7
Conclusions and Recommendations

The majority of adolescents in the United States work. The benefits of work include increased self-esteem, responsibility, and autonomy, as well as income, the primary reason most adolescents work. Working during high school may also be associated with increased employment and higher wages as long as 10 years after high school. But there are adverse consequences associated with work, too. Children and adolescents have high rates of work-related injuries. In addition, for adolescents, working long hours during the school year is associated with alcohol, tobacco, and drug use; minor delinquency; lack of adequate sleep and exercise; increased rates of dropping out of high school; and decreased overall educational attainment. For the most part, children and adolescents, their parents, and many of the other adults in their lives are unaware of the adverse consequences of work.

The Committee on the Health and Safety Implications of Child Labor was established to examine how working affects the health and safety of young people and to provide recommendations on how adverse consequences can be prevented. To address its charge, the committee undertook several tasks: reviewing the available data on the extent to which children and adolescents in the United States work; reviewing the available data on their work-related injuries and illnesses; and reviewing the research on work's positive and negative



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Protecting Youth at Work: Health, Safety, and Development of Working Children and Adolescents in the United States 7 Conclusions and Recommendations The majority of adolescents in the United States work. The benefits of work include increased self-esteem, responsibility, and autonomy, as well as income, the primary reason most adolescents work. Working during high school may also be associated with increased employment and higher wages as long as 10 years after high school. But there are adverse consequences associated with work, too. Children and adolescents have high rates of work-related injuries. In addition, for adolescents, working long hours during the school year is associated with alcohol, tobacco, and drug use; minor delinquency; lack of adequate sleep and exercise; increased rates of dropping out of high school; and decreased overall educational attainment. For the most part, children and adolescents, their parents, and many of the other adults in their lives are unaware of the adverse consequences of work. The Committee on the Health and Safety Implications of Child Labor was established to examine how working affects the health and safety of young people and to provide recommendations on how adverse consequences can be prevented. To address its charge, the committee undertook several tasks: reviewing the available data on the extent to which children and adolescents in the United States work; reviewing the available data on their work-related injuries and illnesses; and reviewing the research on work's positive and negative

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Protecting Youth at Work: Health, Safety, and Development of Working Children and Adolescents in the United States effects on young people. Chapters 1–6 of this report provide a description of the sources of data on the extent of work and of work-related injuries, illnesses, and fatalities among children and adolescents, as well as the limitations of those data; a summary of the research on the consequences of working; and a review of the laws and regulations that govern child labor. After reviewing the data and literature and examining the U.S. laws and regulations on labor by children and adolescents, the committee agreed on a number of principles that guided their formulation of recommendations. These principles are based on a developmental framework, which recognizes that the needs and abilities of children and adolescents differ from those of adults. The tasks in which children and adolescents engage must be commensurate with their physical, cognitive, emotional, and social abilities. These principles, which represent the judgment and values of the committee, form the basis for ensuring that the work performed by children and adolescents will be safe and healthful and will not compromise their physical, cognitive, emotional, and social development. Guiding Principle 1: Education and development are of primary importance during the formative years of childhood and adolescence. Although work can contribute to these goals, it should never be undertaken in ways that compromise education or development. Guiding Principle 2: The vulnerable, formative, and malleable nature of childhood and adolescence requires a higher standard of protection for young workers than that accorded to adult workers. Guiding Principle 3: All businesses assume certain social obligations when they hire employees. Businesses that employ young workers assume a higher level of social obligation, which should be reflected in the expectations of society as well as in explicit public policy. Guiding Principle 4: Everyone under 18 years of age has the right to be protected from hazardous work, excessive work hours, and unsafe or unhealthy work environments, regardless of the

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Protecting Youth at Work: Health, Safety, and Development of Working Children and Adolescents in the United States size of the enterprise in which he or she is employed, his or her relationship to the employer, or the sector of the economy in which the enterprise operates. With these principles in mind, the committee's recommendations are designed to protect young people in the workplace through education and through updated, enhanced, and adequately enforced laws and regulations. Educational efforts target the behavior of individuals—young people and their parents, employers, teachers, and mentors. While such efforts are an indispensable part of any public policies to protect the health and safety of children, experience in injury prevention has found that legal remedies often result in more rapid and larger changes in occupational safety and health than reliance on individual behavioral change alone (see Chapter 6). The conditions under which minors can work are already limited by regulation. The committee's recommendations address the need for revision or elaboration of those existing limitations. Because such efforts require adequate data, the committee also recommends improved data and surveillance systems and more general research. SURVEILLANCE SYSTEMS Young workers' occupational injuries, illnesses, and exposures to hazardous substances are preventable if proper public health actions are taken. Surveillance systems that provide information about where and how youngsters are injured or made ill while working is essential for both targeting and evaluating prevention efforts. Over the past decade, government agencies have substantially improved the surveillance of illnesses and injuries sustained by adult workers; more recent surveillance initiatives have begun to provide information regarding young workers, at least with respect to their work-related injuries. These activities, however, are limited and poorly coordinated. As yet, the principal federal occupational illness and injury surveillance systems have not been evaluated to assess the extent to which they may systematically omit young workers or subgroups of young workers. The lack of specific attention to the need for data regarding issues related to the protection of young workers as a special population has often meant that even existing data concerning relevant age groups are unavailable to the public.

