Regulations promulgated under the FLSA encourage employers to obtain federal or state certificates of age from minors to protect the employers ''from unwitting violation of the minimum age standards" (29 C.F.R. 570.5) These certificates must include, at a minimum, the names and addresses of the minors and their parents or guardians; places and dates of birth of the minors (including the evidence on which this information was based); the minors' sex; the names, addresses, and industries of the employers; and the occupations of the minors. Forty-one states and the District of Columbia issue certificates, often called work permits, that meet the requirements of the Department of Labor (29 C.F.R. 570.9-570.10).
The requirements and contents of the work permits vary considerably among states. Generally, schools issue the permits to students, rather than to employers. The vast majority of state and local education authorities have not provided the local issuers with training about child labor or health and safety laws, nor have they used the data that could be gathered when issuing permits for intervention, enforcement, training, or educational purposes (Beyer, 1997). Furthermore, the permit systems have not been evaluated to determine whether the issuance of work permits successfully limits youngsters to workplaces that are age-appropriate and free of prohibited employment risks.
The Fair Labor Standards Act specifically allows states to establish additional requirements for the issuance of work permits. For example, six states (Alabama, California, Massachusetts, Nebraska, Oklahoma, and Washington) require youngsters to be regularly attending school if state law so requires before work permits will be issued; two states (New Hampshire and North Dakota) require students to have satisfactory academic levels before they can receive certificates; and six states (Alabama, Indiana, Maine, Michigan, New Hampshire, and New York) allow schools to revoke permits if the schools find that the youngsters' school work has become unsatisfactory. Many, but not all, states take advantage of the permit process to help inform adolescents of the child labor laws by offering a pamphlet that explains the restrictions on young workers' hours and occupations (31 states) or by listing such restrictions on the permit application forms or permits themselves (27 states).4