Personnel(ly) Speaking

A Monthly Newsletter from

Personnel Management Systems, Inc.

June 2007

Summer Employment – Teens and Interns

Generally summer is a time when employers want to augment their workforce.  Seasonal employment can be a great way to fill in for your regular employees’ vacations; get “caught up”; or evaluate an intern for future full-time employment.  As a business owner or manager, you may also be interested in hiring your own children or those of a colleague.  In today’s tight labor market, some entry level jobs can be filled, even temporarily, by younger less-experienced workers.

In each instance, business owners and managers need to know their responsibilities; what rules apply; and what your seasonal employee expect and require.

 

Hiring minors

You may want to hire high-school students to fill gaps in the company work schedule.  Before hiring a person less than 18 years of age, be aware that both federal and state laws regulate the employment of minors.  These laws, which are designed to protect the educational opportunities of minors and prohibit their employment in jobs and under conditions detrimental to their health or well-being, restrict minors’ hours of employment and the jobs they can perform.

 

Some of the issues that need to be considered when hiring minors aged 16 and older are outlined below; more restrictive rules apply for younger minors.  If you are considering employment of a minor make sure you discuss all the requirements with your Human Resources professional.  In some cases, exceptions may apply.

 

What work can minors perform?

Federal regulations restrict the type and hours of work that minors can perform.  Minors who are 16 or 17 years old may perform non-hazardous jobs.  While common sense may help employers determine what jobs the government might find off limits to minor employment, the Secretary of Labor does list specific hazardous non-farm jobs that are out of bounds for teens below the age of 18.  A sampling of the specific exclusions follows:

  • Driving a motor vehicle and being an outside helper on a motor vehicle
  • Using power-driven woodworking machines, hoisting equipment
  • Working with metal-forming, punching, and shearing machines
  • Packing or processing meat
  • Manufacturing brick, tile, and related products
  • Operating power-driven circular saws and band saws
  • Performing roofing operations

The federal Fair Labor Standards Act (FLSA) age requirements do not apply to minors employed by a parent or by a person acting as their guardian. An exception to this occurs in mining, manufacturing, and occupations where the minimum age requirement of 18 years old applies.

 

How much should we pay?

Currently, the federal government requires a minimum wage of $4.25 per hour for employees under 20 years of age during their first 90 consecutive calendar days of employment.  After 90 days the employee must receive the federal minimum wage of $5.15 per hour. Please be aware that this federal minimum wage increases from $5.15 to $5.85 per hour effective July 24, 2007. In 2008 another there will be a second increase to $6.55, followed by a jump to $7.25 in 2009.  (It is likely that these changes will also affect the minimum wage paid to employees under 20, during their first 90 days of work, although the federal government has not issued wording on that provision yet.)

 

Of course states have established their own minimum wage regulations regarding the pay for minors’ work.  For example, Washington employees who are 16 years old or older must be paid the Washington minimum wage of $7.93 per hour.  Employees under the age of 16 must be paid at least 85% of this amount.  California has similar laws; minors must be paid at least the state minimum wage which is $7.50 an hour and applicable overtime rates.  California employers may pay new employees 85% of the minimum wage while they are learning the new job, but only during their first 160 hours of work and only if they have no previous similar work experience.

 

State vs. Federal restrictions

State restrictions may match the federal regulations, be more liberal, or be more restrictive.  For example, in both California and Washington, 16 and 17 year olds may work up to 20 hours a week (only 4 hours per day except on weekends) during a school week[1].  During non-school weeks, they may work up to 8 hours per day, 48 hours per week.  Colorado allows the same age to work six hours or less on school days, after school hours; they can work more if the next day is a weekend.  Oregon takes a more liberal approach with no limits on the number of hours 16 and 17 year olds may work in a day and allowing up to 44 hours per week. 

 

State restrictions on the type of work performed can vary from federal requirements.  In addition to the federally-restricted activities listed above, typical state restrictions include:

  • Operating meat slicers or powered bakery equipment
  • Regularly driving a motor vehicle to make deliveries
  • Operating a forklift
  • Working at heights greater than 10 feet off the ground or floor level.
  • Working in freezers, meat coolers and in preparing meats for sale.
  • Slaughtering, meat packing or food processing.

 

Do we need Work Permits and Proof of Age?

Many states require permits for workers of certain ages.  In states where minor work permits are required, an employer must obtain the permit before allowing a minor to work.  Work permits generally cover all minors employed at the workplace, but separate permits must be obtained for each separate workplace.  Obtaining a permit is usually not difficult, but it does take time.  Employers interested in employing minors should plan ahead so the permit is obtained before the minor’s first shift.

 

Although the federal government does not required proof-of-age certificates, many states do.  The documents that substantiate a minor’s age are set out in state regulations and generally include a birth certificate and social security card, or a driver’s license.  The U.S. Department of Labor will issue age certificates if the minor employee's state does not issue them or if the minor is requested by his or her employer to provide one. 

 

How about Parent/School Authorization?

Employers may be required to obtain a parental/school authorization form for each minor employee.  If required, this form can be obtained from state labor departments and must be completed before the minor reports for work.  The form generally shows proof of age, name and address of the minor, description of the employment and duties, and any employment at other jobs.

 

Maybe hiring an intern makes more sense – what is that?

Interns are usually college students working in their area of major or interest.  Internships can be paid or unpaid, full time or part time.  Some companies partner with local universities or community colleges to find interns. A summer internship program can be viewed as a three month job interview; employers have the opportunity to see actual work performance. It is a training and testing ground for new employees and can be a very successful recruitment strategy for the longer term.

 

Many interns are paid hourly. Alternatives include a stipend to defray some of the costs of living. Some interns are willing to work exclusively for the job experience, particularly in the more “glamorous” industries such as entertainment and advertising.  Some colleges grant university credit for approved internships.

 

There are some employer responsibilities when hiring interns.  For example, covering interns under workers’ compensation insurance is a good idea, as is keeping a record that safety protocol has been reviewed. Treat a summer employee just as you would a permanent employee.

 

Just remember the rules

If you hire minors this summer, remember to follow the rules. Although relatively straightforward, the rules governing the employment of minors are strictly enforced, and it is worth the investment of time to research the requirements and to carefully follow them.  Your state department of labor will provide you with the information necessary to hire minors appropriately.  If you’d like assistance with your hiring plans or finding and interpreting your state’s hiring regulations, call Personnel Management Systems, Inc.

Personnel(ly) Speaking is a monthly comment on HR issues of importance.  It is intended to provide general information and must not be construed as legal advice.  Reproductions are allowed as long as credit for this information is given to PMSI.  We welcome your comments, questions, and concerns.  © PERSONNEL MANAGEMENT SYSTEMS, INC., Corporate Office (425) 576-1900,

Colorado Office (720) 497-0200, www.hrpmsi.com.



[1] Variances are available to extend the available hours of work.