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Guide

Working with Minors in CTE Pathways

In review Last checked

About this guide: three layers of rules

This guide covers what 16- and 17-year-old CTE students may do when they work at a job site, and what you must file before they start. It applies to the eight wave 1 pathway guides (nurse aide, EMT, electrical, welding, construction and carpentry, HVAC, cybersecurity and networking, programming and computer science) and the twelve wave 2 guides in the quick reference table, across Michigan, Virginia, North Carolina, Arizona, Pennsylvania, Missouri and Hawaii.

Three layers of rules apply to every placement:

  1. Federal child labor law (FLSA). The hazardous occupations orders (HOs) in 29 CFR Part 570 set a floor for all 16- and 17-year-old employees. The federal law sets no hour limits at 16 and 17.
  2. State child labor law. Each state adds its own hazardous-work list, hour limits, and permit or certificate rules. When federal and state rules differ, the stricter rule controls (29 CFR 570.50(a)).
  3. Pathway rules. Licensing boards, health regulators and clinical sites set their own ages and supervision rules. Those are in each pathway guide. This guide covers only child labor law.

Child labor law attaches to employment. The HOs apply when a student is an employee. A clinical rotation or unpaid internship that passes the U.S. Department of Labor’s primary beneficiary test (Fact Sheet #71) is training, not employment. Treat the HOs as the safety floor for every placement anyway: if an unpaid placement looks like a job, the student is an employee and every HO applies. A school lab is not employment, so the HOs do not govern what students do in your own shop.

How to read the labels. Each state fact carries one of three labels: Confirmed (checked against the rule text), Confirm with the agency (the text is unclear or the agency’s practice may differ) or Changing (a rule or system changed in 2025 or 2026). Rules were last checked October 3, 2026.

This guide states rules and steps. It is not legal advice. Have district counsel review your agreements before first use.

Decision path for a work placement

Work through four checks in order for each task on the training plan, not once for the whole placement. A single task, such as riding a scissor lift or working on a roof, can change the answer.

Every hazardous task needs an exemption route before a minor starts

noyesyesnonoyesyesnoIs the student an employee?paid, or fails the primary beneficiary testTraining placementtraining agreement; keep HO tasks out anywayIs a task covered by a federal HO?the 17 orders in 29 CFR 570.51 to 570.68Is it HO 5, 8, 10, 12, 14, 16 or 17?the orders with a student-learner exemptionTask not allowed under 18no exemption; take it out of the training planStudent-learner agreement570.50(c), or a registered apprenticeDoes the state bar the task?state hazardous list, permits and hoursUse the state exemption routeNC: Supervised Practice filed 60 days aheadVA: copy to DOLI · PA: student-learner termsMI: school-employer agreement on siteAgreement and permit on filethen the student starts work
Show the steps as text
  • Is the student an employee? No: go to Training placement (training agreement; keep HO tasks out anyway).
  • Is the student an employee? Yes: go to Is a task covered by a federal HO? (the 17 orders in 29 CFR 570.51 to 570.68).
  • Is a task covered by a federal HO? Yes: go to Is it HO 5, 8, 10, 12, 14, 16 or 17? (the orders with a student-learner exemption).
  • Is a task covered by a federal HO? No: go to Does the state bar the task? (state hazardous list, permits and hours).
  • Is it HO 5, 8, 10, 12, 14, 16 or 17? No: go to Task not allowed under 18 (no exemption; take it out of the training plan).
  • Is it HO 5, 8, 10, 12, 14, 16 or 17? Yes: go to Student-learner agreement (570.50(c), or a registered apprentice).
  • Student-learner agreement go to Does the state bar the task? (state hazardous list, permits and hours).
  • Does the state bar the task? Yes: go to Use the state exemption route: NC: Supervised Practice filed 60 days ahead; VA: copy to DOLI · PA: student-learner terms; MI: school-employer agreement on site.
  • Does the state bar the task? No: go to Agreement and permit on file (then the student starts work).
  • Use the state exemption route go to Agreement and permit on file (then the student starts work).
placement decision path · four checks per task
  1. Is the student an employee? Paid students are employees. An unpaid student is an employee if the placement fails DOL’s primary beneficiary test, for example when the host benefits more than the student, the student displaces paid staff, or the work is not tied to course credit and a training plan. If the student is not employed, the placement is training. Use a training or clinical agreement and keep HO tasks out anyway.
  2. Is a task covered by a federal HO? Check every task against the table in the next section.
  3. Does that HO have a student-learner exemption? Only HOs 5, 8, 10, 12, 14, 16 and 17 do. A task under any other HO is not allowed under 18, whatever agreement you sign. For the seven exempt HOs, write a student-learner agreement under 29 CFR 570.50(c) or place a registered apprentice.
  4. Does the state bar the task? Check the state sections below. North Carolina, Pennsylvania, Michigan, Virginia and Arizona bar some work the federal rules allow, and each has its own exemption route and paperwork. Then get any permit or certificate the state requires and put the signed agreement on file before the first day.

