Child Labor: DOL Action Needed to Better Protect Working Children

Overview

GAO found substantial gaps in federal data on working children that limit the Department of Labor’s (DOL) ability to identify and respond to dangerous conditions. An estimated 2.8 million children worked in the U.S. in 2023, and GAO’s review shows that DOL datasets on fatalities, injuries, and illnesses are incomplete or have changed in ways that prevent long-term comparisons. Since fiscal year 2015, cited child labor violations and the number of children affected have generally increased, and examples include children working later than permitted or doing hazardous work such as operating meat processing machines. DOL has launched an initiative to strengthen enforcement but faces challenges: recommended data for targeting violations may lack necessary detail, DOL lacks a process to identify/evaluate additional data sources, outreach impact is not being measured, and recent interagency collaboration did not follow leading practices. For contractors, this means elevated enforcement attention on child-labor risks in affected industries and increased scrutiny of recordkeeping, training, and workplace safety practices. Take immediate steps to inventory exposures, shore up documentation, and prepare to respond to new DOL guidance or enforcement emphasis.

Immediate Actions (This Week)

• [ ] Inventory roles and worksites where employees under 18 may be present; flag any tasks that could be hazardous (examples noted include meat processing machine operation).
• [ ] Audit personnel records for age verification, work hours, work permits (where applicable), and documentation of prohibited tasks to ensure records are complete and accessible.
• [ ] Suspend or reassign minors from tasks that could be hazardous until safety and legal eligibility are confirmed.
• [ ] Review current injury/illness reporting practices and ensure recent incidents involving minors are documented, even where public DOL data are incomplete.
• [ ] Monitor DOL communications and GAO follow-ups for guidance or enforcement changes; assign a point person to track updates.

Short-Term Actions (30 Days)

• [ ] Implement targeted training for supervisors and HR on child labor rules, hazardous-task identification, and documentation expectations; include measurement metrics for outreach effectiveness.
• [ ] Run a focused safety review of equipment, procedures, and permitting for tasks commonly cited in violations in your market segments (Food Processing, Meat Processing, Restaurant Services, Retail Food Services, Manufacturing, Agriculture).
• [ ] Establish a simple internal dashboard or log to capture age, hours worked, assigned tasks, incidents, and corrective actions for all under-18 workers.
• [ ] Develop a communications checklist to proactively inform local managers and affected suppliers about child-labor obligations and acceptable work assignments.

Long-Term Actions (90+ Days)

• [ ] Adopt a formal process to identify and evaluate additional internal and external data sources (incident logs, supplier reports, local enforcement data) that can inform targeted risk reduction and internal investigations.
• [ ] Integrate child-labor risk criteria into procurement and supplier oversight: require supplier attestations, age-verification evidence, and periodic audits for high-risk suppliers.
• [ ] Build measurable outreach assessment — e.g., pre/post training knowledge checks, incidence trends, and corrective-action closure rates — to demonstrate the effectiveness of communications and training.
• [ ] Prepare a response pack (summary of records, corrective actions, training logs, incident investigations) so you can rapidly produce audit-ready documentation if contacted by DOL.

Compliance Checklist

• [ ] Comply with the Fair Labor Standards Act provisions related to child labor (ensure permitted work hours, prohibited hazardous occupations, and age verification practices are implemented).
• [ ] Maintain OSHA Workplace Safety controls and hazard analyses that specifically address workers under 18 and tasks identified as hazardous.
• [ ] Keep complete, audit-ready documentation of age verification, work schedules, training, incident reports, and corrective actions.
• [ ] Track and measure communications and training effectiveness to address persistent knowledge gaps among employers and the public.

Resources

• Fair Labor Standards Act (statute text and DOL guidance): https://www.dol.gov/agencies/whd/flsa
• Department of Labor — Wage and Hour Division (child labor resources and guidance): https://www.dol.gov/agencies/whd/compliance-assistance/child-labor

Also see the primary hub and related guides:

• Winning Federal Contracts Guide (/insights/winning-federal-contracts)
• CMMC (Cybersecurity Maturity Model Certification) Compliance Guide (/insights/cmmc-compliance-guide)
• CUI (Controlled Unclassified Information)-Safe CRM Guide (/insights/cui-safe-crm-guide)

How Cabrillo Club Automates This

Cabrillo Signals War Room — Already detected this event and delivered this briefing within minutes. War Room continuously monitors federal reporting, GAO findings, and DOL communications so you receive alerts the moment enforcement priorities, data-collection changes, or agency initiatives affecting child labor and workplace safety are announced. For this event, War Room flagged the GAO findings, tracked the DOL initiative, and prioritized the alert as CRITICAL for affected market segments.

Cabrillo Signals Match Engine — Automatically rescans your opportunity pipeline and past-performance matches when events like this shift enforcement emphasis or market risk. Match Engine will reprioritize opportunities and alerts for solicitations and outreach where child-labor exposure or related safety controls are relevant, updating keyword relevance and agency alignment in real time so capture teams know where to focus limited resources.

Cabrillo Signals Intelligence Hub — Tracks affected agencies, NAICS codes, and contract vehicles and lets you save searches for follow-on solicitations or guidance. Configure saved searches for the market segments cited in this event (Food Processing, Meat Processing, Restaurant Services, Retail Food Services, Manufacturing, Agriculture) so you get notified when SAM.gov (System for Award Management) listings, DOL guidance, or federal interagency activity matching this profile appears.

Proposal Studio (Proposal OS) — Generates compliance matrices, first-draft technical approaches, and win themes tailored to new enforcement emphasis. For solicitations or voluntary proposals where demonstrating child-labor safeguards and OSHA-aligned safety programs is competitive, Proposal OS pulls your past performance, produces required attestation language, and outlines measurable training and recordkeeping plans.

Proposal Studio Workflow Tracker — Triggers a 9-gate capture workflow when an opportunity is rescored as higher risk or higher priority due to this event. Automatically routes compliance reviews to contracts and legal, assigns tasks for age-verification evidence collection, tracks supplier certifications, and compiles audit-ready documentation packages showing corrective actions and training results.

Explore these features in your Cabrillo Club workspace to automate monitoring, update opportunity relevance, and produce compliant proposal content and audit-ready records.

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