374 (conc. opn. of Kennedy, J.).) As explained below, under state law, actions under the UCL or FAL are not considered to be a means of enforcing the law claimed to have been violated; rather, they provide a remedy for economic damage suffered as a result of violations of a wide array of other laws. Furthermore, to the extent these claims may be a considered an enforcement mechanism with respect to the state plan's substantive standards, these claims merely supplement enforcement of state standards. Federal OSHA's provisions related to the enforcement of state plans are concerned with ensuring enforcement that is at least as effective as the federal standards; nothing in the federal act suggests a concern with enforcement that exceeds federal requirements.
The UCL concerns unfair competition, a term that "mean[s] and include[s] any unlawful, unfair or fraudulent business act or practice and unfair, deceptive, untrue or misleading advertising and any act prohibited by [the false advertising law]." ( Bus. & Prof. Code, § 17200.) The purpose of the UCL "is to protect both consumers and competitors **47by promoting fair competition in commercial markets for goods and services." ( Kasky v. Nike, Inc. (2002) 27 Cal.4th 939, 949, 119 Cal.Rptr.2d 296, 45 P.3d 243.) As we have said, "the act provides an equitable means through which both public prosecutors and private individuals can bring suit to prevent unfair business practices and restore money or property to victims of these practices." ( Zhang v. Superior Court (2013) 57 Cal.4th 364, 371, 159 Cal.Rptr.3d 672, 304 P.3d 163, italics added.) The FAL, for its part, makes actionable "untrue or misleading" statements made to "induce the public to enter into any obligation" to purchase goods and services. ( Bus. & Prof. Code, § 17500.) Actions to enforce the UCL or FAL, which may be brought by government officials and by individuals who have suffered injury in fact ( Bus. & Prof. Code, § 17203 ), address the " ' "overarching legislative concern ... to provide a streamlined procedure for the prevention of ongoing or threatened acts of unfair competition ." [Citation.]' " ( *424Zhang , supra , 57 Cal.4th at p. 371, 159 Cal.Rptr.3d 672, 304 P.3d 163, *341italics added.) And the remedies are "cumulative ... to the remedies or penalties available under all other laws of this state." ( Bus. & Prof. Code, § 17205.)
As noted above, under state law, these actions are not considered on their face to be a means of enforcing the underlying law. " 'By proscribing "any unlawful" business practice, "[the UCL] 'borrows' violations of other laws and treats them as unlawful practices" that the [UCL] makes independently actionable. [Citations.]' " ( Rose v. Bank of America, N.A. (2013) 57 Cal.4th 390, 396, 159 Cal.Rptr.3d 693, 304 P.3d 181.) We have explained that "by borrowing requirements from other statutes, the UCL does not serve as a mere enforcement mechanism. It provides its own distinct and limited equitable remedies for unlawful business practices, using other laws only to define what is 'unlawful.' [Citation.] The UCL reflects the Legislature's intent to discourage business practices that confer unfair advantages in the marketplace to the detriment of both consumers and law-abiding competitors." ( Id . at p. 397, 159 Cal.Rptr.3d 693, 304 P.3d 181 ; see People ex rel. Harris v. Pac Anchor Transportation, Inc. (2014) 59 Cal.4th 772, 783, 174 Cal.Rptr.3d 626, 329 P.3d 180 [Federal Aviation Administration Act does not on its face preempt UCL claims against motor carriers for misclassification of drivers]; In re Tobacco Cases II (2007) 41 Cal.4th 1257, 1272, 63 Cal.Rptr.3d 418, 163 P.3d 106 [a federal law governing cigarette sales to minors on its face did not expressly preempt the UCL, which "is a law of general application, and it is not based on concerns about smoking and health"]; Korea Supply Co. v. Lockheed Martin Corp. (2003) 29 Cal.4th 1134, 1150, 131 Cal.Rptr.2d 29, 63 P.3d 937 ; Cel-Tech Communications, Inc. v. Los Angeles Cellular Telephone Co. (1999) 20 Cal.4th 163, 180, 83 Cal.Rptr.2d 548, 973 P.2d 527 ; Stop Youth Addiction, Inc. v. Lucky Stores, Inc. (1998) 17 Cal.4th 553, 560, 566 576, 71 Cal.Rptr.2d 731, 950 P.2d 1086.) Thus, the UCL and FAL are laws of general application.
