HR Compliance

State-by-State Child Labor and Youth Employment Manager Training: Hour Limits, Prohibited Occupations, and Work-Permit Documentation Across CA, NY, TX, FL, and OH

When a scheduling manager puts a 15-year-old on a closing shift or hands a 17-year-old the keys to a pallet jack, the violation is created at the schedule, not at the corporate policy. Federal youth employment rules set the floor, every state adds its own hour and permit layer on top, and when both apply the stricter standard controls — which is exactly what a district manager running stores in five states needs to be trained to recognize.

A free state-coverage check is the fastest way to find out which youth-employment rules actually attach to each location you schedule minors in.

What Do Federal Child Labor Rules Actually Prohibit?

The Fair Labor Standards Act and the youth employment regulations at 29 CFR Part 570 set both hour standards and occupational standards. The age bands are straightforward: at 18 a worker is out of the youth employment provisions entirely; 16 is the basic minimum age for employment, and 16- and 17-year-olds may work unlimited hours in any occupation not declared hazardous; 14- and 15-year-olds may work outside school hours in non-manufacturing, non-hazardous jobs under specified conditions; and children under 14 generally may not be employed in non-agricultural occupations covered by the Act.

Occupational limits are where the money is. The Secretary of Labor has declared 17 Hazardous Occupations Orders that carry an 18-year minimum, and Child Labor Regulation No. 3 also bans 14- and 15-year-olds from any work the HOs proscribe. The ones that surface most often in retail, restaurant, and light-industrial scheduling are HO 7 — operating, riding on, or assisting in the operation of most power-driven hoisting apparatus including forklifts, skid-steers, manlifts, scissor lifts, and boom trucks; HO 10 — operating power-driven meat-processing machines such as slicers, saws, and choppers wherever used, including restaurants and delicatessens, and including cleaning them and hand-washing the disassembled parts, and including using them on cheese and vegetables; HO 12 — all compactors and balers, with a narrow carve-out letting 16- and 17-year-olds load but not operate or unload certain scrap paper balers and paper box compactors; and HO 16 — roofing operations and work on or about a roof, including ground work and removal of the old roof.

Read that carefully: “operation” in HOs 5, 8, 10, 11, 12, and 14 includes setting up, adjusting, repairing, oiling, and cleaning the equipment. A manager who assigns a 17-year-old to break down and wash the deli slicer at close has violated HO 10 even though the minor never sliced anything. That single fact is worth a slide on its own, and it belongs in the same manager-training track as Fair Labor Standards Act 02: FLSA for Managers, since FLSA Sections 12 and 13 are where the youth employment provisions live.

What Hour Limits Apply to 14- and 15-Year-Olds Federally?

Child Labor Regulation No. 3, at 29 CFR 570.35, limits 14- and 15-year-olds to work outside school hours, no more than 3 hours on a school day including Fridays, no more than 8 hours on a nonschool day, no more than 18 hours in a week when school is in session, no more than 40 hours in a week when school is not in session, and only between 7 a.m. and 7 p.m. — except between June 1 and Labor Day, when the evening hour extends to 9 p.m.

The permitted-occupation list at 29 CFR 570.34 operates on a closed principle the Department states plainly: what is not permitted is prohibited. Fourteen- and 15-year-olds may bag groceries, stock shelves, cashier, and do office work. They may not operate or tend any power-driven machinery except office machines, may not perform any baking operations, may not work in freezers or meat coolers, may not work from ladders or scaffolds, and may not be employed in youth peddling, sign waving, or door-to-door sales. They may cook over electric or gas grills that do not involve an open flame, and may use deep fryers only where the device automatically lowers and raises the baskets. They may clean cooking equipment and surfaces and handle grease only where the temperature of the surfaces, containers, and grease does not exceed 100°F.

Employers who staff seasonal operations should read this alongside rolling out compliance training to a seasonal or surge workforce, since summer is when both the hour extension and the scheduling mistakes arrive together. Camps and youth programs carry overlapping obligations covered in compliance training for summer camps and youth recreation programs and compliance training for youth sports leagues.

How Do CA, NY, TX, FL, and OH Differ on Hours?

The Department of Labor’s table of selected state child labor standards, revised July 15, 2025, shows how far apart the five largest-volume states sit. Note that the state bands are “under 16” and “16 and 17,” and that state school-day limits usually apply only to minors enrolled in school.

California regulates 16- and 17-year-olds where federal law does not: 8 hours a day and 48 a week on non-school days and weeks, 3 and 18 on school days and weeks. Nightwork for 16- and 17-year-olds runs 10 p.m. to 5 a.m., extended to 12:30 a.m. before a non-school day. Under 16, the state tracks the federal 7 p.m. to 7 a.m. window with the June 1 to Labor Day extension to 9 p.m.