Federal hazardous occupations orders that affect CTE pathways

The FLSA has 17 hazardous occupations orders for 16- and 17-year-olds (29 CFR 570.51 to 570.68). The table lists the ones that come up in the eight wave 1 pathways. HOs 4, 6, 10 and 11 for wave 2 pathways are in the quick reference table and the sections on food service machines and firefighting. The apprentice exemption (570.50(b)) and the student-learner exemption (570.50(c)) reach only HOs 5, 8, 10, 12, 14, 16 and 17. Status for every row: Confirmed against the eCFR text and DOL elaws, October 2026.

HO What it covers Student-learner or apprentice exemption? Pathways it affects
HO 2 (570.52) Driving a motor vehicle on public roads and working as an outside helper on a vehicle. 17-year-olds may drive only incidentally, in daylight, under strict conditions No EMT (keep students out of the driver’s seat; ambulance services set their own driver ages), construction, electrical, HVAC (no riding on the outside of trucks; no driving between job sites except within the narrow 17-year-old rule)
HO 5 (570.55) Power-driven woodworking machines, including portable power saws and nailers used on wood Yes Construction and carpentry
HO 7 (570.58) Power-driven hoists: forklifts, scissor lifts, boom lifts, bucket trucks, cranes and powered patient lifts No Construction, electrical, HVAC, welding (lifts); nurse aide and EMT (patient lifts)
HO 8 (570.59) Power-driven metal forming, punching and shearing machines, such as press brakes and power shears Yes Welding, HVAC (sheet metal)
HO 12 (570.63) Balers, compactors and paper-products machines Yes Rarely relevant. HO 12 does not cover electrical work
HO 14 (570.65) Circular saws, band saws, reciprocating saws, chain saws, guillotine shears, wood chippers and abrasive cutting discs Yes Construction, electrical (cutting strut and conduit), welding (cut-off wheels), HVAC
HO 15 (570.66) Wrecking, demolition and shipbreaking, including demolition cleanup No Construction, electrical and HVAC renovation work
HO 16 (570.67) Roofing and all work on or about a roof, including rooftop equipment Yes Construction, HVAC (rooftop units), electrical (rooftop solar and service work)
HO 17 (570.68) Trenching and excavation. Manual work in trenches 4 feet deep or less is allowed Yes (for deeper work) Construction, electrical (trenching for conduit and grounding)

What no federal HO covers. No HO covers electrical work as such, welding, ladders and scaffolds at 16 and 17, confined spaces, or office and IT work. Where those are barred, the bar comes from state law (see the state sections).

Powered patient lifts. DOL’s Fact Sheet #52 says HO 7 bars minors under 18 from operating or assisting in operating power-driven patient lifts. Field Assistance Bulletin 2011-3 sets an enforcement policy, not an exemption: DOL will not cite a 16- or 17-year-old who assists with floor-based, ceiling-mounted or sit-to-stand powered lifts only when all of these hold. The student has completed nurse aide training and competency evaluation, works as the junior member of a team of at least two led by an employee 18 or older, has no independent hands-on contact with the patient while the lift is used, and has received the bulletin’s Attachment A from the employer. The policy also requires that the student is not injured. A 2018 DOL proposal to allow 16- and 17-year-olds to operate patient lifts was withdrawn in 2019. In a clinical rotation that is not employment, HO 7 does not apply, but most clinical sites set their own lift policy.

Bloodborne pathogens. OSHA’s bloodborne pathogens standard covers employees, not unpaid students. Your agreement should say who provides training, hepatitis B vaccination or declination, and follow-up after an exposure.

Hours for 14- and 15-year-olds only. The FLSA sets no hour limits for 16 and 17. For 14 and 15, it allows no more than 3 hours on a school day, 18 hours in a school week, and work only between 7 a.m. and 7 p.m. (9 p.m. from June 1 to Labor Day) (29 CFR 570.35). Most CTE worksite placements involve 16- and 17-year-olds, so state hour limits are the ones to check.

Student-learner pay. An employer may apply to DOL for a certificate to pay a student-learner at least 75 percent of the federal minimum wage. State minimum wage laws may not allow this. Confirm with the state labor agency before you mention it to an employer.

Penalties. Federal civil penalties (2026): up to $16,035 per child labor violation; up to $72,876 when a violation causes serious injury or death; up to $145,752 if that violation is repeated or willful.

Hours, permits and certificates by state

This table covers 16- and 17-year-olds during the school year. Federal law sets no hours at these ages, so the state rule is the one that applies. Build the student’s work schedule, including any release time, inside these limits.

State Permit or certificate at 16 and 17 School-year hour limits at 16 and 17 Status
Michigan Work permit required. Since October 2, 2026, permits come from LEO’s online Youth Employment Permit Portal, not from schools. Employers register before hiring a minor and report when the job ends. A school-issued permit from before October 2 stays valid until the student changes employers 24 hours a week when school is in session; 10 hours a day; 6 days a week; no work 10:30 p.m. to 6 a.m. (11:30 p.m. on Fridays, Saturdays and school vacations) (MCL 409.111) Hours Confirmed. Permit portal Changing. Whether a placement under a school-employer agreement (MCL 409.118) still needs a portal permit: Confirm with the agency
Virginia None. Employment certificates apply only under 16 (Va. Code 40.1-84) None for 16 and 17 (Va. Code 40.1-80.1; DOLI Field Operations Manual) . The age scope of the 30-minute meal-break rule in 40.1-80.1(B): Confirm with the agency
North Carolina Youth employment certificate for all employment under 18, signed by all parties before the first workday No work 11 p.m. to 5 a.m. before a school day without written approval from the parent and principal (G.S. 95-25.5). No daily or weekly cap was found
Arizona None None for 16 and 17. A.R.S. 23-233 limits apply only under 16
Pennsylvania Work permit for every minor under 18, issued by the school district’s issuing officer. Students can appear virtually (Act 117 of 2022) 8 hours a day and 28 hours in a school week, between 6 a.m. and midnight (Act 151 of 2012)
Missouri None. Work certificates apply only under 16 (RSMo 294.024) None for 16 and 17. RSMo 294.030 hour limits apply only under 16
Hawaii Certificate of Age (form eCL-3), issued online by DLIR. No job offer is needed to apply None, except no work during required school hours

