Child Labor: DOL Action Needed to Better Protect Working Children

TL;DR

GAO found an estimated 2.8 million children worked in the U.S. in 2023 and identified persistent data gaps that limit the Department of Labor’s (DOL) ability to identify and respond to hazardous working conditions for children. GAO’s analysis shows DOL datasets lack some publicly available detail on child workplace fatalities, injuries and illnesses; some datasets ended between 2015 and 2023; and a change in injury/illness data collection in 2021 makes trend comparisons difficult. Since fiscal year 2015, cited child labor violations and the number of children affected have generally increased through 2025. DOL has launched an initiative to enhance enforcement but faces targeting, outreach, and interagency collaboration challenges, including discontinuing an interagency task force in 2025. For contractors in food processing, retail food services, manufacturing, and agriculture markets, this means higher enforcement attention and the need to validate child-labor and workplace-safety compliance immediately. Expect agencies and compliance teams to prioritize improved recordkeeping, communications, and internal audits; contractors should treat this as a critical compliance and capture signal.

Key Points

• What happened: GAO found major data gaps in DOL’s child labor fatality, injury, and illness data, noted discontinued datasets (2015–2023), a data collection change in 2021, rising cited violations from 2015–2025, and DOL’s recent enforcement initiative with collaboration shortfalls.
• Who is affected: Market segments include Food Processing, Meat Processing, Restaurant Services, Retail Food Services, Manufacturing, and Agriculture; NAICS codes listed in segmentation: 311615, 311611, 311612, 722513, 722511, 445110, 445120, 311999, 311991, 311421, 311422, 311423; agency explicitly named: DOL.
• Timeline: GAO analyzed working-children data from 2023, child labor fatalities/injuries/illnesses since 2013, cited violations from fiscal years 2015–2025; DOL data collection changed in 2021; interagency task force discontinued in 2025.
• What contractors should do NOW: Immediately verify compliance with child labor laws and Fair Labor Standards Act requirements; run targeted internal audits of hours and task assignments for minors, especially in food/meat processing and retail food services; preserve and centralize records for potential investigations; notify capture, legal/compliance, HR/payroll, and safety teams; and configure monitoring to detect related solicitations or enforcement announcements.

Who Is Affected

• Market segments called out: Food Processing; Meat Processing; Restaurant Services; Retail Food Services; Manufacturing; Agriculture.
• Specific NAICS codes (from segmentation): 311615, 311611, 311612, 722513, 722511, 445110, 445120, 311999, 311991, 311421, 311422, 311423.
• Agency: Department of Labor (DOL).
• Contract vehicles: Specific contract vehicles pending source review.

Frequently Asked Questions

Q: Does GAO say how many children worked in 2023?

A: Yes — GAO’s analysis estimates 2.8 million children worked in the U.S. in 2023.

Q: Are child labor violations increasing?

A: GAO’s analysis shows the number of cited child labor violations and the number of children affected generally increased between fiscal years 2015 and 2025.

Q: Will this trigger immediate new contracting requirements or solicitations?

A: Pending source review — GAO identifies enforcement and data-use gaps and DOL initiatives, but the Summary does not specify new contracting actions or solicitations.

Definitions

• Child labor / working children: Refers to minors employed in work settings; GAO’s report assesses fatalities, injuries, illnesses, and cited violations affecting children under applicable child labor laws.
• Fair Labor Standards Act: The 1938 statute that included provisions to protect the safety and health of working children under age 18; GAO reviewed enforcement trends under this law.
• DOL: Department of Labor, the federal agency responsible for enforcing wage and hour and child labor laws examined in the GAO report.

Intelligence Response

• Cabrillo products to leverage for this event:
• Cabrillo Signals War Room — Already detected this event and delivered this briefing. Use it to maintain the alert and stream updates to stakeholders.
• Cabrillo Signals Match Engine — Rescore opportunity pipelines and capture priorities where child-labor enforcement risk or compliance services become differentiators.
• Cabrillo Signals Intelligence Hub — Create saved searches for DOL announcements, GAO follow-ons, and solicitations tied to the NAICS codes and market segments listed; set alerts for related SAM.gov (System for Award Management) activity.
• Proposal Studio (Proposal OS) and Proposal Studio Workflow Tracker — Use Proposal OS to generate compliance matrices referencing Fair Labor Standards Act and child labor obligations and Workflow Tracker to route audit-ready capture and compliance documentation through a 9-gate review.
• Who to notify now: Capture Manager — to assess pipeline impacts; Compliance / Legal Officer — to lead immediate audits; HR/Payroll Lead — to verify minor hour/assignment records; Safety/Plant Manager — to verify hazardous-task controls; Executive Leadership — for risk acceptance decisions.
• First 48-hour response playbook:
• Hour 0–4: Convene an incident/capture huddle; confirm War Room alert; notify Compliance, HR, Safety, Capture teams; secure minor employment records.
• Hour 4–12: Run a rapid compliance sweep on schedules, job assignments, and safety permits for minors in affected sites; log findings in Proposal Studio Workflow Tracker.
• Hour 12–24: Configure Intelligence Hub saved searches for DOL/GAO follow-ups and set Match Engine to rescore active opportunities; prepare executive brief.
• Hour 24–48: Complete initial corrective actions where violations are identified; assemble materials for potential inquiries; begin drafting outreach communications and any proposal amendments tying compliance capabilities to capture strategy.

Primary hub: Winning Federal Contracts Guide (/insights/winning-federal-contracts)

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