We acknowledge that in some instances, a UCL claim may fall within a field of preemption. For example, in In re Tobacco Cases II, supra, 41 Cal.4th 1257, 63 Cal.Rptr.3d 418, 163 P.3d 106, a UCL claim based on advertising activities alleged to violate Penal Code section 308 (prohibiting sale of tobacco products to minors and possession of such products by minors) was preempted as applied under the particular terms of a federal law governing cigarette labeling and advertising. ( Id. at pp. 1272-1273, 63 Cal.Rptr.3d 418, 163 P.3d 106.) Under the federal law involved, preemption turned on whether the particular UCL claim would impose a duty necessarily and inherently based on concerns about smoking and health. ( Id . at p. 1273, 63 Cal.Rptr.3d 418, 163 P.3d 106.) But here, the UCL and FAL claims are based on standards set forth in an approved state plan, and which therefore preempt any federal standards . Because these claims do not impose any duty on *342employers that is subject to federal preemption, they do not come within the principles articulated in Tobacco Cases II .
We also recognize that the federal OSH Act is concerned not only with a state's substantive standards, but also with its enforcement.
**48( 29 U.S.C. § 667(b) [a state that wants to assume responsibility for "development and enforcement" of standards must submit a state plan for "development of such standards and their enforcement"].) Therefore, when UCL and FAL claims are premised on violations of a state's plan, the UCL and FAL arguably come within the high court's description of an occupational safety and health standard *425in the context of the federal OSH Act: "a state law requirement that directly, substantially, and specifically regulates occupational safety and health." ( Gade, supra , 505 U.S. at pp. 107, 112 S.Ct. 2374 (plur. opn. of O'Connor, J.); id . at p. 114, 112 S.Ct. 2374 (conc. opn. of Kennedy, J.).)
Notably, however, the federal OSH Act's concern regarding enforcement is only that states provide enforcement "at least as effective" as required under the federal OSH Act. ( 29 U.S.C. § 667(c)(2) ; see 29 C.F.R. § 1902.3(d) (2017).) Its focus on adequate enforcement, and its silence with respect to enforcement that is more than adequate or is pursued through mechanisms other than those set forth in a state's plan, lead us to conclude that the federal OSH Act's scheme is not " ' "so pervasive as to make reasonable the inference that Congress left no room for the States to supplement it." ' " ( Gade, supra , 505 U.S. at p. 98, 112 S.Ct. 2374 (plur. opn. of O'Connor, J.).) California has provided adequate enforcement provisions through its plan, and there is no "unavoidable implication" to be derived from the federal OSH Act that where a state has met this federal requirement, Congress intended to preclude supplemental enforcement of approved standards. ( Id . at p. 99, 112 S.Ct. 2374.)
Our conclusion is consistent with the decision of the federal Department of Labor approving California's Hazard Communication Standard (Standard), which incorporated provisions from Proposition 65, the Safe Drinking Water and Toxic Enforcement Act. ( Health & Saf. Code, §§ 25249.5 et seq. ; 62 F.R. § 31159-01.) In addition to adopting the substantive standards of Proposition 65, "the Cal/OSHA standard incorporate[d] the enforcement mechanism of Proposition 65, which provides for supplemental judicial enforcement by allowing the State Attorney General, district attorneys, city attorneys, city prosecutors, or 'any person in the public interest' to file civil lawsuits against alleged violators." (62 Fed.Reg., supra , at p. 31161.) Some comments regarding the proposed Standard contended that Proposition 65's private right of action violated the federal requirement that an agency be designated to enforce the state plan. The Board's decision noted that "[i]f a State standard is not identical to Federal standards, the State standard (and its enforcement) must be at least as effective as the comparable Federal standard." (62 Fed.Reg, supra , at p. 31160.) It also observed, "Although [the *343federal OSH Act] does not authorize private enforcement, OSHA State plans do not operate under a delegation of Federal authority but under a system which allows them to enact and enforce their own laws and standards under State authority. Therefore, nothing in the Act prevents States with approved plans from legislating such a supplemental private right of action in their own programs.... [¶] In the case of Proposition 65, private enforcement is supplemental to, not a substitute for, enforcement by Cal/OSHA. Private enforcement, therefore, should not detract from Cal/OSHA's responsibilities to enforce State standards." (Id ., p. 31167.)
The federal Department's consideration of Proposition 65 occurred in the context of an approval of a plan amendment, but Congress has not specified (as it has elsewhere) that any amendments to the state plan-even as to substantive standards-must be submitted to the Secretary of Labor for approval before they are implemented. (See, e.g., 7 U.S.C. § 6507(c)(2) [in context of changes to federally-approved supplemental state requirements for organic food certification, governing state official, "prior to implementing any substantive change to programs approved under this subsection, shall submit such change *426to the Secretary for approval"].) In addition, as explained above, the federal OSH Act's provisions related to the authority of the Secretary of Labor to approve modifications to a state plan and to evaluate a state's execution of its plan ( 29 U.S.C. § 667(c), (f) ) raise the potential that a modification may be rejected or that approval of a plan may be withdrawn, but these provisions **49leave the state plan intact and do not preempt state law before a modification is rejected or approval is withdrawn. There is no indication in these provisions that any state deviation from the formally approved plan is, by some self-executing feature, without effect until it is brought to the Secretary's notice and formally approved as an amendment.
