Last Updated on May 20, 2025

As seasonal hiring ramps up this summer, there is a critical area of compliance that businesses must not overlook: child labor laws. One of the most recent notable cases involves Luttrell Staffing Group, a Tennessee-based agency recently held accountable for placing minors in hazardous jobs. Here’s what you need to know to protect your organization and ensure lawful hiring of younger workers, or minors.

Background: Luttrell Staffing and the DOL’s Enforcement Action

In August 2024, the U.S. Department of Labor (DOL) announced a consent judgment against Luttrell Staffing Group, a staffing agency headquartered in Kingsport, TN. The agency was found to have violated the Fair Labor Standards Act (FLSA) by placing minors in prohibited roles at Tuff Torq Corp., a manufacturing facility in Morristown, TN.

The investigation revealed that minors under the age of 18 were assigned to operate power-driven hoisting apparatuses- a clear violation of federal child labor provisions, which strictly prohibits employing minors in hazardous occupations.

Settlement Terms: A Wake-Up Call for Employers Regarding Child Labor Law Compliance

The U.S. District Court for the Eastern District of Tennessee ordered Luttrell Staffing to:

• Pay $121,572 in civil money penalties.
• Provide detailed documentation on all minor employees to the DOL.
• Engage an independent third-party compliance specialist for at least three years.
• Submit compliance reports within 180 days and annually thereafter.
• Use the DOL’s Youth Employment Compliance Assistance Toolkit for ongoing training.
• Establish a confidential hotline for reporting potential violations.
• Include child labor law clauses and compliance contact info in all client contracts.

The company’s leadership claimed the minors provided fraudulent documents to bypass E-Verify, but this did not absolve them of responsibility under federal law.

Understanding Child Labor Laws

Under the FLSA, the employment of minors is highly regulated, especially for those under 18. Here’s a brief refresher:

Minimum Age Requirements

• 14 years old is the minimum for non-agricultural employment.
• 16 and 17-year-olds can work in most non-hazardous jobs.
• Workers under 18 cannot perform hazardous duties, as defined by the DOL.

Hour Restrictions

• 14 and 15-year-olds can work:
  • No more than 3 hours on a school day, 8 hours on a non-school day.
  • No more than 18 hours during a school week, 40 hours in a non-school week.
  • Only between 7 a.m. and 7 p.m. (extended to 9 p.m. from June 1 through Labor Day).

What Is a Hazardous Job?

The DOL has identified 17 Hazardous Occupation Orders (HOs) that apply to workers under the age of 18 in non-agricultural settings. Some examples include:

• Operating heavy machinery or power-driven equipment, including forklifts, hoisting devices, meat slicers, and certain saws.
• Driving motor vehicles or serving as an outside helper on a vehicle.
• Manufacturing or storing explosives.
• Working in demolition, roofing or excavation.
• Exposure to radioactive substances or ionizing radiation.
• Jobs involving exposure to electrical hazards or power-driven metal forming, punching or shearing machines.
• Work in slaughtering, meatpacking, or processing industries.
• Jobs in logging or sawmilling.

Even if a teen is 16 or 17, these types of work remain strictly off-limits. For a complete list of hazardous orders, click here.

In addition to the federal regulations, states may also have specific regulations related to hiring minors. Make sure to also be aware of any state or local requirements in your area.

Why This Matters Now: Summer and Seasonal Hiring Risks

Summer is traditionally a peak period for hiring teens and students. Whether you’re staffing retail stores, restaurants, camps or light industrial operations, it’s essential to:

• Know the law: train hiring managers on youth employment rules.
• Verify age documentation thoroughly, beyond relying solely on E-Verify.
• Audit job roles and tasks: ensure teens are not exposed to hazardous duties.
• Update job descriptions and postings: include age-appropriate requirements and clearly defined responsibilities.
• Maintain accurate records: track hours, job assignments and proof of age for all minors.

Closing Note: Seasonal Hiring Starts with Smart Compliance

The Luttrell Staffing case serves as a reminder that intent is not a defense- even if minors misrepresent their age, employers are still liable for child labor law violations. As you prepare for your summer workforce, especially when hiring teens or students, now is the time to tighten compliance protocols and review your practices. Hiring minors can be a great way to build your talent pipeline and support community employment, but only when done in full compliance with the law.

Make sure your business’s human resources department maintains compliance with government regulations by outsourcing HR help with MyHRConcierge. Contact us today at 855-538-6947 ext. 108, ccooley@myhrconcierge.com. If you need assistance with performing E-Verify, you can also contact MyHRScreens at 866-899-8970 ext. 118 or klewis@myhrscreens.com. Or, schedule a convenient consultation below: