What Employers Need to Know about Hiring Minor Workers

For some Washington employers, the start of summer means the addition of seasonal workers, particularly minor workers who are out of school. If your business is preparing to hire any worker under the age of 18, you should be aware of the following requirements and legislative developments related to minor workers:

• Get a minor work permit endorsement on your business license. Apply with the Department of Revenue (DOR) for a minor work permit. The Washington State Department of Labor & Industries (L&I) reviews all minor work permit requests. Once approved, DOR will issue a new business license with your endorsement, which you must post and renew with DOR every year. You can verify whether your business already has the required Minor Work Permit here.
• Get a completed parent authorization form. Before a minor can begin working, you must get their parent or legal guardian to complete the Parent Authorization for Summer Work form (for minor working during the summer) or their parent or legal guardian and school to complete a Parent/School Authorization form (for minors working during the school year). The authorization form must be renewed every September 30^th for all minor workers and includes information such as the hours worked and job duties. The authorization form must be kept on file by the employer.
• Verify the minor’s age. You must keep a copy of one of the following on file: (1) birth certificate, (2) driver’s license, (3) baptismal record, or (4) notarized statement from the parent or legal guardian. For agricultural jobs, the same forms of verification are may be used, as well as (5) insurance policy at least one year old indicating the date of birth, or (6) completed federal employment eligibility verification (I-9).
• Verify that the minor is a legal age to work this particular role. The legal age to work in Washington varies based on the type of work (e.g., agricultural or non-agricultural), whether the job is considered hazardous or has prohibited duties, whether school is in session, the legal status of the minor (e.g., emancipated minors), and whether the job is exempt from the Fair Labor Standards Act (FLSA). Visit the Washington State Department of Labor & Industries website for more details regarding age restrictions related to specific kinds of work.
• Verify the number of hours the minor is legally allowed to work. Minors are only allowed to work certain hours depending on their age, type of work and whether the work occurs during the school year. Generally, minors may not work during school hours, except for 16- and 17-year-olds who have been excused from school attendance by the school district. See WAC 296-125-027 for a full explanation of hours worked by minors working non-agricultural jobs. Helpful information regarding agricultural jobs can be found here. Employers should also be aware that minors have different rest and meal break requirements.
  • During the school year, most non-agricultural jobs. Generally, workers who are 14 and 15 years old may only work during non-school hours and between the hours of 7:00 a.m. and 7:00 p.m. (or 9:00 p.m. on Friday through Saturday), and no more than three hours per day (except weekends), six days per week for a total of no more than 16 hours per week. Generally, workers who are 16 and 17 years old may work between the hours of 7:00 a.m. and 7:00 p.m. (or 10:00 p.m. on Friday through Saturday) but no more than four hours per day (except weekends), six days a week for a total of 20 hours per week.
  • During summer and school vacations, most non-agricultural jobs. Generally, workers who are 14 and 15 years old may work between 7:00 a.m. and 9:00 p.m., a maximum of eight hours per day, six days per week, and no more than 40 hours per week. Generally, workers who are 16 and 17 years old may work between 5:00 a.m. and 12:00 a.m., a maximum of eight hours per day, six days per week, for a maximum of no more than 48 hours per week.

2. Legislative Developments Related to Minor Workers

In addition to the requirements set out above, L&I has recently updated its child labor rules to comply with three bills passed in the 2025 legislative session: S.H.B. 1121, H.B. 1722, and E.S.H.B. 1644. The new rules will allow employers to have greater scheduling flexibility for certain minor workers but also impose stricter workplace safety requirements and increased penalties for violations. The new rules will take effect as of July 1, 2026.

• Substitute House Bill 1121 allows minors enrolled in career and technical education (“CTE”) programs to work the same number of hours in a day and week during the school year as during school vacations, so long as the work is performed for an employer participating in the educational program. Previously, Washington law allowed certain 16- and 17-year-old workers enrolled in qualifying college programs to work the same hours during the school year that they could work during school breaks. Students participating in CTE programs, however, were not eligible for this flexibility. This change is meant to expand opportunities for students to earn income and gain practical work experience while remaining in school.
• House Bill 1722 aims to revise rules or policies that have been identified as barriers to 16- and 17-year-old students being able to continue with more advanced coursework or otherwise work in a profession after completing training and certification or licensure. This includes training specifically related to emergency medical services and fire services. The law also allows minors with certain licenses or certifications issued by the Washington State Department of Health to work around bloodborne pathogens.
• The new rules also impose new safety obligations on employers. Under Engrossed Substitute House Bill 1644, employers seeking to hire minors for certain hands-on training roles must complete a safety consultation with L&I before obtaining variances that allow minors to perform work otherwise restricted based on age (such as workplaces with machinery that would otherwise be prohibited for minors). In addition, the law strengthens the state’s authority to bar noncompliant employers from hiring minors. For example, L&I must revoke an employer’s minor work permit following a serious violation that results in the severe injury or death of a minor, preventing the employer from hiring minors for at least 12 months.

Notably, the rules also increase penalties for child labor violations, which now range from $100 for non-serious violations, such as failing to maintain records, to $71,000 for offenses resulting in serious physical harm or death of a minor. (Previously, the highest penalty for a child labor violations was $1,000). Penalties can be doubled if they’re willful or a repeated violation.

As employers prepare to hire minor workers going forward, they should be sure to: (i) verify eligibility before scheduling expanded hours for minor workers by confirming enrollment in a qualifying program and securing required approval; (ii) update youth-employment policies and manager training to ensure supervisors understand that expanded hours apply only to certain qualifying students; and (iii) be careful to comply with all other child-labor requirements, including hazardous-occupation restrictions, wage-and-hour laws, meal and rest break requirements, and permitting and recordkeeping obligations.

Associated Industries will keep you updated regarding any developments related to employment of minor workers. In the meantime, if you have any questions, please contact Member Care at 509-777-2727 or membercare@aiin.com and speak with one of our HR or Legal professionals.