School-day placements. Paid hours during release time count toward the weekly limit in Pennsylvania, and in Michigan when the placement is not under a school-employer agreement. A student who works 15 hours in a Pennsylvania co-op during the school day can work only 13 more hours that week at an after-school job.

Michigan’s school-employer agreement. MCL 409.118 says the Youth Employment Standards Act does not apply to a student 14 or older employed under a written agreement between the employer and the student’s school district, public school academy or nonpublic school. The employment must not violate federal law, and a signed copy must be on file at the workplace before the student starts. This removes the state hour limits and the state hazardous-work rules for that placement. Federal HOs still apply. Write the hours you will allow into the agreement, since the statute no longer sets them.

Evening work. Federal law sets no hour limits at 16 and 17. Michigan, North Carolina and Pennsylvania set school-year limits (see the table above). Where the state sets none, write a weekly hours cap and a school-night end time into the training agreement.

State hazardous-work rules by state

Five of the seven states bar 16- and 17-year-olds from work the federal HOs allow. Each has its own exemption route, and the routes differ in who signs, who files and how far ahead. Federal HOs still apply under every state exemption.

State Barred at 16 and 17 beyond the federal HOs Exemption route for CTE students Pathways most affected Status
Michigan All minors: construction work, additions, improvements, excavating, roofing, wrecking and demolition; power-driven woodworking machines, metal-forming machines and saws; power-driven hoists (R 408.6208(2), (9), (11)). Welding, ladders and scaffolds are barred only under 16 (R 408.6209) A written agreement between the employer and the student’s school. R 408.6206(a) says the rules do not apply to a student 14 or older employed under such an agreement, and MCL 409.118 exempts the placement from the whole act. Keep a signed copy at the workplace before the first day. LEO cannot grant a deviation that opens hazardous work (MCL 409.120) Construction, electrical, HVAC, welding Rule text Confirmed. Whether R 408.6206(a), which names only school district boards, covers public school academies: Confirm with the agency
Virginia Roofing, power saws, power woodworking, demolition, excavation and the other items in 16VAC15-30, which track the federal HOs A written work-training agreement signed by the employer and the school coordinator, with the four student-learner elements, and a copy filed with DOLI (Va. Code 40.1-100). DOLI posts a form only for pharmacy technicians. Registered apprentices 16 and older may work as the FLSA allows (Va. Code 40.1-100(A)) Construction, HVAC, electrical Exemption route Confirmed. The power saw and roofing rules state that apprentice and student-learner exemptions apply (16VAC15-30-150, -170). Confirmed. Power woodworking and DOLI’s filing form: Confirm with the agency
North Carolina Any work as an electrician or electrician’s helper; welding and torch cutting; work with a fall risk of 10 feet or more; confined spaces; work that requires a respirator (13 NCAC 12 .0406) A registered apprentice, an FLSA student-learner, or an NCDOL-approved Supervised Practice Youth Work-Based Experience Agreement for ages 16 and 17 (G.S. 95-25.5(k1)), approved by the NCDOL Wage and Hour Bureau before the student starts the task (allow about 60 days). Supervised Practice covers paid work at minimum wage or higher Electrical, welding, construction, HVAC
Arizona Power woodworking machines, power saws, roofing, wrecking and demolition, and most excavation (A.R.S. 23-231) A.R.S. 23-235 exempts students in career education or vocational and technical programs and registered apprentices from the state list. No filing is required Construction, HVAC
Pennsylvania Electrical work, welding, power woodworking and roofing, among other items (34 Pa. Code chapter 11) Apprentices, student-learners, and graduates of an approved vocational program in that occupation. PDE’s Cooperative Education Guidelines require documented safety instruction for any student-learner exemption. The exemption covers roofing (34 Pa. Code 11.63), and the federal roofing rule allows the same exemption. Federal rules still bar driving on the job, hoisting equipment including power patient lifts, and demolition, with no exemption Electrical, welding, construction, HVAC
Missouri Nothing. RSMo 294.040 applies only under 16 Federal 570.50(c) governs None beyond federal
Hawaii HAR chapter 12-25 orders largely track the federal HOs. No electrical, scaffold or ladder order was found Student-learner and apprentice exemptions sit inside HAR 12-25-43, -46, -47, -49, -51, -53 and -54 and require a DOE-approved cooperative vocational program. HAR 12-25-48 (bakery machines) has no exemption, so employed minors may not run power-driven mixers, including countertop mixers. HAR 12-25-56 (logging and sawmill) has no student-learner exemption. An apprentice or trainee agreement must be registered with DLIR within 30 days Same as federal

Michigan in practice. Without a school-employer agreement, a 16- or 17-year-old in Michigan cannot be employed in construction work at all, and that includes most electrical, HVAC and carpentry job sites. With one, only the federal HOs apply. Earlier pathway guides in this set marked the scope of R 408.6208 as an open question. The rule text and R 408.6206(a) now answer it: use the school-employer agreement for every paid trades placement. Michigan districts can use MDE’s sample CTE training agreement as the base document.