Federal regulations and commentary are in accord that changes to state plans may be implemented immediately, prior to any action by the Secretary of Labor or that officer's designee, federal OSHA: "Federal OSHA approval of a State plan ... in effect removes the barrier of Federal preemption, and permits the State to adopt and enforce State standards and other requirements regarding occupational safety or health issues regulated by OSHA. A State with an approved plan may modify or supplement the requirements contained in its plan, and may implement such requirements under State law, without prior approval of the plan change by Federal OSHA. Changes to approved State plans are subject to subsequent OSHA review. If OSHA finds reason to reject a State plan change, and this determination is upheld after an adjudicatory proceeding, the plan change would then be excluded from the State's Federally-approved plan." ( 29 C.F.R. § 1953.3(a) (2017).) Federal OSHA explained that this regulation reflects the agency's "longstanding interpretation of the Act to the effect that States which have submitted and obtained Federal approval of a State plan under [the federal OSH Act] may adopt *344modifications to their State plan (such as new standards, regulations, amendments to State OSHA legislation, or revised enforcement procedures ) and may implement these modifications upon adoption, without prior approval of each particular modification.... OSHA has always viewed its enabling statute as not requiring pre-enforcement/pre-implementation Federal approval...." (67 Fed.Reg., supra , at p. 60123, italics added; see also 62 Fed.Reg., supra , at p. 31165 ["A modification to an approved State plan takes effect prior to and pending OSHA review of the modification" and the burden of proof rests on the party opposing the modification]; see Florida Citrus Packers v. California (N.D.Cal. 1982) 545 F.Supp. 216, 219 [upholding federal OSHA's pre-approval enforcement policy]; see also Shell Oil Co. v. U.S. Dept. of Labor (D.D.C. 2000) 106 F.Supp.2d 15, 18 [noting in passing that federal OSHA routinely applies this pre-approval enforcement policy].)6 *427Finally, we reiterate the strong presumption against preemption, arising both from the fact that the federal legislation addresses an area that has been the long-standing subject of state regulation and from the fact that California has assumed responsibility under **50the federal OSH Act to regulate worker safety and health, thereby preempting federal law. In light of the cooperative character of the federal OSH Act, the authority the federal OSH Act grants states that have assumed responsibility for worker safety and health, the nature of UCL and FAL claims, and the strong presumption against preemption, we find no implied preemption of the claims in this case. *3452. Obstacle preemption
To recall, "Obstacle preemption permits courts to strike state law that stands as 'an obstacle to the accomplishment and execution of the full purposes and objectives of Congress.' [Citations.] It requires proof Congress had particular purposes and objectives in mind, a demonstration that leaving state law in place would compromise those objectives, and reason to discount the possibility the Congress that enacted the legislation was aware of the background tapestry of state law and content to let that law remain as it was." ( Quesada , supra , 62 Cal.4th at p. 312, 195 Cal.Rptr.3d 505, 361 P.3d 868.) We "conduct our analysis from the starting point of a presumption that displacement of state regulation in areas of traditional state concern was not intended absent clear and manifest evidence of a contrary congressional intent." ( Id . at p. 315, 195 Cal.Rptr.3d 505, 361 P.3d 868 ; see also Iskanian v. CLS Transportation Los Angeles, LLC (2014) 59 Cal.4th 348, 388, 173 Cal.Rptr.3d 289, 327 P.3d 129 [a high threshold must be surmounted before obstacle preemption will be found].)
The principal goal of the federal OSH Act's enactment was to "address the problem of uneven and inadequate state protection of employee health and safety" by supplying a minimum level of protection throughout the country-a federal "nationwide 'floor' of minimally necessary safeguards." ( United Air Lines , supra , 32 Cal.3d at p. 772, 187 Cal.Rptr. 387, 654 P.2d 157.) Federal approval of the California plan indicates that this goal has been met in this state. Even if we view UCL and FAL actions based on Cal/OSHA violations as having a substantial impact on occupational safety and health issues, that impact is not an obstacle to achieving the congressional purpose, nor are additional enforcement mechanisms an obstacle to establishing at least a minimum level of worker protection.7
*428Similarly, UCL and FAL claims that are premised on Cal/OSHA violations do not conflict with the federal OSH Act's provision that when state standards are applicable to products in interstate commerce, the Secretary of Labor must determine that the standards "are required by compelling local conditions and do not unduly burden interstate commerce." ( 29 U.S.C. § 667(c)(2).) Such claims involve the same substantive standards that have *346been approved by the Secretary, and therefore do not impose any greater substantive burdens on interstate commerce. Even if the availability of greater penalties should be incorporated into the state plan and submitted to the Secretary of Labor for review of any impact on interstate commerce, it does not follow that any change that has not yet been incorporated and approved is preempted in the meantime.
