Update Applicable to:	Effective Date
All Washington Employers with Nonagricultural Jobs	July 1, 2026

What happened?

On April 21, 2025, Washington enacted House Bill 1121 (Chapter 79, Laws of 2025), adding a new section to RCW 49.12 (Industrial Welfare Act). Washington’s Industrial Welfare Act declares that employees must be protected from labor conditions harmful to their health and authorizes the Department of Labor & Industries (L&I) to investigate wages, hours, and working conditions and adopt rules setting minimum standards.

Overview

Why this matters: For Washington employers, this new law directs the Department of Labor & Industries (L&I) to allow 16–17‑year‑olds enrolled in approved Career & Technical Education (CTE) programs work the same hours during school weeks as they can in non‑school weeks—but only when the job is with an employer approved by the CTE program, giving employers added scheduling flexibility for qualified minors in those placements.

Action Steps for Compliance

• Confirm coverage and timing: Check if the role qualifies: Verify the minor is enrolled in a Career & Technical Education (CTE) program and that your company is an employer approved by the CTE program (this is what unlocks the “non‑school week” hours during school weeks). Keep written proof from the school/CTE office in the personnel file.
  
• Complete and refresh required authorizations: Ensure you have a current Minor Work Permit endorsement on your Washington business license (post it and renew annually). Parent/School Authorization: Before work starts (and each school year), obtain a Parent/School Authorization Form; use the summer authorization during school breaks. File copies for audit.
  
• Update scheduling rules for CTE students: Apply the new flexibility correctly: For 16–17‑year‑olds in approved CTE placements, L&I must allow scheduling up to “non‑school week” hours even during school weeks (i.e., the same maximum hours/days you would allow during school vacations), without changing other restrictions.

• Keep all other youth‑employment rules intact: Confirm job duties don’t fall into prohibited/ hazardous occupations and provide age‑appropriate training and supervision. (Washington’s child‑labor rules continue to apply.)

• Strengthen documentation & controls: CTE eligibility file: Keep copies of (1) student’s CTE enrollment confirmation; (2) program’s employer approval; (3) any variance letters; (4) Parent/School Authorizations; (5) proof of age; (6) job description and schedule grid.
  
• Coordinate with schools and L&I: Assign a HR/Compliance point‑person to coordinate with the CTE director on employer approval, work‑site learning plans, and any L&I consultations/variances. Align your youth‑employment policy with L&I’s “How to Hire Minors” guidance and your school partner’s program rules; retain all correspondence for audits.

• Train managers now: Train schedulers that only CTE‑approved 16–17‑year‑olds may use the non‑school week hours during school weeks starting July 1, 2026; all other minors remain on standard limits.

• Audit and adjust: Pre‑launch audit (June 2026): Run a file audit for every minor worker to confirm permits, authorizations, CTE documentation, and schedule rules ahead of go‑live. Review minor schedules, timesheets, and duty assignments for compliance; remediate quickly.

Additional Information

Highlights (with section references)

• Legislative intent: Ensures equity between students in bona fide college programs (e.g., Running Start) and those in career and technical education (CTE) by directing L&I to revise rules so both groups can work school week hours/days equal to non-school weeks (§1).

• College pathway: A 16–17‑year‑old enrolled in a bona fide college program may work the same hours and days during the school year as in vacations/holidays. No employer approval is required (§2(1)(a)).

• CTE pathway: A 16–17‑year‑old enrolled in a CTE program may work the same hours and days during the school year if the work is performed for an employer approved by the program (§2(1)(b)).

• Definition: A CTE program is a work-based learning program approved by OSPI or the student’s school district, including Core Plus (§2(2)).

• Effective date: July 1, 2026 (§3).

Source References

• Washington HB 1121 – Concerning restrictions on the working conditions and hours of sixteen- and seventeen-year-olds
• Washington Governor – Press Release

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