Combining breaks

In WA State, 10 minute breaks are required for every 4 hours worked and must take place by the 3rd hour.  In our retail locations, because lunch hours need to be staggered to ensure consistent customer service is available, they range from late morning to mid afternoon. Customer Service Reps start work at 8:30. The first lunch break is scheduled at 11:00. Site supervisors have developed a practice of giving that employee a 30 min break in the afternoon, rather than trying to squeeze a 15 min break in the morning.  The same is done with the employee going to a 2:00 lunch, but with 30 min in the morning.  (All rest breaks are paid time & lunch breaks are unpaid.)

Is this practice consistent with the law?

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