Energized electrical work. No federal or state child labor rule reviewed addresses live electrical work by minors directly. Set a program policy that students do no energized work, lockout and tagout, or work with arc-flash exposure. This is a recommended program standard, not a cited rule.

Student-learner agreement: required elements and template

You need a student-learner agreement only when a task on the training plan falls under HO 5, 8, 10, 12, 14, 16 or 17. The student must be enrolled in a course of study and training in a cooperative vocational training program under a recognized state or local education authority (29 CFR 570.50(c)). DOL publishes no sample agreement, so write your own.

What the federal rule requires

The agreement must be in writing, name the student, and be signed by the employer and by the school coordinator or principal. Each party keeps a copy. It must state that:

  1. The hazardous work is incidental to the training.
  2. The hazardous work is intermittent and for short periods, under the direct and close supervision of a qualified and experienced person.
  3. The school gives safety instruction, and the employer ties it to on-the-job training.
  4. A schedule of organized and progressive work processes is attached.

DOL can revoke the exemption for a student if reasonable safety precautions were not followed. A student who graduates can continue as a student-learner in the occupation trained for until age 18. Michigan’s MDE guidance reads “intermittent and for short periods” as under one hour at a time and under 20 percent of the shift. That is state guidance, not federal rule text, and you can use it as a benchmark in other states.

State additions

  • Michigan: sign the agreement as the school-employer agreement under MCL 409.118 and keep a copy at the workplace before the first day. For credit-bearing placements, R 340.15 also requires a training plan, a certificated teacher’s site visit at least every 9 weeks, and proof of the employer’s workers’ disability compensation and liability insurance.
  • Virginia: the employer and school coordinator sign, and copies go to the school, the employer and DOLI (Va. Code 40.1-100).
  • North Carolina: for electrical, welding, height, confined-space or respirator tasks, use NCDOL’s Supervised Practice Youth Work-Based Experience Agreement and get NCDOL approval before the student starts. Submit it about 60 days ahead.
  • Pennsylvania: PDE’s co-op guidelines require the student, parent, school official, employer and coordinator to sign, and the training plan must list the CIP code and the competencies with approximate time for each. Record the work permit number.
  • Hawaii: the student-learner exemptions require a DOE-approved cooperative vocational program. Register an apprentice or trainee agreement with DLIR within 30 days.
  • Arizona and Missouri: no state filing. Use the federal elements.

Template

Copy this into your district’s training agreement as an addendum. Have counsel review it before first use.

Student-Learner Addendum to the Training Agreement

Student: [full name], date of birth [date], enrolled in [program name and CIP code] at [school].

Employer: [business name], worksite [address]. Supervisor: [name and title], who is qualified and experienced in [occupation].

Hazardous tasks covered: [list each task and the HO it falls under, for example: “Cutting strut with a portable band saw, HO 14”]. No other hazardous task is permitted. The student will not operate or ride any lift, forklift or hoist, drive or ride outside a vehicle, or do demolition work.

  1. Each task listed is incidental to the student’s training in [occupation].
  2. The student will do these tasks only intermittently and for short periods, under the direct and close supervision of the supervisor named above or another qualified and experienced person.
  3. The school gave safety instruction on these tasks on [dates]. The employer will tie that instruction to on-the-job training before the student does each task.
  4. The attached training plan sets a schedule of organized and progressive work processes.

[State line: Michigan, this is a written agreement under MCL 409.118 and is on file at the worksite. Virginia, a copy has been filed with DOLI on (date). North Carolina, NCDOL approval received on (date).]

Signatures and dates: employer, school coordinator or principal, student, parent or guardian. Copies to each party and to the worksite file.

Training plan elements

Attach a plan that lists the competencies the student will learn, the approximate time for each, the related classroom instruction, the safety training required before each hazardous task, and how and when the supervisor and coordinator will evaluate the student. The Clinical and Work-Based Learning Partnerships toolkit has a full training agreement template and host intake checklist.

Quick reference by pathway

Use this table to see which rules a placement in each pathway will hit. The pathway guides cover credential ages, licensing and clinical rules.