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Protecting Youth at Work: Health, Safety, and Development of Working Children and Adolescents in the United States There are few state-based surveillance systems of nonfatal work-related injuries that combine data from multiple sources and allow for important links to intervention programs in the workplace. The field of injury surveillance is expanding, and new opportunities to integrate the surveillance of work-related injuries into more general injury surveillance systems need to be actively pursued. The conventional injury surveillance datasets, such as workers' compensation and the Department of Labor's Survey of Occupational Injuries and Illnesses, need to be supplemented by data from broader resources, such as ambulatory care data, which captures a much greater range of the work-related injuries sustained by the general population. Almost completely lacking is information about the health hazards to which young workers are exposed: Very little information is currently available, and the committee could not identify any surveillance focus on such hazards. Recommendation: The National Institute for Occupational Safety and Health, in collaboration with the Bureau of Labor Statistics and other relevant federal and state agencies, should develop and implement a comprehensive plan for monitoring the work-related injuries and illnesses sustained by workers under the age of 18 and for monitoring the hazards to which these young workers are exposed. Additional resources should be allocated to the appropriate agencies to implement the components of such a plan that are not currently funded. The committee has identified a number of surveillance activities that should be priorities for consideration as this planning effort proceeds. The National Institute for Occupational Safety and Health (NIOSH) should explore paying specific attention to young workers when conducting hazard surveillance. For example, NIOSH should explore the feasibility and utility of collecting and routinely reporting how many workers are under the age of 18 and what percentage of the work force they represent whenever it assesses exposures to health hazards. (This would apply both to workplaces in which health hazards are evaluated and to those surveyed in the National Occupational Exposure Survey.) Special studies to assess exposure to health hazards among certain populations of young workers, such

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Protecting Youth at Work: Health, Safety, and Development of Working Children and Adolescents in the United States as young migrant workers' exposure to pesticides, should also be undertaken. NIOSH should collaborate with the National Center for Injury Prevention and Control at the Centers for Disease Control and Prevention, the National Center for Health Statistics, and other relevant agencies to enhance the collection of data on the work relatedness of injuries and illnesses. Particular attention should be directed to existing ambulatory care surveillance systems, such as the National Ambulatory Care Survey; the relationship of work to injuries sustained by youngsters should be specifically included as new state-level systems are developed using emergency department data. The Fatality Assessment and Control Evaluation program of NIOSH should consider including young people's work-related fatalities on its list of fatalities targeted for in-depth investigations. If full field investigations of all incidents are not feasible, NIOSH should, at least, develop a supplement to its basic data collection instrument to gather key information pertinent to working youngsters. State-based surveillance activities, particularly those supported by NIOSH, should be expanded to allow for combining all the sources of data on nonfatal injuries and illnesses sustained by young workers and to develop appropriate links of surveillance so that relevant data collection is designed to support local intervention efforts. The Bureau of Labor Statistics should routinely publish tabulations of the available data from the Survey of Occupational Injuries and Illnesses and the Census of Fatal Occupational Injuries (CFOI) for individuals under the age of 18, by separate and appropriate age categories. Existing data systems, including the Census of Fatal Occupational Injuries, the National Traumatic Occupational Fatality Surveillance System, the Survey of Occupational Injuries and Illnesses, and the National Electronic Injury Surveillance System, should be evaluated to assess the extent to which they capture and generate representative data on work-related injuries sustained by youngsters. The Bureau of Labor Statistics, with the assistance of the Wage and Hour Division, should include information on violations of federal child labor laws in the CFOI database for fatal incidents involving individuals under the age of 18. Such information is important