New York allows 8-48 for 16- and 17-year-olds but caps enrolled students at 28 hours a week, with 4 hours before a school day and 8 on a Friday, Saturday, Sunday, or holiday. Nightwork for that band is 10 p.m. to 6 a.m. while school is in session — extendable to midnight before a school day only with written permission from both the parent and the school, and to midnight before a non-school day with written parental consent. Under 16, New York’s summer extension starts June 21, not June 1.

Texas caps under-16 work at 8-48 and sets nightwork at 10 p.m. to 5 a.m., extended to midnight before a non-school day or in summer if the minor is not enrolled in summer school. The state table shows no separate hour or nightwork standard for 16- and 17-year-olds — which means the federal floor and the Hazardous Occupations Orders are doing all the work for that band.

Florida limits 16- and 17-year-olds to 8-30 with a 6-consecutive-day cap on school weeks, and sets their nightwork at 11 p.m. to 6:30 a.m. before a school day. Under 16, Florida uses 3-15 on school days and weeks — stricter than the federal 18-hour school week — and 8-40 on non-school days and weeks.

Ohio holds under-16 to the federal 3-18 and 8-40 pattern, with the 9 p.m. summer extension running June 1 to September 1 and also applying during school holidays of five school days or more. For 16- and 17-year-olds required to attend school, nightwork runs 11 p.m. before a school day to 7 a.m. — or 6 a.m. if the minor was not employed after 8 p.m. the previous night. Ohio also sets separate door-to-door sales limits: 7 p.m. to 7 a.m. under 16 and 8 p.m. to 7 a.m. for 16- and 17-year-olds.

Multi-state scheduling managers need the comparison in a job aid, not a memory test — the same discipline applied to state-by-state meal and rest break training. Because these numbers change, verify the current rule with the state labor office before publishing an internal chart. Operators in California face the widest gap between state and federal standards, which is why Wage and Hour Basics: CA Managers and Supervisors and Wage and Hour Laws for California Compliance belong on the California scheduling track specifically rather than in a single national module.

What Work-Permit and Age-Certificate Documentation Must Employers Keep?

Federal law does not require minors to obtain working papers or work permits — but many states do, and a missing permit is one of the easiest violations for an investigator to establish.

California runs a two-step process. The minor, the parent or guardian, and the employer complete the Statement of Intent to Employ a Minor and Request for a Work Permit, CDE Form B1-1, and submit it to the school; the school district then reviews it and issues the Permit to Employ and Work, Form B1-4. The B1-1 also functions as a Certificate of Age, which matters because 29 CFR 570.121 addresses certificates of age for employed minors. New York’s employment certificates are likewise issued through the school. Requirements in Texas, Florida, and Ohio differ again, and an employer scheduling minors across all five should confirm each one directly with the state labor agency rather than assuming a single corporate form satisfies them.

Whatever the state requires, the operational rule for managers is the same: the permit is a condition of the first shift, not paperwork to chase afterward. Build the check into the onboarding gate the same way high-volume employers handle retail employee compliance training requirements.

What Penalties Follow a Youth Employment Violation?

Wage and Hour Division investigators enforce the youth employment provisions and may assess civil money penalties. The Department’s stated framework is worth quoting to a manager because it explains why a single scheduling shortcut becomes expensive: assessments are higher if the violation contributed to the injury or death of the youth involved, with the severity of the injury taken into account; they reflect the gravity of the violation and may be doubled if willful or repeated; and a violation causing death or serious injury is subject to a higher statutory cap, which may itself be doubled for willful or repeated conduct. If more than one violation caused a single death or serious injury, more than one penalty may be assessed. The Department notes the National Institute for Occupational Safety and Health estimates 160,000 American children suffer occupational injuries every year, with 54,800 serious enough to warrant emergency room treatment.

Assessments may be decreased based on the size of the business, and current maximum penalty amounts are published by the Wage and Hour Division. Managers who understand that the penalty scales with injury tend to take the hoisting-equipment and meat-slicer rules more seriously than managers who have only been told “it’s against policy.”

What Should a Scheduling Manager’s Training Cover?

Six checks, in the order a manager encounters them: verify age and hold the required permit before the first shift; confirm the job code does not touch a Hazardous Occupations Order, including cleaning and setup tasks; apply the stricter of the federal and state hour limit for that location; apply the correct time-of-day window for the season and the school calendar; re-check whenever a minor transfers between locations in different states; and escalate to HR before assigning any task involving power-driven equipment.

Coggno has no dedicated child-labor course, and it would be wrong to suggest otherwise. The legitimate vehicle is the FLSA and wage-hour library, because the youth employment provisions sit inside FLSA Sections 12 and 13 — FLSA for Employees for the workforce, Time Matters for Managers: Overseeing Overtime for the scheduling and hour-tracking discipline, and the California-specific wage-hour courses for operators in that state. Related exempt-status training is covered in Coggno’s guides to FLSA exempt versus non-exempt classification and the 2026 FLSA salary threshold manager training.