Pathway Federal HO limits at 16 and 17 State limits beyond federal What to put in place
Nurse aide and patient care HO 7 bars operating powered patient lifts. FAB 2011-3 allows assisting only under its conditions, including completed nurse aide training and a two-person team led by an adult employee No state bar found in the seven states Clinical rotations: a clinical agreement that states students are trainees, not employees. Paid aide jobs at 16 and 17: the state permit or certificate, and the lift conditions in writing
EMT HO 2 limits driving; keep students out of the driver’s seat. HO 7 applies to powered patient lifts No child labor bar found. Certification age gates are state EMS rules (see the EMT guide) Field and clinical agreements for ride-alongs. Ride-alongs that are training are not employment
Electrical HO 7 lifts and HO 15 demolition are barred. HO 14 saws, HO 16 roofs and HO 17 trenches need a student-learner agreement. No HO covers electrical work itself NC: all electrician and helper work. PA: electrical work. MI: construction work generally NC: Supervised Practice agreement approved by NCDOL before work starts, or a registered apprenticeship. PA: student-learner agreement. MI: school-employer agreement on site
Welding HO 8 metal-forming machines and shears, HO 14 abrasive cut-off wheels and saws: student-learner agreement. HO 7 lifts barred. No HO covers welding itself NC and PA bar welding under 18. MI and MO bar welding only under 16 NC: Supervised Practice agreement or registered apprenticeship. PA: student-learner agreement. Elsewhere: student-learner agreement for HO 8 and HO 14 tasks
Construction and carpentry HO 5 woodworking, HO 14 saws, HO 16 roofs, HO 17 trenches: student-learner agreement. HO 7 lifts, HO 15 demolition and HO 2 outside helper barred MI: all construction work. VA: roofing, saws, woodworking, demolition. NC: falls of 10 feet or more. AZ: woodworking, saws, roofing, excavation. PA: woodworking, roofing MI: school-employer agreement. VA: work-training agreement filed with DOLI. NC: Supervised Practice for height work. AZ: no filing (23-235). PA: student-learner agreement
HVAC HO 16 rooftop units, HO 8 sheet metal, HO 14 saws: student-learner agreement. HO 7 lifts barred NC: falls of 10 feet or more, confined spaces, respirator work. PA and AZ: roofing. MI: construction work Same filings as construction. Plan rooftop and attic tasks explicitly in the training plan
Cybersecurity and networking None. No HO covers office or IT work Hours and permits in most states. North Carolina also bars under-18 work with a fall risk over 10 feet and electrician’s helper work, which can reach ceiling cabling The state permit or certificate. Employers often add background checks, confidentiality agreements and limits on access to live systems and personal data. Those are contract terms, not child labor law
Programming and computer science None No state rule found for software work. Cabling or hardware tasks follow the cybersecurity row. Otherwise limits are hours and permits only Same as cybersecurity
Automotive service technology HO 7 bars engine hoists, winches and tow-truck hoists. DOL field guidance treats vehicle lifts as outside HO 7. HO 2: no public-road driving at 16; moving cars on the shop lot is allowed. HO 14 cut-off discs need a student-learner agreement MI and AZ: power-driven hoists for all minors. NC and PA: welding and torch cutting, which reaches exhaust work List tasks by equipment (vehicle lift yes, engine hoist no). No road tests unless every 17-year-old driving condition is documented. MI: school-employer agreement. NC: Supervised Practice or apprenticeship for torch work
Medical and dental assisting HO 6 bars paid students from X-ray work above 0.5 rem a year, with no exemption No child labor bar found. Dental radiography credentials are dental board rules (see the guide) Clinical agreement that states students are trainees. For paid students who take X-rays, document operator dose or radiation safety practice. Confirm in writing that host sites let minors do venipunctures and EKGs
Cosmetology None. No HO covers salon work VA: since July 1, 2025, 16- and 17-year-olds may work in salons as apprentices, in work-training programs or with a license. AZ bars paying students in a school salon (A.R.S. 32-557) The state permit or certificate. Apprentice permits and hour rules come from the licensing board (see the guide)
Agriculture Farm hazardous orders apply only under 16. Off-farm agribusiness jobs generally follow the nonfarm HOs to 18, including HO 7 forklifts. EPA: paid pesticide handlers must be 18 HI: under-16 farm list with no exemptions. NC: youth employment certificate for farm jobs. AZ: under-16 ladder limit of 5 feet Sort each placement as farm or agribusiness first. Student-learner agreement for orders 1 to 6 under 16. Keep paid students out of pesticide handling. See Farm work and agriculture placements
Early childhood education None. No HO covers child care work Licensing sets 16 as the youngest age to count in ratio. NC: supervised by a credentialed adult 21 or older. MO: never sole caregiver or in infant and toddler ratios. PA: only after 400 classroom hours The state permit or certificate, a fingerprint background check before the first day (PA minors need all three clearances), and the student’s licensing role (staff, volunteer or student) in writing
Culinary arts and hospitality HO 10 slicers, including for cheese, bread and vegetables: student-learner agreement. HO 11 bakery machines barred, except countertop mixers of 5 quarts or less MI, AZ, VA, PA and HI have state meat and bakery machine orders. HI 12-25-48 has no exemption and no countertop carve-out. Alcohol service ages vary (see the guide) Student-learner agreement for slicer tasks. No floor mixers for any paid student. MI: school-employer agreement. A school restaurant that pays students makes them employees. See Food service machines
Machining and mechatronics HO 8 presses, press brakes and shears, HO 14 band saws and cut-off discs: student-learner agreement. CNC mills and lathes are machine tools, outside HO 8. HO 7 cranes, hoists, forklifts and lifts barred MI: metal-forming machines, saws and hoists for all minors. PA: metal forming and emery wheels (grinders). NC: welding, heights, confined spaces. HI: exemption needs a DOE-approved co-op program List tasks by machine type, not by “CNC.” MI: school-employer agreement on site. PA: student-learner agreement. NC: Supervised Practice for welding or height tasks. Keep maintenance students off lifts and cranes
Engineering and drafting None for design and CAD work. HO 5 or HO 8 applies only if a placement puts the student on shop equipment No state rule found for design work. Shop tasks follow the machining and construction rows The state permit or certificate. Add a student-learner agreement only if prototyping shop tasks are on the training plan
Firefighting No HO covers structural firefighting. HO 4 bars paid students from wildland fire suppression, with no exemption. HO 2 limits driving VA and PA set junior firefighter rules by statute. NC uses Commission guidance. MI regulates course access through cadet and explorer programs. AZ, MO and HI: none found Department cadet, explorer or junior membership, written parent permission (PA: Act 155 form with chief approval) and live fire training under NFPA 1403 or 1400. See Firefighting and public safety
Law, public safety and corrections No HO covers police, corrections, dispatch or security work. HO 2 bars driving agency vehicles. Handguns under 18 need written parental consent (18 U.S.C. 922(x)) No student can hold these jobs before 18; some sworn and detention roles start at 20 or 21. CJIS rules make students escorted visitors Observation and ride-along agreements, not employment. The agency’s consent form and, for Explorer posts, the two-adult rule. No terminal access. See Firefighting and public safety
Business management and marketing HO 12: students may load compliant balers and compactors; operating or unloading needs a student-learner agreement. HO 2 limits delivery driving Alcohol sales at the register: 18 in MI, MO and HI; 16 with an 18+ supervisor in AZ; no floor for off-premises sales in NC. VA and PA: Confirm with the agency The state permit or certificate. Keep co-op students off delivery routes and off baler operation unless a student-learner agreement covers it
Entrepreneurship None for unpaid school-based enterprise work. Paid enterprise students are district employees, and the usual HOs and hours apply Contract capacity starts at 18. PA bars LLC organizers under 18. Parent-owned businesses are exempt from federal minimum age except hazardous, manufacturing and mining work Decide whether the venture is school-run or student-owned. For a student-owned entity, name a parent or other adult as organizer or co-party

