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A new Iowa law recently signed by Governor Reynolds related to minors working longer hours, later at night, and performing certain types of tasks conflicts with federal law. Prior to enactment, the U.S. Department of Labor (DOL) sent a letter to the Iowa legislature highlighting the conflicts with federal law which are detailed as follows:

  • Permitting 14 and 15 year olds to work “before the hour of 7:00 a.m. or after 9:00 p.m., except the period from June 1 through Labor Day when the hours may be extended to 11:00 p.m.”
  • Permitting 14 and 15 year olds to outside of school hours up to six hours in a day or 28 hours in one week while school is in session.
  • Permitting 14 and 15 year olds to work in non-agricultural occupations that are not listed in the federal regulations (i.e., light assembly work, non-incidental work in meat freezers).

Finally, the new Iowa law describes permitting minors to engage in “work-based learning programs” without reference to the fact that specific federal requirements must be met first.

Employers that have an annual gross volume of sales made or business done totaling $500,000 or more, and employees who are engaged in “interstate commerce” and public agencies all fall within the jurisdiction of the Fair Labor Standards Act. Accordingly, employers that do not comply with the federal regulations run the risk of DOL complaints, investigations and civil money penalties. In FY 2022, the DOL received over 800 cases with child labor violations (including employing minors in hazardous occupations) resulting in over $4.3 million dollars in civil money penalties. See

Employers looking to employ minors under 16 years of age, should speak with their employment and labor attorneys. Or contact Attorney Amy Reasner or Holly Corkery.


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