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Protecting Youth at Work: Health, Safety, and Development of Working Children and Adolescents in the United States to evaluate the adequacy of hazardous order regulations and compliance with those regulations. Targeted periodic surveillance efforts should be undertaken to identify the work-related injuries and illnesses sustained by particularly vulnerable subgroups of young workers, such as young migrant farmworkers, young immigrants, poor youngsters, and minority youngsters. Education efforts should be targeted to health care providers who work with children and adolescents to develop professionals who routinely collect essential information about work histories and who routinely provide anticipatory guidance to adolescents about work-related health issues. Because the surveillance of occupational injuries and illnesses is contingent on the recognition that some health problems are related to hazards in the workplace, adequate training of health care providers is essential. In the United States, however, occupational health training for providers is generally extremely limited. Moreover, those specialists who provide other health services specifically to children and adolescents receive no training regarding health and safety for working youngsters. Even in the standard prevention counseling guidelines for young people, occupational safety and health issues are not mentioned. All federal agencies that collect data on the occupational injuries and illnesses sustained by youngsters should improve efforts to disseminate this information to state and local public health practitioners who are responsible for injury control and adolescent health. A surveillance component should be developed so that schools with work-based learning programs can track and investigate injuries sustained by students in job placements. DATA Taken together, federal data sources and national and local survey research provide a fair amount of information about teenagers who have jobs, where they work, and how much they work. However, definitions and nomenclature often vary from source to source, making it difficult to compare information, and little information is available about the extent of work by those under the age of 15. Nor is there much information on subpopulations of young people, such as those who are disabled, poor, or members of minority groups. Information on the quality of the work in which young people en-

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Protecting Youth at Work: Health, Safety, and Development of Working Children and Adolescents in the United States gage is also lacking. Finally, there are very little data on children and adolescents who are illegally employed, either in violation of child labor laws or in illicit activities. The Current Population Survey only asks about work performed by those aged 15 and older, although research and anecdotal evidence suggest that many children and adolescents hold their first jobs at ages much younger than 15. Under the Fair Labor Standards Act (FLSA), many jobs are legal for 14-year-olds; in agriculture, children as young as 10 can legally perform some jobs. In order to understand the work experiences of young people, information on the numbers of children and young adolescents who work and the types of jobs they hold is vital. Good employment data are also necessary to establish information about injury rates. The information on all adolescents needs to be reported in ways that are useful to researchers and policy makers. Aggregating information into broad groups, such as 15-to 24-year-olds or 16-to 19-year-olds, obscures important differences that may exist at crucial developmental and legal periods. Information on the numbers of hours worked per job would allow better assessment of workers' exposures to workplace hazards and more accurate calculation of injury rates. These data are particularly important for groups of workers who are not full-time employees, such as children and adolescents. Calculating injury rates by using injuries per employee underestimates the actual extent of exposure for part-time workers. Information on the numbers of hours worked allows for the calculation of injury rates using denominator units, such as full-time-employee equivalents, that account for the actual amounts of exposure to hazards. The Current Population Survey collects information on the hours individuals have worked in the previous week on all their jobs: For those with more than one job, this aggregation does not allow for the calculation of industry-specific injury rates. Recommendation: The Bureau of Labor Statistics should routinely collect and report data on the employment of young people aged 14 and older. Such data should be reported by informative age groupings, by school status (e.g., school year or summer and in-school or not-in-school), and by hours worked per job. For the decennial census, the Bureau of the Census should collect and report similar data on employment for young workers.

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Protecting Youth at Work: Health, Safety, and Development of Working Children and Adolescents in the United States Little information on very young workers and on the employment of special populations of youth is available. In large, national surveys, such as the Current Population Survey, it is difficult to get a sufficiently large sample of these populations for accurate analyses. Therefore, specially targeted studies are needed for particular subgroups of children and adolescents. Little data exist on the illegal employment of children. Estimates based on violations of child labor laws often combine hour violations and hazardous-order violations. These estimates depend on known violations, which vary from year to year because of such factors as the number of inspectors available and the industries targeted for inspection. Furthermore, these estimates are unlikely to include children and adolescents employed in sweatshops or in other illegal activities. Recommendation: The Bureau of Labor Statistics should periodically conduct special studies to document the employment of children under the age of 14 and of special populations of children and adolescents, such as minorities, immigrants, migrant farmworkers, and those who are poor or disabled. Also needed are periodic studies of children and adolescents who are illegally employed. The bureau's sampling methodology is designed to provide reliable estimates of employment at a national level, but the size of the sample often limits the detail with which reliable state-specific estimates can be made. Yet enforcement of child labor laws and occupational safety and health regulations is frequently done at the state level. State-specific estimates of employment in those industries and jobs where youths predominantly work are necessary not only for determining reliable rates of injury or illness, but also for targeting state-based inspections of compliance with child labor laws and sites for workplace-based educational efforts. Recommendation: The Bureau of Labor Statistics should develop methods to generate reliable estimates of youth employment at the state level. Many agencies, including the National Center for Health Statistics, the Bureau of Labor Statistics, the National Institute for Occupational Safety and Health, the National Center for Education Statistics, the Bureau of Justice Statistics, and the Occupational Safety

