Paul DeCamp, Member of the Firm in the Employment, Labor & Workforce Management practice, in the firm’s Washington, DC, office, was quoted in the Bloomberg Law Daily Labor Report, in “DOL’s Wage Arm Vows Child Labor Focus Despite No Rule Changes,” by Rebecca Rainey. (Read the full version – subscription required.)

Following is an excerpt:

Democrats and safety organizations want the US Labor Department to go further in its child labor enforcement efforts by revisiting certain limits on the types of jobs minors can work, but the Biden administration says it doesn’t have the rulemaking bandwidth to take on such an update.

Advocates have met with the US DOL’s wage regulator four times in recent months, urging them to revisit its Hazardous Occupation orders, which limit the types of job duties minors can conduct like prohibiting use of meat slicers or certain equipment. Democratic lawmakers have also pressed the agency to address its rules protecting minors at work, noting they are woefully outdated and haven’t been updated since the 1970s.

In just the last four months, recent cases have uncovered that at least 50 children were working with dangerous chemicals to clean meatpacking plants overnight, and that kids as young as 13 were manufacturing auto parts—reinforcing calls on the Biden administration to strengthen the rules protecting kids while they’re at work. …


The DOL’s wage arm, which is in charge of policing the limits under the Fair Labor Standards Act governing when minors can work, how long minors can work, and the tasks minors can do at work, has seen about a 50% increase in child labor violations since 2018, according to Looman.

In FY 2022, there were 835 cases involving child labor violations and 3,876 minors employed in violation of child labor laws, an uptick from the 747 cases and 2,819 minors working in violation in FY 2021, according to DOL data. …

In one instance, the DOL in December 2022 secured a consent order against a cleaning company, Packers Sanitation Service Inc. Ltd., for allegedly hiring 50 underage workers to clean meatpacking plants—violating its hazardous occupation limits for minors by exposing them to chemicals and certain machinery. And in October 2022, DOL got a court to force an Alabama auto-parts manufacturer for Hyundai and Kia to stop employing 13-, 14- and 15-year-old workers. …

Fluctuations in child labor violations tend to parallel the state of the labor market and the demand for workers, noted Paul DeCamp, a Wage and Hour administrator during the George W. Bush administration, adding that the economy is still recovering from the pandemic.

“It’s tempting to look at the year to year fluctuations in the numbers and try to draw conclusions about those but I think the year to year variations really are more about what’s going on with the economy,” said DeCamp, now a management-side attorney with Epstein Becker & Green PC. “When unemployment is high, and people are looking for work, there’s usually lower employment of minors.”

While not a direct client, DeCamp submitted an expert declaration in the Packers Sanitation Services litigation.


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