The Staffing, Partnerships, Approvals, Facilities, Curriculum and Scheduling toolkits each carry a by-pathway table that links back to the pathway guides.

Farm work and agriculture placements

Farm jobs follow their own federal rules (29 CFR 570.70 to 570.72). Off-farm agribusiness jobs do not. Sort each placement as farm or agribusiness before you write the training plan. The Agriculture guide covers credentials, SAE and FFA.

Hazardous agricultural orders apply under 16 only. The eleven orders in 570.71 cover employees under 16. At 16 and 17, a student may do any farm job, including the hazardous ones, with no federal hour limits. Confirmed.

Parent-owned farms. The farm orders do not apply to a child employed by a parent, or a person standing in place of a parent, on a farm that person owns or operates. Write your own safety plan for home SAEs. Confirmed.

Vocational agriculture student-learner exemption. The exemption in 570.72(a) covers orders 1 to 6 only: tractors over 20 PTO horsepower, the listed farm machines, earthmoving equipment, forklifts and power saws, breeding animals, timber over 6 inches, and ladders or scaffolds over 20 feet. The student must be enrolled in a vocational agriculture program and work under a signed written agreement with the same elements as the student-learner agreement above. WHD treats close supervision as one experienced adult with the first student-learner and three more for each additional one. Orders 7 to 11 (carrying passengers, silos and manure pits, Category I and II chemicals, blasting agents, anhydrous ammonia) have no exemption. Confirmed.

Training certificates for 14- and 15-year-olds. 4-H and vocational agriculture certificates open orders 1 and 2 only (tractors and the listed machines).

  • 4-H (570.72(b)): a 10-hour tractor program; or that program plus a 10-hour machine program; or a 4-hour orientation plus a 20-hour combined program. The leader who ran the program and an Extension agent both sign the certificate.
  • Vocational agriculture (570.72(c)): a 15-hour tractor program and, for machines, a further 10-hour machine program, each with written and practical tests. The agriculture teacher signs the certificate.

Keep a copy of the certificate in the employer’s records. Confirmed.

Off-farm agribusiness jobs. Work for a business that is not a farmer, such as a feed mill, grain elevator, equipment dealer or veterinary clinic, generally falls under the nonfarm rules. The nonfarm HOs apply until 18, including HO 7 for forklifts. Status for a specific employer: Confirm with the agency (DOL WHD).

Pesticides. The EPA Worker Protection Standard requires every pesticide handler and early-entry worker to be at least 18 (40 CFR 170.309(c)). The owner’s immediate family is exempt on its own farm. EPA’s 2016 FAQ says students who do handler tasks for course credit are not WPS handlers; whether that still stands: Confirm with the agency. Federal rules set 18 for commercial and private restricted-use applicator certification. State applicator ages:

  • Michigan, Virginia, North Carolina and Arizona: 18. Confirmed.
  • Pennsylvania: 18 for commercial applicators, but 7 Pa. Code 128.62 still lets 16-year-olds get a private applicator permit, which conflicts with the federal 18. Changing.
  • Missouri: 18, except that 16- and 17-year-old immediate family members of certified private applicators may be provisional private applicators (2 CSR 70-25.130). Confirmed.
  • Hawaii: no state age yet; 18 was proposed in 2026. Changing.

