Employment of Children Under Eighteen Years of Age

Under certain circumstances, the University may hire children who are older than fourteen (14) years and younger than eighteen (18) years old. Children under fourteen (14) may not be employed in any capacity. This information is intended to provide an overview of major federal and state laws and regulations, and University policies restricting hiring children under eighteen (18). For additional information, please use the website links provided or contact your Human Resources Consultant.

Contents

• Age Related Restrictions
• UA Classifications
• Required Documents
• Compensatory Time
• Hazardous Work Restrictions
• Driving Restrictions

 
Age Related Restrictions

Age 14-15

The employee may not:

• work during regular school hours;
• work more than eighteen (18) hours per week nor more than three (3) hours per day when high school is in session;
• work more than forty (40) hours per week nor more than eight (8) hours per day when high school is not in session;
• work between 7:00 p.m. and 7:00 a.m. in any one day, except in the summer between June 1 and Labor Day, when the evening hour will be 9:00 p.m.; and,
• perform hazardous duties (see below for details) or perform duties not specifically outlined in the Fair Labor Standards Act, 29 C.F.R. §570.34.

Age 16-17

The employee may not:

• work during regular school hours;
• work more than forty (40) hours per week nor more than eight (8) hours per day when high school is not in session;
• perform hazardous duties (see below for details).

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UA Classifications

"High School Student" and "High School Student-Food Service"
Employment of a "High School Student" is permitted, but should not interfere with the student's concurrent high school education. An individual employed as a "High School Student" may continue as a "High School Student" and work during the summer months between high school graduation and the fall semester if they are pre-registered to attend the UA for that fall semester. On the first day of fall semester regular classes, the "High School Student" classification is no longer applicable and the employment status should be changed to either 1) a Student Group A, B or C position or 2) the employment must be terminated.

"Student A, B or C" or Other Classified Staff Title
Employment of a UA student or anyone under the age of eighteen (18) requires the University to adhere to the guidelines for youth employment whether the individual is hired in a Student Group A, B or C or in a Classified Staff title.

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Required Documents

Proof of age is required and may be established by documents used for I-9 compliance. Proof of enrollment and attendance at a recognized high school or high school program is required for high school students. If the employment is for the contiguous period immediately after the employee's high school graduation, proof of high school graduation is required.

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Compensatory Time

It is University policy to pay time and one-half cash overtime for hours in excess of forty (40) hours worked per work week to High School Students, High School Students-Food Service, and employees in Student Group A, B and C. These employees may not accrue compensatory time.

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Hazardous Work Restrictions

Under Age 18

Employees under age eighteen (18) cannot perform non-agricultural hazardous work. Non-agricultural hazardous work includes but is not limited to:

• Working in laboratories or other workplaces that have the following hazards present:
  • presence of chemical hazards that are present in concentrations above any OSHA level;
  • laboratories with a Chemical Hazard rating of CSL-2 or CSL-3;
  • laboratories that are approved for use, storage, or handling of radioactive materials;
  • laboratories with a Biological Safety rating of BSL-3 or BSL-4, or where CDC Select Agents are housed or handled;
  • workplaces or activities with a potential for exposure to infectious agents or blood borne pathogens.

• Other examples of non-agricultural hazardous work includes but is not limited to:
  • driving a motor vehicle or being an outside helper in one except under limited circumstances;
  • working with or on any systems that require the use of lockout-tagout per OSHA standards;
  • working in an unprotected elevated location that requires personal fall arrest protection per OSHA standards (4 feet);
  • entry to any confined space as defined by OSHA standards;
  • exposure to high noise levels above the OSHA action level (85 dbA, 8 hours TWA), without hearing protectors;
  • working in a location where respiratory protection is required;
  • manufacturing/storing/working around explosives and explosive components (as defined by the ATF and including ammunition, black powder, blasting caps, fireworks, high explosives, primers and smokeless powder);
  • coal mining or other mining;
  • logging/saw milling and forestry services including forest firefighting;
  • using power-driven circular saws, band saws and guillotine shears;
  • using power-driven wood-working, hoisting, wood-working, metal-forming, punching, shearing, paper product, slicing, or baking machines;
  • meat packaging or processing;
  • manufacturing brick, tile or related products;
  • wrecking, demolition and ship breaking operations;
  • roofing operations; or,
  • any duties with exposure to a serious health or safety hazard.

If there is any potential that the assigned duties could be deemed hazardous, please contact Risk Management & Safety for clarification. Any exception to the listed restrictions must be approved in advance by Risk Management & Safety, and a copy of that approval sent to Human Resources.

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Hazardous Work Restrictions, continued

Under Age 16

In addition to the above, employees under age sixteen (16) cannot perform agricultural hazardous work. Agricultural hazardous work includes but is not limited to:

• driving a bus, truck, or automobile when transporting passengers, or riding on a tractor as a passenger or helper;
• working from a ladder or scaffold (painting, repairing, or building structures, pruning trees, picking fruit, etc.) at a height of over 4 feet;
• operating a tractor of over 20 PTO horsepower, or connecting or disconnecting an implement or any of its parts to or from such a tractor;
• operating or assisting to operate (including starting, stopping, adjusting, feeding, or any other activity involving physical contact associated with the operation) any of the following machines: corn picker, cotton picker, grain combine, hay mower, forage harvester, hay baler, potato digger, mobile pea viner, feed grinder, crop dryer, forage blower, auger conveyor, or the unloading mechanism of a non-gravity-type self-unloading wagon or trailer, power post-hole digger, power post driver, or non-walking type rotary tiller;
• operating or assisting to operate (including starting, stopping, adjusting, feeding, or any other activity involving physical contact associated with the operation) any of the following machines: trencher or earthmoving equipment, fork lift, potato combine, or power-driven circular, band, or chain saw;
• working on a farm in a yard, pen, or stall occupied by a bull, boar, or stud horse maintained for breeding purposes; or sow with suckling pigs, or cow with newborn calf (with umbilical cord present);
• felling, bucking, skidding, loading, or unloading timber with butt diameter of more than 6 inches;
• working inside a fruit, forage, or grain storage designed to retain an oxygen deficient or toxic atmosphere; an upright silo within 2 weeks after silage has been added or when a top unloading device is in operating position; a manure pit; or a horizontal silo while operating a tractor for packing purposes;
• handling or applying (including cleaning or decontaminating equipment, disposal or return of empty containers, or serving as a flagman for aircraft applying) agricultural chemicals classified under the Federal Insecticide, Fungicide, and Rodenticide Act (7 U.S.C. 135 et seq.) as Category I of toxicity, identified by the word "poison" and the "skull and crossbones" on the label; or Category II of toxicity, identified by the word "warning" on the label;
• handling or using a blasting agent, including but not limited to, dynamite, black powder, sensitized ammonium nitrate, blasting caps, and primer cord; or
• transporting, transferring, or applying anhydrous ammonia.

If there is any potential that the assigned duties could be deemed hazardous, please contact Risk Management & Safety for clarification. Any exception to the listed restrictions must be approved in advance by Risk Management & Safety, and a copy sent to Human Resources.

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Driving Restrictions

Under the University's Fleet Safety Policy, employees under age eighteen (18) are not permitted to drive on University business. For information on driving qualifications for employees eighteen (18) and over, please refer to http://risk.arizona.edu/fleetsafety/index.shtml.

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