Hiring Young Workers This Summer? What OSHA and the FLSA Actually Require

Every June, small businesses across the country bring on summer help — teenagers and young adults filling in for vacationing staff, picking up seasonal hours, or getting their first taste of real work. It's a familiar and valuable arrangement. What many employers don't realize is that young workers, generally defined as those under 18, come with a distinct set of legal obligations that go beyond a normal new-hire checklist.

OSHA data consistently shows that workers between the ages of 15 and 24 suffer injuries at roughly twice the rate of experienced adult workers. The causes aren't random. Young employees lack the job-specific experience to recognize hazards, they're less likely to push back on unsafe instructions from supervisors, and they're often placed in fast-paced environments without adequate orientation. As an employer, the legal and moral responsibility for managing that risk sits squarely with you.

What the FLSA Hazardous Orders Actually Prohibit

Most small business owners know that there are rules about what minors can do at work, but the specifics are often fuzzy. The Fair Labor Standards Act (FLSA) establishes Hazardous Orders — a list of seventeen occupational categories that employees under 18 are prohibited from performing, regardless of training or supervision.

Several of these show up regularly in small business settings. Workers under 18 cannot operate, set up, adjust, repair, or clean power-driven meat processing equipment — relevant for food service and grocery operations. They cannot work in roofing operations or at heights on a roof, which matters for contractors. The orders also prohibit minors from operating power-driven circular saws, band saws, and guillotine shears; from operating forklifts and most powered industrial trucks; from exposure to radioactive substances; and from working in wrecking, demolition, or excavation operations.

The distinction between 16-year-olds and 14 to 15-year-olds matters as well. Workers aged 14 and 15 face additional restrictions on hours, shift lengths, and the types of tasks they can perform even outside the Hazardous Orders. If you're hiring anyone in that age range, a close read of the Department of Labor's child labor rules is essential before their first day.

Violations of the Hazardous Orders carry civil penalties starting at over $15,000 per minor per violation, and if a minor is injured while performing prohibited work, that penalty increases substantially.

OSHA's Standards Apply to Young Workers Too

OSHA does not have a separate regulatory track for minors. Every standard in 29 CFR 1910 (general industry) and 1926 (construction) that applies to adults applies equally to your summer hires. A 17-year-old stocking shelves in a warehouse is subject to the same requirements as a 45-year-old doing the same job — proper footwear, safe racking loads, training on powered equipment if they're authorized to use it.

Where OSHA intersects with young worker risk most acutely is in 29 CFR 1910.132, which requires a hazard assessment before workers use personal protective equipment, and in the training requirements embedded throughout the standards. If a young worker will be exposed to hazardous chemicals, they need HazCom training under 29 CFR 1910.1200 before they touch anything. If they'll work around energized electrical equipment, arc flash awareness applies. The standard doesn't say "except for seasonal employees."

OSHA's General Duty Clause (Section 5(a)(1) of the OSH Act) adds an additional layer. Employers are required to provide a workplace free from recognized hazards likely to cause serious harm. Assigning a teenager with no experience to a task that poses recognized risks without adequate training and supervision is a General Duty Clause violation waiting to happen — and OSHA compliance officers are well aware of this when they investigate injuries involving young workers.

Training Before the First Shift, Not During It

One of the most consistent findings in young worker injury investigations is that training either didn't happen or happened simultaneously with the hazardous work it was supposed to prevent. Getting this right isn't complicated, but it requires intention.

Every young worker should receive site-specific orientation before performing any work. That means a walkthrough of emergency exits and the emergency action plan under 29 CFR 1910.38, an explanation of what PPE is required for their role and why, clear identification of which equipment and areas are off-limits, and an introduction to the chain of command if they feel unsafe. Put it in writing, have them sign it, and keep the record.

Training should happen in a language the worker understands. This matters particularly with young workers from immigrant families who may have limited English. OSHA's training requirements don't specify English; they specify comprehension.

Beyond the orientation, consider assigning a specific experienced employee as a point of contact for the summer hire — someone whose job includes answering questions and checking in on how the new employee is doing. Young workers are statistically more likely to get hurt in the first month on the job, and informal mentoring has been shown to reduce that risk materially.

Supervision Standards and the Temptation to Fill Gaps

Summer is frequently the season when businesses are running lean. Experienced employees are on vacation, demand is up, and a summer hire who's picked things up quickly starts to look like a capable gap-filler. This is often when the worst accidents happen.

A young worker who seems competent at a task should not be left to handle it alone before they've demonstrated consistent, supervised performance over time. "Seemed like they knew what they were doing" is not a defense in an OSHA investigation. If your operation has tasks that genuinely require solo work, those tasks should be staffed by experienced adults — not by the quickest learner among your summer crew.

Document supervision levels for the first several weeks. It doesn't need to be elaborate — a simple log noting which tasks a new employee performed, with whom, and whether any issues arose is enough to demonstrate a structured onboarding process.

The Paperwork Is Simpler Than the Liability

OSHA doesn't require a separate young-worker safety program. What it requires is that all applicable standards are met, that training is documented, and that hazard assessments are completed. If you're already maintaining a well-run safety program for your regular employees, extending it thoughtfully to summer hires is mostly an exercise in thoroughness, not bureaucracy.

The FLSA compliance side requires knowing the Hazardous Orders and reviewing each summer hire's assigned tasks against them before work begins. The Department of Labor's Youth Rules website provides a searchable summary of what different age groups can and cannot do — it's worth bookmarking now, before your hires start.

A summer hire who gets hurt is a human cost first, and a compliance cost second. Young workers often don't speak up when something feels unsafe because they're new, they want to make a good impression, and they don't yet know what "safe" looks like in a given work context. That's precisely why the responsibility for creating a safe environment rests with the employer, not the employee.

If you're bringing on teenagers or young adults this summer, take the time to do it right. Review the Hazardous Orders, complete your hazard assessments, document your training, and set up actual supervision — not just proximity. The investment is modest. The downside of skipping it is not.