Neither do the UCL or FAL claims obstruct another of the federal OSH Act's purposes, namely to encourage the States "to assume the fullest responsibility for the administration and enforcement of their occupational safety and health laws." ( 29 U.S.C. § 651(b)(11) ; see also 29 C.F.R. § 1902.1(a) (2017), see id . § 1902.1(c)(1) (2017) [after an approved plan gains successful review the year following its initial approval, the federal "enforcement authority shall not apply with respect to any occupational safety or health issue covered by the plan"].) "OSHA has interpreted the OSH Act to recognize that States with approved State plans retain broad power to fashion State standards" and **51to experiment. (62 Fed.Reg., supra , p. 31160, italics added.) The federal OSH Act "reflects [a] 'search for enlightened public policy' ... by removing the bar of preemption through plan approval and, thus, allowing States to administer their own workers' protection laws so long as they meet the floor established by the Federal OSHA program." (Ibid .) We can identify no evidence that Congress had a "particular purpose[ ] and objective[ ]" to restrict state authority to the exact terms of the state's approved state plan. (See Quesada , supra , 62 Cal.4th at p. 312, 195 Cal.Rptr.3d 505, 361 P.3d 868.)
Finally, there is no reason to "discount" Congress's awareness and acceptance of the "background tapestry" of state law in this area. ( Quesada , supra , 62 Cal.4th at p. 312, 195 Cal.Rptr.3d 505, 361 P.3d 868 ) In the federal OSH Act's savings clause, Congress explicitly recognized the continuing applicability of state law in the field. (See 29 U.S.C. § 653(b)(4).) Under that clause, tort litigation could produce large civil awards and penalties despite the existence of a more modest state administrative enforcement plan, but such litigation is not preempted. Therefore, the magnitude of the potential UCL and FAL penalties compared with the lesser administrative penalties imposed under the state plan are not inconsistent with the federal scheme.
Under the circumstances, there is no "clear and manifest evidence" ( Quesada , supra , 62 Cal.4th at p. 315, 195 Cal.Rptr.3d 505, 361 P.3d 868 ) of a congressional intent to displace state authority over unfair competition and consumer claims that are premised on Cal/OSHA standards.
*347B. No express preemption of UCL and FAL claims
As noted above, the federal OSH Act does not state that claims such as *429UCL and FAL claims or that enforcement actions beyond those specified in a state plan are preempted until they are included in a plan and approved by the Secretary of Labor. However, despite the absence of such a statement, express preemption may be found where an act's structure and language reflect a clear purpose of Congress to preempt state law. (See Gade , supra , 505 U.S. at pp. 112-113, 112 S.Ct. 2374 (conc. opn. of Kennedy, J.) [express preemption of state law established by federal OSH Act provisions that allow state regulation where there is no relevant federal standard, require a state to submit a plan in order to assume responsibility for worker safety and health, set forth conditions for approval of a plan, and require continuing evaluation of a plan by the Secretary of Labor].)
As our discussion above of implied preemption reflects, when a state has obtained approval of a state plan for the regulation of worker safety and health, state law preempts federal law. Moreover, with respect to the enforcement of safety and health standards, the federal OSH Act requires enforcement at least as effective as under the federal act; there is no indication in the language or structure of the federal OSH Act that states with approved plans cannot supplement enforcement of federally-approved standards by means of unfair business practice claims. (See Farm Raised Salmon Cases , supra , 42 Cal.4th at p. 1090, 72 Cal.Rptr.3d 112, 175 P.3d 1170 [permitting UCL claim to proceed and finding it significant that nothing in the federal Food, Drug and Cosmetic Act said anything restricting the range of remedies states could provide].) Finally, the federal OSH Act allows a state with an approved plan to implement modifications or additions without prior approval of the plan change by Federal OSHA.
In the absence of a clear and manifest congressional purpose to preempt claims such as the UCL and FAL claims asserted in this action, such claims are encompassed in the presumption against preemption that arises upon a state's assumption of responsibility under the federal OSH Act to regulate worker safety and health. (See Quesada , supra , 62 Cal.4th at p. 315, 195 Cal.Rptr.3d 505, 361 P.3d 868.)
III. Disposition
The judgment of the Court of Appeal is reversed, and the matter is remanded to the Court of Appeal with directions to vacate its order granting the petition for writ of mandate and instead to deny the petition for writ **52of *348mandate, and to remand the matter to the trial court for further proceedings not inconsistent with this opinion.
WE CONCUR:
CHIN, J.
CORRIGAN, J.
LIU, J.
CUÉLLAR, J.
KRUGER, J.
MIHARA, J.*