As teen employment rates continue to rise in Washington, so do youth labor violations

Editor’s note: This article is being republished with permission from InvestigateWest and Cascade PBS .

Jasmine Brennan started her first job a few months after turning 16. Like most high school students who work, Brennan found a position in food service, taking orders behind the counter at a Jack in the Box in Ferndale.

Brennan said her boss, rarely around, never provided formal training. Instead, she relied on a friend for instruction.

“I was very lost. I have no clue. But it was fun, because obviously I’m a kid and I was having fun with not really working, but working,” Brennan told Cascade PBS.

Brennan’s boss then began scheduling her for late shifts the night before she had class or asking her to work during school hours, all later ruled violations of state youth labor laws. For Brennan, closing the restaurant at the end of a night wasn’t hard, but the late hours meant less sleep if she had to be at school by 7:45 a.m. the next day.

“When I had to be there later than 12:30 a.m., I would be mad or annoyed,” she said. “I have stuff to do tomorrow. I’m gonna have to open tomorrow, or I’m gonna have to go to school.”

“They constantly made them work late on Sundays, which would fall into early morning,” her mom Lindsey Brennan added, “which then did probably mess with school a little bit — you’re exhausted.”

As youth employment has risen in Washington over the past decade, so has the number of citations for violating youth labor laws. Teenagers get overworked or kept too late on school nights. Some are asked to do dangerous or prohibited tasks. According to Washington’s Department of Labor & Industries, the state agency that oversees working conditions, 750 workers under 18 reported on-the-job injuries in the state last year.

Many of these young workers serve food from behind a counter or scan items through a check-out lane. Some pick fruits and vegetables in fields. Most are eager to please or do not want to call attention to their inexperience.

Brennan said she would text her boss when she was scheduled at times that weren’t allowed.

Nothing changed, so she eventually filed a complaint with L&I. During the three-month investigation period, the agency found that this Jack in the Box in the state’s Northwest corner had violated youth labor laws 149 times for working minors too many hours in a day, too late on a school night and without adult supervision.

Brennan knew that the company had broken labor laws only because her dad, who worked construction, was familiar with L&I.

After five months, Brennan’s parents forced her to quit. Her dad had spent hours keeping watch from the parking lot during a late shift as Brennan and another 16-year-old friend served the last customers and closed the store without any adult supervision, as required by law.

“[Her boss] had no idea what they were allowed to do or what not to do,” Lindsey Brennan said. “If she hadn’t vented to us, she probably would have just continued to get abused.”

Growing workforce

Youth employment in Washington grew 46% among 16-19-year-olds over the past decade. The latest figures from the Bureau of Labor Statistics show that 137,000 youth, about a third of all Washington residents in that age group, held jobs in 2023.

Reid Maki, a director of child labor issues and coordinator of the Child Labor Coalition , said the tight labor market likely incentivizes businesses to hire minors.

“Teens are more likely to work for a little bit less money,” Maki noted.

State laws regulate how many hours 14-17-year-olds can work when school is in session, how late they can work on a school night and which jobs and tasks are prohibited – for example, excavating sites, roofing or operating a meat slicer. (In agricultural jobs, children as young as 12 can harvest vegetables and fruits when school is not in session.)

Youth workers are more vulnerable than adults, Maki said. They often aim to please and, because of brain development, have a limited capacity to assess risk.

“Just because of their life experience, they just don’t really have a concept of what could go wrong,” he added.

L&I records show that the number of complaints the agency investigates each year has more than doubled between 2014 and 2022, as has the number of citations issued each year during that time period.

“Because we’re a complaint-driven process, it may be fair to say there are more people watching,” L&I spokesperson Matthew Elrich said. “That might be the reason we’re getting more complaints that lead to investigations.”

A Cascade PBS analysis of L&I data from 2014 to 2022 found that nearly all child labor complaints to L&I resulted in a citation. In 2022, L&I conducted investigations into 122 complaints, issuing citations – many for multiple violations – in 119 of those cases. Most violations also came with a monetary fine.

Maki said the high rate of investigations resulting in citations suggests many unrecognized violations may go unreported.

“The number of violations we’re seeing, which are alarming — but they’re just the tip,” Maki said. “I think there’s a huge number of violations happening out there.”

More than a third of violations involved minors working too many hours, too late on a school night or when they were supposed to be in school, the data shows. The second-largest category of violations, 17%, resulted from workers missing meal or rest breaks. Violations for performing prohibitive tasks ranked fourth on the list of most common violations.

In the past decade, the largest single L&I citation for violating youth labor laws went to a Jack in the Box. The $69,500 fine issued in 2020 was one of at least 18 monetary penalties – totaling nearly $200,000 – issued to Jack in the Box franchises in that time period.

L&I issued Brennan’s store in Ferndale a $12,450 fine after the agency cited the company 146 times for working four minors during school hours 48 times, working six minors more hours than allowed on a school day 39 times and working three minors past 8 p.m. without adult supervision.

Multiple phone, email and text messages sent to the Pars Group, which operates Jack in the Box locations in the state including the one in Ferndale, were not returned.

Nearly half of all youth labor citations issued by the state over the past decade went to the food service industry, according to L&I data. Workers in that sector also file the most compensation claims among minors.

L&I research from the early 1990s found young workers are nearly twice as likely to get hurt on the job than their older counterparts. Using census data and adjusting for the number of hours worked, researchers calculated the injury rate for 16- and 17-year-olds to be 19.4 per 100 employees, compared with 10.6 per 100 for adults.

Twice as likely to get hurt

In 2019, a minor died due to an injury sustained at a worksite, according to L&I worker’s compensation data. Last year, a 16-year-old lost both legs operating a machine on the do-not-use list for minors. L&I reported that in 2023, underage workers also suffered 245 fractures, 225 concussions and numerous cuts or sprains.

Matt Pomerinke said he was working his first job out of high school at a papermill when he got pulled into a machine, losing much of his right arm at 21.

“Dumb luck. That was our entire safety program,” Pomerinke said two decades later, addressing an auditorium filled mostly with teenage boys wearing hoodies and baseball caps.

Pomerinke was speaking at the New Market Skills Center in Tumwater as part of L&I’s Injured Young Workers Speakers Program , a workplace safety awareness campaign running in the weeks before the school year ended.

In just a short time at the mill, Pomerinke watched co-worker after co-worker get hurt – a broken finger and a wrist, pulled muscles, a torn rotator cup.

He received very little training at his first job, he told the crowd. He got a 10-minute tour of the sawmill followed by five minutes on how to pull wooden boards off a conveyor belt and stack them, he recalled.

“Nobody ever taught you anything there. Nobody showed you anything,” Pomerinke said. “There was nobody there to ask. Not that I probably would have at that point my career. I just wanted to do everything myself.”

One night, when a stick got caught in his sawdust conveyor, Pomerinke reached in to dislodge it, something he had done a hundred times.

“After two years, my luck ran out,” he said. “I got hurt the worst out of everybody.”

It took 45 minutes for emergency responders to extract him from the machine.

Before the school bell rang, Pomerinke shared his parting advice.

“Don’t take a shortcut. … It’s not worth it,” he said. “Get all the training you can and take it seriously.”

And learn your rights and responsibilities as a worker.

“Things that employers can and cannot ask you to do,” he said, before gesturing toward his missing right forearm and hand. “Things I never knew about that ultimately led to this.”

InvestigateWest ( invw.org ) is an independent news nonprofit dedicated to investigative journalism in the Pacific Northwest. Visit invw.org/newsletters to sign up for weekly updates.