Two new Washington laws—House Bills 1121 and 1164—give employers greater scheduling flexibility for certain minor workers while increasing workplace safety requirements for youth and penalties for violations.

Beginning July 1, 2026, minors enrolled in approved college or career and technical education programs may work the same number of hours during the school year that they are permitted to work during school breaks. This change is intended to expand opportunities for students to participate in work-based learning programs and job training.

At the same time, the new laws impose additional obligations on employers. These include state-facilitated safety consultations before minors may begin certain work-based learning placements; stricter requirements for student learner variances; heightened safety requirements; and increased penalties for violations.

Despite the new scheduling flexibility, Washington's youth-employment laws remain highly regulated. Employers should ensure that any use of expanded school-year hours complies with all applicable statutory and regulatory requirements.

Background

Previously, Washington law allowed certain 16- and 17-year-old workers enrolled in qualifying college programs to work the same hours during the school year that they could work during school breaks. Students participating in career and technical education (CTE) programs, however, were not eligible for this flexibility.

Under the new law, minors aged 16 and 17 enrolled in approved CTE programs may now work the same number of hours during the school year as they are permitted to work during school breaks. The change is intended to expand opportunities for students to earn income and gain practical work experience while remaining in school. For example, a student could attend high school classes in the morning and participate in work-based learning at an approved employer jobsite for the remainder of the day.

The legislation also introduces new compliance and safety requirements for employers. Employers seeking to hire minors for certain hands-on training roles must complete a safety consultation with Washington State Department of Labor & Industries (L&I) before obtaining variances that allow minors to perform work otherwise restricted based on age.

In addition, employers must meet stricter safety standards before bringing students into the workplace. The laws strengthen the state's authority to bar noncompliant employers from hiring minors. For example, L&I must revoke an employer's minor work permit following a serious violation that results in the severe injury or death of a minor, preventing the employer from hiring minors for at least 12 months.

Penalties for youth employment violations have also increased. Employers may face $100 penalties for each instance of failing to obtain a required minor work permit and minimum penalties of up to $71,000 for violations resulting in the serious injury or death of a minor worker.

What Employers Should Know

Employers should treat these changes as a limited expansion of scheduling flexibility, not a broad rollback of Washington's child-labor protections.

Employers should:

  • Verify eligibility before scheduling expanded hours, including confirming enrollment in a qualifying program and required program approval of the employer/worksite.
  • Update youth-employment policies and manager training to ensure supervisors understand that expanded hours apply only to certain qualifying students.
  • Continue complying with all other child-labor requirements, including hazardous-occupation restrictions, wage-and-hour laws, meal and rest break requirements, and permitting and recordkeeping obligations.
  • Document eligibility and approvals before assigning school-year schedules that rely on the new flexibility.
  • Monitor L&I rulemaking, which may impose additional consultation, safety, and compliance requirements.

Takeaway

The new law will provide employers hosting students in approved college or CTE programs with greater scheduling flexibility beginning in 2026.

Employers considering using this expanded-hours exception during the academic term should consult counsel to confirm eligibility and ensure continued compliance with Washington's child labor laws.

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Scott Prange is counsel and Lauren Nelson is an associate in the employment group in the Seattle office of DWT. For more insights, reach out to Scott, Lauren, or another member of our employment services team or sign up for our alerts.