In Fernandez v. Lawson (2003) 31 Cal.4th 31, the California Supreme Court defined the "'household domestic service'" exception to include a tree trimmer hired by a private homeowner. (Id. at p. 36.) The court explained that the "'household domestic service'" exception applies to work connected with maintaining "'a private household or its premises by an employee of a private householder'" and "implies duties that are personal to the homeowner, not those which relate to a commercial or business activity . . . ." (Id. at pp. 36-37.) The court also stated that "overwhelming public policy and practical considerations make it unlikely the Legislature intended the complex regulatory scheme that is Occupation Safety and Health Act (OSHA) to apply to a homeowner hiring a worker to perform tree trimming. It is doubtful the average homeowner realizes tree trimming can require a contractor's license, let alone 'expects that OSHA requirements would apply when they hire someone to trim a tree for their own personal benefit and not for a commercial purpose . . . . Moreover, homeowners are ill-equipped to understand or to comply with the specialized requirements of OSHA.'" (Id. at p. 37.)