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January 6, 2026
Washington state has made key amendments to its child-labor laws through House Bill 1644 (“HB 1644”), which is effective July 1, 2026.
Youth employment in Washington state has increased in recent years, and with it, there has been an increase in violations of child-labor laws and worksite injuries of minors. To ensure a safe working environment for minors and to prevent employer exploitation of minors, the Washington legislature passed HB 1644. Washington’s previous version of its child-labor laws had a very low penalty structure for violators, which has now been updated and increased with the aim of reducing repeat offenses by bad-actor employers.
HB 1644 was signed into law by Governor Bob Ferguson on April 28, 2025. HB 1644 strengthens Washington’s enforcement tools and penalties around youth employment; it brings agriculture into parity with non-agriculture rules; and it creates additional safeguards around variances that allow minors to perform otherwise prohibited work. These changes should improve safety for minors while also increasing compliance costs and risk for employers, which may reduce some youth employment or delay training placements unless employers proactively adapt their safety and permitting practices.
For instance, HB 1644 creates statutory minimum civil penalties for employers’ violations of child-labor laws. These penalties include: $100 for non-serious paperwork-type violations; $150 for hours violations; $300 for meal- or rest-break violations; $1,000 for prohibited duty, variance, minimum wage, and other serious violations; and $71,000 for any violation that results in serious physical harm or death to a minor, which can double for an employers’ willful or repeated violations. Beginning July 1, 2027, these penalty amounts will be adjusted every two years for inflation. The Washington Department of Labor and Industries (“L&I”) has discretion to waive or reduce penalties for first-time, non-serious violations, so long as the employer corrects the violations.
If a business receives any combination of three or more certain serious, willful, or repeat safety citations or child-labor citations within a 24-month period, L&I is required to revoke the business’s minor work permit for at least 12 months. A business can also have its minor work permit revoked for a single violation that resulted in serious physical harm or death. Contractors with a revoked minor work permit are prohibited from bidding on public works projects.
HB 1644 also extends enforcement to the agricultural industry, applying the same procedures and penalties as non-agricultural industries with modifications to specifically cover serious agricultural violations.
HB 1644’s significantly increased penalties for violations create a stronger incentive for employers to avoid exposing minor employees to hazardous conditions, which should reduce riskier assignments and improve safety oversight of those employees.
HB 1644 now provides better oversight of variance training programs. Before L&I can grant a variance allowing minors to do otherwise-prohibited tasks (e.g., certain hazardous tasks under a supervised learning program), HB 1644 requires L&I to conduct a mandatory safety/health consultation at the worksite and consult with the employer about the tools, equipment, and practices permitted under the variance. This process should reduce the chance that a minor employee is assigned to perform dangerous tasks.
There are now more consistent protections across industries, including agriculture, where minors have sometimes been less protected in the past. Serious agricultural violations may now result in criminal penalties.
HB 1644 creates clearer rules and a predictable penalty schedule to guide employers. The minimum penalty schedules and inflation adjustments provide employers with more clarity about consequences and permit predictable budgeting for compliance costs.
HB 1644 affords employers the opportunity to avoid penalties if they promptly correct their actions. Specifically, it allows abatement of such actions and provides waivers or penalty reductions for first-time, non-serious violations when quickly corrected, with the goal of encouraging employers’ voluntary fixes.
Employers and contractors that maintain strong safety programs for their minor employees can gain a competitive advantage, especially in the public-bidding process where L&I is required to revoke permits and disqualify repeat/serious violators from bidding.
HB 1644’s amendments can potentially reduce work and training opportunities for minors. For example, the higher financial and licensing risk could deter some employers, especially small businesses, from hiring minors or offering student-learner variances, which could decrease a minor’s access to entry-level jobs or hands-on training. Further, the mandatory on-site safety consultations may lead to delays in L&I’s variance approval process.
The new penalty schedule for violators—which includes mandatory minimum penalties and large penalties for violations causing serious harm or death—significantly increases an employer’s financial exposure. Whereas the prior maximum penalty for most violations was $1,000, the new schedule provides increased fines that can double for willful or repeat violations, daily penalties of up to $10,000 per day for persisting serious violations, and adjustments for inflation every two years.
HB 1644 can also increase an employer’s operational and administrative costs. For example, employers of minors are now subject to increased compliance costs due to more inspections, pre-variance consultations, and recordkeeping requirements, while also running the risk of permit revocation and bans on public-works bidding for non-compliance. This means an increase in costs for compliant safety systems, training for minors, and a potential increase in insurance costs.
Employers may also face reputational and revenue consequences if they end up having their minor work permits revoked or they are banned from the public-bidding processes. It is likely that small businesses will be disproportionately affected by HB 1644’s changes.
Prior to applying or accepting a job, minors (and their parents/guardians) should confirm that potential employers have a valid minor work permit and proper authorizations in place.
Observers, including minor workers, their parents/guardians, and their co-workers, are encouraged to report an employer’s unsafe working conditions or practices to L&I. Reporting such instances will help to protect all minors in the workforce.
Washington employers should immediately:
Employers’ proactive action will ensure compliance with HB 1644 ahead of its July 1, 2026 effective date. Once HB 1644 is enacted, employers should strive to engage with L&I early if they anticipate applying for a student-learner variance and effectively budget for the mandatory on-site safety consultations. Finally, employers should implement policies that prioritize prompt corrective action in the event they receive citations for any violations of the new law.
The author of this article, Peter Nakonechni, is a member of the Bars of Pennsylvania and New Jersey. This article is designed to provide one perspective regarding recent legal developments, and is not intended to serve as legal advice in Pennsylvania, New Jersey, Washington, or any other jurisdiction, nor does it establish an attorney-client relationship with any reader of the article where one does not exist. Always consult an attorney with specific legal issues.