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Protecting Youth at Work: Health, Safety, and Development of Working Children and Adolescents in the United States and Health Administration collect much information on children and adolescents. The information includes the work experiences of youngsters, but there is no standard for what information is gathered or for how it is reported. Standard definitions and nomenclature are needed to make the various sources of information more complementary. Immediately needed are appropriate definitions for the following: Work status: When surveying about young workers, it is important to collect information on jobs that are informal or unpaid, short-term or seasonal, during the summer or during the school year, and so forth. Although all agencies need not collect the same information on all work by youngsters, a common rubric or scheme is needed if information collected by different agencies is to be effectively combined or compared. Age groups: Current reporting of data by groups, such as ''under 20" or "15-to-24," ignore critical social and behavioral changes that occur during adolescence, as well as the dividing age that legally defines minors (under the age of 18). More appropriate age groupings are essential for addressing issues related to child labor. Hours of work: Categories should be standardized so that developmentally appropriate levels of investment in employment can be monitored. For example, hours worked per week might be reported in 5-hour increments. It is especially important to be able to discern the frequency at which minors work at different intensities in examining the consequences of work. Recommendation: Federal agencies that collect data related to work by children and adolescents should establish standardized nomenclature and definitions for such variables as work status, age groups, and hours of work. Those agencies that collect data for health, education, and development purposes should also collect data on the employment of youngsters in their surveys. EDUCATION The health and safety hazards that face children and adolescents in the workplace and the protections to which they are entitled under the law are little known or understood by the children and

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Protecting Youth at Work: Health, Safety, and Development of Working Children and Adolescents in the United States adolescents themselves, by their parents, or by other adults who are in positions to give them guidance. The committee proposes several plans to begin to remedy this lack of knowledge and to promote understanding of the conditions that allow or promote safe and meaningful work experiences for children and adolescents. Information and Training A number of efforts are currently under way around the country to provide information and training related to making workplaces safe and healthy environments for young people. It was beyond the scope of the current study to adequately assess the most appropriate mechanisms for providing such training. Undoubtedly, a variety of mechanisms are needed, depending on whether the target audiences are young people themselves; or their parents, teachers, employers, health care providers, or community leaders. The federal government could play a key role in advancing information in this area by supporting a series of demonstration projects to test the feasibility and effectiveness of various approaches to information and education about health and safety issues related to the employment of young people. Examples of the types of approaches that could be tested include the following: Regional resource centers could be funded to provide technical assistance to schools, employers, and local government agencies regarding the health and safety of young workers. The activities of such centers might include conducting qualitative research to identify the gaps in information; developing and disseminating appropriate materials on health, safety, and well-being to various key audiences, including health care professionals, educators, parents, and employers; developing educational curricula for teaching children and adolescents about workplace health and safety; facilitating the adoption of curricula in schools and work-based learning programs; and facilitating collaboration among government agencies at the state and local levels to develop programs and policies to enhance the health and safety of young workers. Mechanisms could be developed to help young workers who have encountered hazardous or otherwise unacceptable working conditions to understand their rights and to take appropriate action. Regional resource centers are one possible source of assistance; link-

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Protecting Youth at Work: Health, Safety, and Development of Working Children and Adolescents in the United States ing youngsters with organizations that have narrower responsibilities is another. Community-based approaches, involving partnerships among young workers, their parents, their employers, their schools, health care providers, community organizations, and others, have the potential to provide comprehensive and coordinated services and to identify young people's employment as an issue in which the entire community has a stake. NIOSH is currently funding three such demonstration projects. An evaluation of the effectiveness of these projects should improve our understanding about how best to focus a community's attention on the health and safety needs of young workers. NIOSH or an agency of the Department of Labor would be a logical lead agency to coordinate educational and training activities and demonstration programs. If provided adequate resources, such a lead agency would be able to collaborate with other agencies in an initiative to assemble the required blend of expertise in both content about child labor health and safety issues, in effective presentation and dissemination of information, and in training. Agencies collaborating with NIOSH and the Department of Labor should include, at a minimum, the Department of Education, the National School-to-Work Office, the Bureau of Maternal and Child Health of the Department of Health and Human Services, and the CDC's Center for Injury Prevention and Control. These federal agencies should provide information, materials, and technical assistance to state and local agencies, including state departments of education and labor and local school systems. Recommendation: A national initiative should be undertaken to develop and provide information and training to reduce the risks and enhance the benefits associated with youth employment. Adequate resources should be allocated to an agency to lead this effort. Occupational Health and Safety in School-to-Work Programs The purpose of the School-to-Work Opportunities Act of 1994 was to leverage other resources to foster partnerships, at the state and local levels, that would build systems to support the transition