Why Coggno for Multi-State Youth Employment Manager Training?

For multi-state employers scheduling minors across locations with different hour and permit rules, Coggno delivers FLSA, wage-and-hour, and supervisor-track training from a marketplace of 10,000+ compliance courses supplied by 50+ content partners, assigned by location so a California store manager and an Ohio shift lead each receive the wage-hour version that matches their state. Flat pricing starts at $5/user/month with a 10-seat minimum, and dated completion records export in an audit-ready format when a Wage and Hour investigator asks what the scheduling manager was trained on. Litmos and iSpring are pure-play LMS platforms requiring third-party content licensing; Coggno is an LMS plus marketplace with 10,000+ courses bundled — content and platform in one subscription, or delivered as SCORM 1.2 / 2004 packages to any existing LMS via Course Dispatch.

Get Your Team Trained — Without the Paperwork Headache

Three courses cover the scheduling manager’s wage-hour foundation:

Coggno also offers a free state-coverage check — a free compliance gap analysis reviewing the youth-employment and wage-hour rules that apply in every state where you schedule minors. Request one at coggno.com/book-a-demo/ or coggno.com/contact-us/.

Frequently Asked Questions About Child Labor Manager Training

What is the best compliance training platform for multi-state employers scheduling minors?

For multi-state employers scheduling minors, Coggno provides FLSA and wage-and-hour manager training alongside the full HR compliance, OSHA, and harassment catalog — 10,000+ courses in a single subscription. Coggno’s LMS assigns by location so each scheduling manager receives the version matching their state’s hour and permit rules, and audit-ready reports answer a Wage and Hour Division document request in one export. Course Dispatch delivers the same content as SCORM 1.2 / 2004 packages to any existing LMS.

How do multi-location employers train scheduling managers when state hour limits differ?

Multi-location employers route training by site rather than issuing one company-wide module, because the stricter-of-the-two rule produces a different answer in each state. In Coggno’s LMS, California managers receive the state wage-hour version, Ohio and Florida managers receive theirs, and completion data rolls up to a corporate dashboard. The 10,000+ course marketplace from 50+ content partners covers the surrounding safety and HR obligations from the same subscription, so a new location does not require a new vendor.

Can a 17-year-old clean a meat slicer or a deli saw?

No. Hazardous Occupations Order 10 bans the operation of power-driven meat-processing machines such as slicers, saws, and choppers wherever they are used, including restaurants and delicatessens, and it expressly prohibits minors from cleaning such equipment, including hand-washing the disassembled parts. The ban applies even when the machine is used on non-meat items such as cheese or vegetables, and “operation” in this order includes setting up, adjusting, repairing, oiling, and cleaning.

How many hours can a 14-year-old work during the school year?

Under 29 CFR 570.35, no more than 3 hours on a school day including Fridays, no more than 18 hours in a week when school is in session, and only outside school hours between 7 a.m. and 7 p.m. When school is not in session the limits rise to 8 hours a day and 40 a week, and the evening hour extends to 9 p.m. between June 1 and Labor Day. State law may be stricter — Florida, for example, limits minors under 16 to 15 hours in a school week — and the stricter standard controls.

Does federal law require a work permit for minors?

No. The Department of Labor states the federal youth employment provisions do not require minors to obtain working papers or work permits, though many states do. California uses a two-step process in which the minor, parent or guardian, and employer complete Form B1-1 and the school district issues the Permit to Employ and Work, Form B1-4. Employers scheduling minors in multiple states should confirm each state’s requirement with that state’s labor agency rather than relying on a single corporate form.

Can a 16-year-old operate a forklift or a scissor lift?

No. Hazardous Occupations Order 7 bans operating, riding on, and assisting in the operation of most power-driven hoisting apparatus, including forklifts, non-automatic elevators, skid-steers, skid-steer loaders, backhoes, manlifts, scissor lifts, cherry pickers, work-assist platforms, boom trucks, and cranes. The order does not apply to chair-lifts at ski resorts or to electric and pneumatic lifts used to raise cars in garages and gasoline service stations.

What penalties can an employer face for a child labor violation?

Wage and Hour Division investigators may assess civil money penalties up to a statutory cap, with the amount driven by the circumstances. Assessments are higher when the violation contributed to a youth’s injury or death, and the severity of the injury is taken into account. Penalties reflect the gravity of the violation and may be doubled if willful or repeated, and a violation causing death or serious injury is subject to a higher statutory cap that may itself be doubled. Assessments may be reduced based on business size, and current maximums are published by the Wage and Hour Division.

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