Washington State Increases Work Hours for 16- & 17-Year-Olds During School Weeks

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Peter Nakonechni

January 8, 2026

Through House Bill 1121 (“HB 1121”), Washington state has revised its child-labor laws to allow 16- and 17-year-olds who are enrolled in certain bona fide college programs or approved career and technical education (“CTE”) to work the same amount and frequency of hours during school weeks that they are permitted to work during non-school weeks.  HB 1121 becomes effective July 1, 2026

Overview
On April 21, 2025, Washington Governor Bob Ferguson signed HB 1121 into law.  HB 1121 requires the Washington Department of Labor and Industries (“L&I”) to revise the regulations to reflect that 16- and 17-year-olds enrolled in qualified programs can now work the same hours and days during school weeks as they could work during vacations and non-school weeks, subject to approval of such programs and approval of employers hosting CTE students.

Benefits to Student Employees
HB 1121 will provide several benefits to 16- and 17-year-old students in CTE and college programs.  Students now have the opportunity to increase their income and utilize more flexible scheduling between work and school, which could help reduce any financial stress they may be facing.  It better aligns formal education programs with actual work experience, which strengthens skill development and increases employability of students.  Students enrolled in approved CTE placements can now receive consistent work hours with their employer that may open pathways to employment post-graduation.

Benefits to Employers of Students
HB 1121 provides employers participating in approved student work-based programs with access to a more reliable pipeline of trained student workers.  Employers can now consistently schedule work hours for their student employees during the school week, which eases staffing issues during critical time periods and will help demonstrate a reliable return on the employer’s investment into training programs.  HB 1121 may also streamline participating employers’ hiring processes for interns and entry-level employees because their new hires will already be familiar with the employer’s business practices.

Potential Negatives for Student Employees
While HB 1121 allows student workers to potentially earn more income during school weeks with increased work hours, it can also negatively impact their academic performance.  For example, working more hours during school weeks increases the likelihood that students will become overworked, resulting in issues with concentration during classes, school attendance, and grades.

Further, certain work environments require employees to engage in potentially dangerous tasks.  By increasing the hours that a student worker spends in these environments, the student’s exposure to such dangerous tasks also increases.  Finally, HB 1121 applies only to students participating in qualified work programs—it does not afford the same opportunity to other employed students who may need the additional income provided by the increase in work hours.

Potential Negatives for Employers
Participating employers will now have to implement new policies to guarantee that they are compliant with HB 1121.  Employers must abide by L&I’s new rules and meet the administrative hurdles to become an “approved” employer for CTE placements, which may increase overhead costs for employers.  Providing student workers with additional work hours will require employers to invest in training for their supervisors and their student workers to ensure adherence to the amended child-labor laws and occupational safety standards and confirm that adequate safety protections for students are in place and strictly enforced.  Otherwise, an employer could be subject to penalties or enforcement action.

Key Takeaways

For Employers:

• Employers should maintain sufficient records and documentation regarding their participation in qualifying student-work programs, including work permits, proper authorizations (by parents and/or schools), and training records.
• Prior to hiring a student under HB 1121, employers should first confirm that the student has been approved to participate in a qualified work program.
• Employers should prepare job descriptions for their student workers that limit participation in and performance of dangerous job tasks, and make efforts to assign their student workers to non-dangerous duties or provide enhanced supervision of students performing dangerous tasks.

For Schools and Program Administrators:

• Schools and program administrators should collaborate with participating employers to implement scheduling rules for student workers to prevent interference with students’ academics and to protect students from becoming overworked.
• Both employers and schools/program administrators should periodically monitor student workers to prioritize the students’ well-being and make sure students’ academic performance is not suffering due to the increased work hours.

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.