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Protecting Youth at Work: Health, Safety, and Development of Working Children and Adolescents in the United States associated with unhealthy and problem behaviors, including substance use and minor deviance, insufficient sleep and exercise, and limited time spent with families. Moreover, high-intensity work during adolescence has been found to be associated with decreased eventual educational attainment. In contrast to these negative consequences, some other studies have found positive results associated with moderate-to high-intensity work during high school. The results include increased employment and higher earnings for as long as 10 years after students leave high school. While conclusions about positive benefits have been questioned in some analyses (one study found that the apparent increase in earnings disappeared after carefully controlling for unobserved differences among groups of students and that it was the students who did not work at all during high school who had the highest earnings a decade later), the findings suggest that attention will need to be given to how to specify the circumstances under which the benefits outweigh the negative consequences of high-intensity work by adolescents. On balance, in the judgment of the committee, the scientific evidence supports increased restrictions on the intensity of work by children and adolescents. In keeping with its guiding principles and the research evidence, the committee believes that limiting the hours of work for most 16-and 17-year-olds during the school year is essential to their healthy development. Because of limits in the evidence, however, one cannot specify precisely at what intensity of work the negative consequences outweigh the benefits. Following the majority of the evidence to date, and the conventional cutoff used in many studies, the committee strongly supports a limit of 20 hours of work per week during the school year for adolescents under most circumstances. The committee acknowledges that care will have to be taken in setting an upper limit in number of work hours for 16-and 17-year-olds. Some circumstances may warrant exemptions from the limitations on work hours during school, such as for adolescents in extreme financial need or for emancipated minors. There may also be special circumstances, related to an individual student or to the quality of the work (e.g., high-quality school-to-work placements), under which high-intensity work may be determined to have fewer negative consequences than benefits.

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Protecting Youth at Work: Health, Safety, and Development of Working Children and Adolescents in the United States It has been suggested that there may be some students who might drop out of school if their work hours are limited. The committee did not thoroughly review the literature on dropping out of school, but multiple factors, many of which precede entry into the work force, may lead youngsters to drop out of school. Dropping out of school has also been linked to the labor market, with dropout rates declining as unemployment rates rise. Clearly, the issue of dropouts deserves further investigation and, as standards are implemented, this is a question that should be monitored closely. As with any policy change, other unintended consequences may occur, as well. For example, restrictions on the hours that adolescents can work might reduce their employment opportunities. Often, when employment of a particular group is made more difficult or costly for the employer, the employment level for that group declines, but the experience in Washington state suggests that this may not necessarily be the case for young people (see Chapter 6). After Washington imposed stricter limits on work by 16-and 17-year-olds, there was no decrease in the number of jobs available for adolescents. One method to arrive at the appropriate restrictions would be for the Department of Labor to establish an expert advisory committee charged with recommending what specific limits should be placed on allowable work hours for youngsters aged 16 and 17 and what, if any, exceptions to these limits should be permitted. In addition to the number of hours worked per week, the advisory committee should also investigate whether hours per day and start and stop times of work, particularly on school nights, should be included in the regulation. Recommendation: The Department of Labor should be authorized by Congress to adopt a standard limiting the weekly maximum number of hours of work for 16-and 17-year-olds during the school year. This standard should be based on the extensive research about the adverse effects of high-intensity work while school is in session. Currently, children and adolescents working in agriculture are permitted to work many more hours and at younger ages than those who work in nonagricultural workplaces. Yet, the negative conse-