State farm rules.

  • Hawaii: HAR 12-25-57 bars farm work under 16 on a state list that covers most of the federal tasks and adds work with state-restricted pesticides. The state list does not include some federal tasks, such as combines, hay mowers, balers, blasting agents and driving passengers; for those, only the federal rules and their exemptions apply. Chapter 12-25 has no student-learner, 4-H, vocational agriculture or parent-farm exemption for tasks on the state list. Confirmed (checked October 5, 2026).
  • North Carolina: youth employment certificates and 13 NCAC 12 .0406 apply to farm jobs. The agriculture exemption in G.S. 95-25.14 covers only minimum wage, overtime and some record keeping. Confirmed.
  • Arizona: the under-16 list (A.R.S. 23-232) bars all ladder work above 5 feet and picking or pruning from ladders above 8 feet (federal: 20 feet). Its tractor item covers only tractors without a rollover protective structure and seatbelts, so the federal tractor order is stricter. Vocational agriculture and 4-H trainees and career education students are exempt. Confirmed.
  • Michigan and Virginia exempt parent-farm work. Michigan also exempts farm work from YESA unless it violates a department standard; the current standards: Confirm with the agency (LEO).

Food service machines

Two federal orders govern kitchen, deli and bakery placements. The Culinary Arts and Hospitality guide covers alcohol service ages, which differ by state.

HO 10, meat slicers (570.61). 16- and 17-year-old employees may not operate, set up, adjust, repair, oil or clean power-driven meat slicers and similar machines, including in restaurants and delis. The order covers a slicer used for cheese, bread or vegetables. A co-op student may use one under a student-learner agreement, only intermittently and briefly, under close supervision. Confirmed.

HO 11, bakery machines (570.62). 16- and 17-year-old employees may not operate or assist with dough and batter mixers or bread dividing, rounding and molding machines. HO 11 has no student-learner or apprentice exemption. The only machines allowed at 16 and 17 are countertop mixers of 5 quarts or less (no more than 1/2 horsepower, not hardwired, and not used for meat or poultry) and safeguarded pizza-dough rollers, for operation only. A floor mixer is off-limits to every employed minor, co-op students included. Confirmed.

School restaurants. An unpaid class lab is not employment, so HO 10 and HO 11 do not apply as law there. Use them as your safety rule anyway. A school restaurant that pays students makes them employees, and both orders apply in full. Confirmed.

State orders.

  • Michigan: R 408.6208(9)(c) and (f) bar all minors from bakery and meat-processing machines. A school-employer agreement or employment by the student’s own school lifts the state bar. Federal HO 11 still applies. Confirmed.
  • Arizona: A.R.S. 23-231 bars meat and bakery machines; A.R.S. 23-235 lifts the state bar for CTE students. Confirmed.
  • Virginia: 16VAC15-30-110 and -120 exempt student-learners. The state bakery exemption does not override HO 11. Confirmed.
  • Pennsylvania: slicing machines are open to student-learners, apprentices and approved vocational graduates. Bakery machines are barred except the countertop mixer carve-out. Confirmed.
  • Hawaii: HAR 12-25-47(c) exempts student-learners for meat machines on the 12-25-43 conditions, including a DOE-approved cooperative vocational program. HAR 12-25-48 (bakery machines) has no exemption of any kind and no countertop carve-out. Employed minors may not run power-driven mixers, including countertop mixers. Confirmed.
  • North Carolina: 13 NCAC 12 .0406 bars cutting and slicing machines in canneries and seafood and poultry processing. The FLSA student-learner and apprentice exemptions apply. Confirmed.

Firefighting and public safety

See the Firefighting guide and the Law, Public Safety and Corrections guide for certification ages and agency rules.

Structural firefighting. No federal HO covers structural firefighting. DOL has published no guidance on 16- and 17-year-olds in structural firefighting. Confirm with the agency (DOL WHD).

Wildland firefighting. HO 4 (570.54) bars paid 16- and 17-year-olds from forest fire fighting, including extinguishing spot fires, wetting down areas and patrolling burned areas. HO 4 has no student-learner or apprentice exemption, and it applies in Hawaii even though HAR 12-25 has no fire order. Keep wildland content in the classroom until students turn 18. Confirmed.

Junior volunteers. Federal child labor rules apply to employment. Under the FLSA volunteer definitions, unpaid junior members appear to fall outside them, but DOL has issued nothing on minors, and stipends or pay per call could change the answer. State law sets what juniors may do:

  • Virginia: Va. Code 40.1-79.1 exempts volunteer fire company members 16 and older, with parental approval. Va. Code 40.1-100(D)(3) bars entering a burning structure until certified, except in training toward certification. Confirmed.
  • Pennsylvania: the Child Labor Act junior firefighter rules and Act 155 of 2022 require a work permit and the Act 155 permission form. A 17-year-old may not do interior live fire suppression at a real incident until 18. Confirmed.
  • North Carolina: the Fire and Rescue Commission Junior Member Standard (2009) is guidance, not rule. It bars 16- and 17-year-olds from structure and vehicle fire suppression and from driving. Confirmed.
  • Michigan: R 29.405 regulates only course access, through registered cadet and explorer programs for ages 16 to 18. Confirmed.
  • Arizona, Missouri and Hawaii: no junior firefighter law found.

