ES.C.4.1, School Week and Work Week For Minors Draft Policy (July 2024)
In order to be transparent and seek input from the diverse business and labor communities, L&I is further seeking stakeholder feedback on draft administrative policy, ES.C.4.1, School Week and Work Week For Minors.
We are asking the public to review the draft of the administrative policy and provide written feedback by July 26, 2024.
Feedback can be submitted directly to this page via the “Submit Comments” tab.
Feedback can also be submitted via the ESRules@Lni.wa.gov email box.
In order to be transparent and seek input from the diverse business and labor communities, L&I is further seeking stakeholder feedback on draft administrative policy, ES.C.4.1, School Week and Work Week For Minors.
We are asking the public to review the draft of the administrative policy and provide written feedback by July 26, 2024.
Feedback can be submitted directly to this page via the “Submit Comments” tab.
Feedback can also be submitted via the ESRules@Lni.wa.gov email box.
To submit your feedback directly to this page, please enter your comments in the text box below.
You need to be signed in to comment in this Guest Book. Click here to Sign In or Register to get involved
Thank you for the opportunity to provide comments on ES.C.4.1, School Week, and Work Week for Minors Draft Policy. After reviewing the draft policy, the Washington Retail Association has a primary question to limit hours worked by minors 16 or older, and we have identified three items we believe need clarification in the guidance.
Question - With policymakers’ emphasis and promotion of students receiving school credits through work, L&I’s weekly hour limitations rules have not changed to commensurate with the policy trend. Would you please explain the basis and rationale for not re-evaluating the hour limitations especially when there are no such federal limitations?
Other comments: 1. The third bullet under Section 4.1 states that a 16-17-year-old can work “8 hours on a Friday or any non-school day including holidays”. Example 4.2-1 then states that a 16-year-old can work 8 hours on the day preceding a holiday. Accordingly, we suggest the language in the third bullet of Section 4.1 be clarified to read, “8 hours on any day preceding a holiday or weekend, and 8 hours on any holiday”. 2. The guidance is unclear if the weekly hourly limits apply in a week that may have one holiday (e.g. Thanksgiving or Christmas) in addition to the two-day weekend. In that situation, are 16–17-year-olds allowed to work an additional 8 hours beyond the 20-hour limit because of the added holiday outside of a typical weekend? If not, please explain. 3. We would appreciate further clarification on the meaning of “special variance” mentioned in this document. It would be helpful to employers/parents/educators to reference the limitation prescribed in RCW 49.12.124 in the vicinity of “special variance” to make it easy for readers so they do not have to look up the statute.
Thank you for the opportunity to comment.
Sincerely, Rose Gundersen VP of Op & Retail Services, Washington Retail Association
Thank you for the opportunity to provide comments on ES.C.4.1, School Week, and Work Week for Minors Draft Policy. After reviewing the draft policy, the Washington Retail Association has a primary question to limit hours worked by minors 16 or older, and we have identified three items we believe need clarification in the guidance.
Question - With policymakers’ emphasis and promotion of students receiving school credits through work, L&I’s weekly hour limitations rules have not changed to commensurate with the policy trend. Would you please explain the basis and rationale for not re-evaluating the hour limitations especially when there are no such federal limitations?
Other comments:
1. The third bullet under Section 4.1 states that a 16-17-year-old can work “8 hours on a Friday or any non-school day including holidays”. Example 4.2-1 then states that a 16-year-old can work 8 hours on the day preceding a holiday. Accordingly, we suggest the language in the third bullet of Section 4.1 be clarified to read, “8 hours on any day preceding a holiday or weekend, and 8 hours on any holiday”.
2. The guidance is unclear if the weekly hourly limits apply in a week that may have one holiday (e.g. Thanksgiving or Christmas) in addition to the two-day weekend. In that situation, are 16–17-year-olds allowed to work an additional 8 hours beyond the 20-hour limit because of the added holiday outside of a typical weekend? If not, please explain.
3. We would appreciate further clarification on the meaning of “special variance” mentioned in this document. It would be helpful to employers/parents/educators to reference the limitation prescribed in RCW 49.12.124 in the vicinity of “special variance” to make it easy for readers so they do not have to look up the statute.
Thank you for the opportunity to comment.
Sincerely,
Rose Gundersen
VP of Op & Retail Services, Washington Retail Association