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Protecting Youth at Work: Health, Safety, and Development of Working Children and Adolescents in the United States quences of long hours of work are equally serious for youngsters working in agriculture as for those working in other industries. Recommendation: The current distinction in federal child labor restrictions on the total maximum weekly hours youngsters are allowed to work in agricultural and nonagricultural industries should be eliminated in favor of the more stringent nonagricultural restrictions. Hazardous Work Many existing hazardous orders, which restrict the types of jobs those under 18 (under 16 in agriculture) may perform, refer to machinery and processes that are no longer used, and they fail to address the full range of health and safety hazards and technologies in the contemporary workplaces in which youngsters are now employed. None of the current hazardous orders takes into account the special risks to young workers caused by exposure to carcinogens, biohazards, reproductive toxins, and ergonomic hazards, the health effects of which may not be evident until adulthood. Changes in hazardous orders should be based on research and data on jobs that pose hazards to children and adolescents. NIOSH performs and reviews this research and is in a position to evaluate hazardous occupations for young people, although it may need additional resources to perform thorough evaluations. The institute has already made a number of research-based recommendations about needed changes in hazardous orders in its 1994 comments to the Department of Labor. The reviews and updates should be performed on a periodic basis to ensure that the hazardous orders remain up to date. Recommendation: The Department of Labor should undertake periodic reviews of its hazardous orders in order to eliminate outdated orders, strengthen inadequate orders, and develop additional orders to address new and emerging technologies and working conditions. Changes to the hazardous orders should be based on periodic reviews by the National Institute for Occupational Safety and Health of current workplace hazards and the adequacy of existing hazardous orders to address them.

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Protecting Youth at Work: Health, Safety, and Development of Working Children and Adolescents in the United States All working children and adolescents should be equally protected from similar hazardous occupational conditions, including those caused by chemical exposures or dangerous machines, regardless of the types of industry or the workers' relationships to their employers. The current distinction between agricultural and nonagricultural industries is frequently artificial. The committee's review determined that activities and machinery are often similar in both settings. For example, tractors are used in both agricultural and nonagricultural industries, and construction activities occur on farms. Activities that are hazardous for those under the age of 18 in nonagricultural settings are equally hazardous in agricultural settings, yet current regulations do not protect 16-and 17-year-olds on farms from performing hazardous tasks, nor do they protect youngsters of any age on their parents' farms. The only appropriate justification for a lower minimum age for performing hazardous work would be demonstrably lower risks in the industry, but this is not the case for work in agriculture: agriculture is one of the most dangerous industries in the country. Recommendation: The current distinctions between hazardous orders in agricultural and nonagricultural industries should be eliminated. Furthermore, the minimum age of 18 should apply for all hazardous occupations, regardless of whether the adolescent is working in an agricultural or nonagricultural job, and whether the minor is employed by a stranger or by a parent or other person standing in for the parent. Minimum Levels of Protection State regulations vary widely on the maximum weekly hours that are permitted for minors under the age of 16. Although some states have enacted regulations that are consistent with the Fair Labor Standards Act regulations, 16 states allow minors to work more than the federal maximum. For example, Wyoming allows minors to work as many as 56 hours per week, Idaho allows 54 hours per week, and a number of other states allow 48 hours per week. For businesses that do not meet the threshold for coverage under the FLSA, the less protective standards apply in those states. A few states regulate the maximum permissible hours of work

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Protecting Youth at Work: Health, Safety, and Development of Working Children and Adolescents in the United States per week for 16-and 17-year-olds, and these rules also vary, ranging from 20 to 50 hours per week. States' hazardous orders also differ with regard to coverage and interpretation from the FLSA hazardous orders. Although some states have incorporated the federal standards, other states have adopted their own definitions, as in the case of operating power-driven machinery. Consistent with the principle of equal protection for all children, the committee believes that federal hour limitations and hazardous orders should be considered the minimum safe requirements for working children and adolescents. States should be free to have more stringent regulations, but not less stringent ones. Recommendation: All state regulations for minors' working hours and hazardous orders should be at least as protective as federal child labor rules. Under current law, young workers in agriculture are not entitled to the same health and safety protection as in those other industries. Only a few Occupational Safety and Health Administration standards apply to agriculture. Standards that regulate such things as electrical hazards, unguarded machinery, confined spaces, heat stress, carcinogens, and access to medical and exposure records in other industries do not apply in agriculture. The hazard communication standards under OSHA with respect to pesticides have been preempted by less comprehensive Worker Protection Standards under the purview of the U.S. Environmental Protection Agency. Furthermore, although the enforcement of OSHA standards is generally more limited for businesses that employ 10 or fewer workers, these businesses must nonetheless comply with the standards, while farms that employ 10 or fewer workers and do not have labor camps are exempted altogether from such enforcement. No health and safety justification for the distinction between agricultural and nonagricultural settings appears to exist. It should be a priority to protect the large number of youngsters working in agriculture from the recognized significant risks of such work to the same extent that young workers are protected in other industries. The committee acknowledges that extending OSHA coverage to agriculture would be a major change in policy with many ramifications, particularly since OSHA regulations have, to date, not distinguished between adult and youth workers. However, the fact that