Put department cadet, explorer or junior membership and written parent permission in place before any fireground activity.

Police, corrections, 911 and security jobs. No HO covers these jobs, but no student can hold them before 18, and some sworn and detention roles start at 20 or 21. HO 2 bars paid students from driving agency vehicles. Under CJIS rules, students are escorted visitors with no terminal access. Write placements as observation and ride-alongs, not employment. Confirmed.

Handgun training. Under 18 U.S.C. 922(x), a student under 18 may possess a handgun in a course of instruction only with prior written consent from a parent or guardian, carried at all times while holding the handgun, and in line with state and local law. Long guns are not covered by 922(x). Check district weapons policy before any range activity. Confirmed.

Open questions for state agencies

These items need a call or email to the agency named. Each is labeled in the tables above.

  1. Michigan LEO: permits under a school-employer agreement. MDE’s 2022 WBL FAQ says students in state-approved CTE WBL contracts are exempt from the Youth Employment Standards Act and need no work permit. That answer predates the Youth Employment Permit Portal, which went live October 2, 2026. Ask LEO whether a student employed under an MCL 409.118 agreement needs a portal permit and whether the employer must register. Changing.
  2. Michigan LEO: public school academies and R 408.6206(a). The rule exempts placements under an agreement with a school district’s board of education. The statute (MCL 409.118) also names public school academies and nonpublic schools. Ask LEO to confirm the statute controls for academies. Confirm with the agency.
  3. Michigan LEO: deviations. Since 2024 PA 196, MCL 409.120(3) bars deviations that allow hazardous work. R 408.6208(11)(a) still describes a deviation for 16- and 17-year-olds to operate motorized hand trucks. Ask whether LEO still grants it. Confirm with the agency.
  4. Michigan MDE: workers’ compensation for unpaid placements. R 340.15 and the 2023-24 WBL Manual list workers’ compensation as required for unpaid placements; the 2022 FAQ says it is not. Confirm with the agency.
  5. Virginia DOLI: filing and apprentice status. Ask whether DOLI has a general trades work-training agreement form and how to file it, and whether a program registered with Virginia Works counts as a “voluntary apprenticeship” under Va. Code 40.1-100(A). Ask also whether the student-learner exemption reaches power woodworking machines. Confirm with the agency.
  6. Virginia DOLI: meal breaks. Confirm whether the 30-minute break rule in Va. Code 40.1-80.1(B) applies to 16- and 17-year-olds. Confirm with the agency.
  7. Missouri DESE: agreement template. No DESE training agreement template was found. Ask whether one exists. Confirm with the agency.
  8. Hawaii DOE: cooperative program approval. Ask how a CTE program becomes a “DOE-approved cooperative vocational program” for the HAR 12-25 student-learner exemptions, and whether HIDOE has a template. Confirm with the agency.
  9. Student-learner subminimum wage. Confirm in each state whether state minimum wage law allows the federal 75 percent student-learner rate. Confirm with the agency.
  10. Unpaid placements and school-to-work guidance. DOL’s older FLSA Advisor page on school-to-work students has not been reconciled with the 2018 primary beneficiary test. Use the primary beneficiary test until DOL says otherwise. Confirm with the agency.

Review status and sources

Last checked: October 3, 2026. Federal rules and the Michigan, Virginia and Missouri items were re-checked against rule text on that date; the other state items come from the October 2 verification ledger. Wave 2 additions (twelve pathway rows and the farm work, food service machines, and firefighting and public safety sections) were added October 3, 2026 from the wave 2 research files. Validation-round corrections to the North Carolina, Virginia, Pennsylvania, Michigan and Hawaii items, and the federal penalties, evening work and bloodborne pathogens notes, were made Oct. 3, 2026. On October 5, 2026, the independent check of the wave 2 guides corrected four items here: the Hawaii farm list (it does not cover every federal task), the Arizona ladder and tractor rules, the 4-H certificate signatures and the countertop mixer limit.

Change since the pathway guides were drafted. The electrical, welding, construction and HVAC guides listed Michigan R 408.6208 as an open question for 16- and 17-year-olds. The rule does bar all minors from construction work, power saws, woodworking machines and hoists, and R 408.6206(a) and MCL 409.118 remove that bar for placements under a school-employer agreement. Those guides should point here.

Pathway guides in this set: Nurse aide · EMT · Electrical · Welding · Construction and carpentry · HVAC · Cybersecurity and networking · Programming and computer science. Agreement templates and host intake: Clinical and Work-Based Learning Partnerships toolkit.

Wave 2 pathway guides: Automotive service technology · Medical and dental assisting · Cosmetology · Agriculture · Early childhood education · Culinary arts and hospitality · Machining and mechatronics · Engineering and drafting · Firefighting · Law, public safety and corrections · Business management and marketing · Entrepreneurship.

Federal sources

State sources

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