Child Labor: DOL Action Needed to Better Protect Working Children

Executive Summary

This GAO-reviewed DOL-focused event affects contractors across the market segments named in the Tags: Food Processing, Meat Processing, Restaurant Services, Retail Food Services, Manufacturing, and Agriculture. The report highlights a large population of working children (an estimated 2.8 million in 2023) and a general increase in cited child labor violations from fiscal year 2015 through fiscal year 2025. The Department of Labor has launched an enforcement initiative to enhance child labor law enforcement, but data gaps, discontinued data sources, and gaps in employer/public knowledge constrain targeting and outreach effectiveness.

Contractors in the listed segments should pay attention now because (1) enforcement activity and cited violations have generally increased (FY2015–FY2025), (2) DOL is attempting to strengthen enforcement and communications but faces limitations in usable data (including a 2021 change in injury/illness data collection and the ending of certain datasets between 2015 and 2023), and (3) interagency collaboration was scaled back when DOL discontinued its interagency task force in 2025. These factors increase the likelihood of inspection, citations, and reputational risk for firms that employ minors or whose supply chains include employers of minors.

Impact Matrix

Food Processing

• Risk Level: High
• Opportunity: Specific opportunities TBD pending solicitation language. Relevant NAICS codes (from Tags): 311615, 311611, 311612, 311999, 311991, 311421, 311422, 311423.
• Timeline: Ongoing. GAO analysis covers fatalities/injuries since 2013; DOL data collection on injuries/illnesses changed in 2021; cited violations trend reviewed through FY2015–FY2025; 2023 child-worker estimate is 2.8 million.
• Action Required:
• Conduct internal audits of youth employment practices and hours to ensure compliance with child labor laws and Fair Labor Standards Act provisions.
• Review hazardous-task assignments and supervision practices for minors; prioritize engineering and administrative controls where exposures exist.
• Track DOL communications/outreach and be prepared for targeted enforcement as DOL refines its initiative.
• Competitive Edge: Develop documented youth-employment compliance packages (policy, training, recordkeeping, and hazard assessments) and demonstrate measured outreach/training outcomes to reduce inspection risk and differentiate in bids.

Meat Processing

• Risk Level: Critical
• Opportunity: Specific opportunities TBD pending solicitation language. Relevant NAICS codes (from Tags): 311615, 311611, 311612, 311421, 311422, 311423, 311999.
• Timeline: Ongoing; see GAO/DOL timeframes above (including FY2015–FY2025 trend and 2021 data-collection change).
• Action Required:
• Prioritize identification of any tasks classified as hazardous for minors (examples in the report include operating meat-processing machines) and eliminate minor assignment to those tasks.
• Implement rigorous training, supervision, and machine-guarding checks for sites that employ young workers.
• Prepare for increased inspector scrutiny given the sector example in the GAO findings.
• Competitive Edge: Offer validated hazard-assessment and youth-safe-workflow solutions (third‑party audits, safety retrofits, training metrics) to employers and downstream customers to reduce compliance exposure.

Restaurant Services

• Risk Level: High
• Opportunity: Specific opportunities TBD pending solicitation language. Relevant NAICS codes (from Tags): 722513, 722511.
• Timeline: Ongoing; subject to the same GAO/DOL dates and trends noted above.
• Action Required:
• Review schedules and permissible tasks for minors to prevent violations such as working prohibited hours or performing hazardous tasks.
• Strengthen onboarding and supervisor training focused on legal limits for youth work and safe task assignment.
• Monitor DOL outreach and be prepared to show evidence of corrective communications/training.
• Competitive Edge: Build youth-focused compliance toolkits and training modules that employers can deploy and measure, supporting proof of proactive compliance under DOL scrutiny.

Retail Food Services

• Risk Level: Medium
• Opportunity: Specific opportunities TBD pending solicitation language. Relevant NAICS codes (from Tags): 445110, 445120.
• Timeline: Ongoing; see GAO/DOL timelines above.
• Action Required:
• Audit youth job duties (e.g., equipment use, stocking) and hours to align with child labor rules.
• Implement role-based restrictions and supervisor checklists to demonstrate due diligence.
• Competitive Edge: Provide audit-as-a-service or compliance-dashboard offerings that retail operators can use to continuously monitor youth employment risk and produce records for inspectors.

Manufacturing

• Risk Level: High
• Opportunity: Specific opportunities TBD pending solicitation language. Relevant NAICS codes (from Tags): 311999, 311991 and other manufacturing-related codes in Tags.
• Timeline: Ongoing; FY2013–present dataset review and FY2015–FY2025 violation trends are relevant.
• Action Required:
• Reassess minor exposure to manufacturing hazards; restrict minors from hazardous operations and document protective measures.
• Strengthen recordkeeping and incident-reporting practices to close the DOL-identified information gaps where possible.
• Competitive Edge: Offer integrated compliance + safety engineering packages that combine task reassignment strategies with measurable training and monitoring for employers of minors.

Agriculture

• Risk Level: High
• Opportunity: Specific opportunities TBD pending solicitation language. Relevant NAICS codes (from Tags): Specific NAICS codes for agriculture are TBD pending source review.
• Timeline: Ongoing; GAO analysis timeframe and DOL actions apply.
• Action Required:
• Review any use of minors in agricultural operations for hazardous-task exposure and compliance with child labor statutes.
• Strengthen outreach and education to supervisors and seasonal hiring teams about restrictions and safe work planning for younger workers.
• Competitive Edge: Develop seasonal-hire compliance programs with measurable outreach and training outcomes that can be shared with regulators and customers.

Cross-Segment Implications

• Enforcement and outreach actions targeting child labor can produce cross-cutting inspection risk across food processing, meat processing, restaurants, retail food, manufacturing, and agriculture—especially where supply chains link these segments.
• Data gaps and changes in DOL data collection mean that DOL may rely more on targeted investigations, complaint referrals, and visible enforcement examples (e.g., hazardous tasks in meat processing) to shape enforcement priorities; contractors in multiple segments should harmonize compliance practices to reduce cascading supplier risk.
• Measurement and documentation of outreach/training effectiveness (requested by GAO as lacking in DOL assessments) will likely become a differentiator; firms that can show measured compliance outcomes across operations and suppliers reduce exposure and can better respond to investigations.