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Protecting Youth at Work: Health, Safety, and Development of Working Children and Adolescents in the United States agriculture is one of the most dangerous industries in the country suggests the need to closely examine health and safety issues in agriculture. In this regard, the committee calls on Congress, which annually has passed language that forbids OSHA enforcement on small farms, to commission a study of the potential effects of bringing agriculture generally, and small farms, in particular, into alignment with other businesses under OSHA and to examine the feasibility of such a change. Under OSHA regulations, there are difficulties in singling out a designated group of workers for specific protections. However, in light of the President's Executive Order asking all agencies to consider the effects of their operations and programs on children, the study could investigate the possibility of extending occupational health and safety protections in agriculture to those under the age of 18, rather than to all workers on small farms. In addition, such a study should review the application of hazard communication standards developed under OSHA and the standards under the EPA's Worker Protection Rule to identify gaps in the coverage of agriculture. Recommendation: To ensure the equal protection of children and adolescents from health and safety hazards in agriculture, Congress should undertake an examination of the effects and feasibility of extending all relevant Occupational Safety and Health Administration regulations to agricultural workers, including subjecting small farms to the same level of OSHA enforcement as that applied to other small businesses. Neither the Occupational Safety and Health Administration nor the Environmental Protection Agency (EPA) have considered, in their standard-setting processes, the special risks to the health and safety of young workers. Based on available research, the committee is particularly concerned about young workers' exposure to carcinogens, reproductive toxins, biohazards, and musculoskeletal hazards, which may cause serious and long-term harm that is not adequately prevented by the current standards. Even if young workers are not especially susceptible to these risks, their ages alone mean that the periods of time over which they may suffer adverse consequences are greater for them than for adults. Although the EPA is mandated by the Food Quality Protection Act to review pesticide standards to determine the safety of children from pesticide residues on food, the

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Protecting Youth at Work: Health, Safety, and Development of Working Children and Adolescents in the United States act does not address the health and safety of minors who are exposed to pesticides or treated crops in the course of working. In light of Executive Order 13045 (issued in April 1997), in which President Clinton identified the need for special attention to environmental health and safety risks to children and called upon all federal agencies to identify and assess those risks, it seems particularly timely for the issues of exposures to working children to be addressed. Recommendation: The National Institute for Occupational Safety and Health, in consultation with the Occupational Safety and Health Administration and the Environmental Protection Agency, including the latter's Office of Child Health Protection, should report on the extent to which existing occupational health and safety and pesticide standards take into consideration special risks for young workers. In addition, the Task Force on Environmental Health Risks and Safety Risks to Children, created by Executive Order 13045, should ensure that its definition of children include older children and adolescents and includes exposures to children and adolescents at work. Enforcement Various studies have documented the widespread inconsistencies among the states regarding the enforcement of child labor laws and the penalties for violating them. Budget cuts have limited federal and state compliance, and only 3 states have more than 50 compliance officers to investigate violations of the labor laws regarding adults and children. Targeted inspections, when used, have been particularly effective in drawing attention to child labor violations by some employers and in deterring others from similar conduct. The penalties for such violations have historically been so low (penalties ranging from $5 to $10,000 per violation, with many states collecting nothing) that fines alone appear to have little deterrent effect on employers. Although federal penalties were increased to $10,000 for any violation that leads to the serious injury or death of a minor, few states have adopted that level of penalty. The Department of Labor has no mechanism to penalize egregious wage and hour violations or child labor cases that involve violations of occupational health and safety rules.

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Protecting Youth at Work: Health, Safety, and Development of Working Children and Adolescents in the United States Recommendation: The Wage and Hour Division and the Occupational Safety and Health Administration enforcement systems should establish special-emphasis programs to increase the level and effectiveness of the inspections of industries that entail particularly high risks and employ large numbers of children. Such programs should also target noncompliant owners who endanger children by willfully or repeatedly disregarding the law. The Department of Labor should evaluate the effectiveness of penalty multipliers and other approaches to increased penalties for serious, willful, and repeated violations of wage and hour regulations and health and safety rules involving children at work. Identifying violators serves two valuable functions: It provides information to young workers, their parents, educators, and others—enabling them to make informed choices about places to work—and it serves as a deterrent to employers, reminding them of their obligations. Publicizing violations of child labor laws is analogous to a public health agency's identifying restaurants found in violation of proper food handling procedures, and it is likely to have the same deterrent effect. To prevent unwarranted punishment, only serious, willful, or repeated violators should be so identified. This recommendation is made with the understanding that it represents a direct reversal of policy in some states, which explicitly prohibits the identification of violators. Recommendation: State and federal agencies responsible for enforcing regulations governing the health and safety of working minors should actively publicize serious, willful, and repeated violators and violations. Although a memorandum of understanding exists between the Wage and Hour Division and OSHA, little has actually occurred, in terms of cross-training of inspectors, referrals, or collaborative inspections, that would be efficient and effective in identifying and penalizing all child labor and health and safety violations in workplaces that employ minors. The number of inspectors or compliance officers available to each agency is insufficient and cannot be expected to permit either agency to regularly inspect all workplaces. If the inspectors were cross trained, however, either agency's inspectors would be able to identify serious violations of the other agency's regulations.

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Protecting Youth at Work: Health, Safety, and Development of Working Children and Adolescents in the United States Recommendation: Interagency cross-training of inspectors should be developed and collaborative multiagency inspections should be increased to ensure that employers comply with all applicable child labor and occupational health and safety standards. Workers' Compensation There has been no systematic study of the adequacy and effectiveness of the workers' compensation system in dealing with the work-related injuries and illnesses sustained by young people. The committee's review indicates that young workers may be less likely than others to make use of the workers' compensation system, but the reasons for this remain speculative. Minors working in agriculture continue to be totally excluded from workers' compensation in most states. The model of indemnification for adult workers—lost wages and medical expenses—does not adequately compensate young workers for their unique losses, such as lost school time (which could have adverse effects on their educational attainment). Recommendation: The National Institute for Occupational Safety and Health and the Occupational Safety and Health Administration, with the assistance of representatives from state workers' compensation programs, should study and report on the adequacy of current workers' compensation coverage, utilization, and indemnification for young workers. The study should consider examples of effective activities by states and other options for reforming the system to protect and compensate young people for the full range of loss, specifically including the adverse educational consequences of workplace injuries and illnesses. Work Permits and Registration Systems Work permits, like other child labor regulations, vary widely among the states in content and requirements. FLSA regulations encourage, but do not require, work permits for minors. These systems offer opportunities to identify young workers in need of training, as well as opportunities for collecting data about young

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Protecting Youth at Work: Health, Safety, and Development of Working Children and Adolescents in the United States workers. However, state permit systems generally fail to facilitate the training of minors on health and safety issues. The systems seldom make use of the permits to track young people's employment to identify and prevent work-related injuries and illness or violations of hazardous orders or rules regarding wages and hours. One alternative that the committee considers worthy of serious consideration for adoption by states is to require the employers who want to hire minors to obtain permits first. The states of Washington and Oregon have adopted such systems, which enables their labor departments to set and enforce working conditions. Recommendation: The Department of Labor, in collaboration with NIOSH, should report on the existing and potential work permit or registration systems for young workers and for employers who intend to hire young workers. The report should examine the cost, use, and effectiveness of permits or registration for health and safety education, surveillance, enforcement, and reduction of workplace injuries and illnesses. OTHER RESEARCH The committee identified several critical areas in which additional research is needed for the adequate protection of young workers. Because so many young people in the United States are working, it is important to determine the strategies that will best serve to make their work experiences safe and healthful. Such research requires increased knowledge about the risk factors (hazards, level of training and supervision, fatigue, and so on) that lead to workplace injuries and illnesses among children and adolescents, as well as evaluation of injury prevention efforts. Agencies that fund research on children and adolescents should be provided sufficient resources to fund the following types of initiatives: Longitudinal studies of how individuals who have worked in their youth function as adolescents and adults and how various outcomes are associated with the quality of the work experiences. Research on working children and adolescents has primarily focused on the effects of the numbers of hours worked. Little attention has been paid to the quality of the work environment and its effect on development, workplace injuries, and educational goals.

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Protecting Youth at Work: Health, Safety, and Development of Working Children and Adolescents in the United States Research to determine whether the developmental characteristics of children and adolescents put them at increased risk from factors in the work environment, including chemical, physical, ergonomic, and psychosocial conditions (such as stress or type of supervision). Very little research has focused on the interaction of developmental characteristics of children and adolescents and risks in the workplace. Recently, the susceptibility of very young children to environmental and chemical toxins has received significant attention. This attention needs to be extended to older children and adolescents to discover at what ages susceptibility reaches a level no different from that for adults. Furthermore, the potential for harm to the musculoskeletal system caused by the physical demands of different types of work during the growth periods of adolescence needs greater attention. Research on the most efficient and effective strategies to protect working children and adolescents, with an emphasis on primary prevention of injury and other negative outcomes.