WORKING 

CHILDREN

Federal Injury Data 

and Compliance 

Strategies Could Be 

Strengthened 

Report to Congressional Requesters

November 2018

GAO-19-26

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-19-26, a report to 

congressional requesters

November 2018

WORKING CHILDREN

Federal Injury Data and Compliance Strategies Could 

Be Strengthened

What GAO Found

The number of working children has fluctuated with the economy since 2003. An 

estimated 3.3 million children aged 15 to 17 worked in the summer months of 

2003, and the number of working children reached a low of 1.9 million by 2011. It

then increased to 2.5 million by 2017, but has not returned to its pre-recession 

level, as shown below. GAO’s analysis of the U.S. Department of Commerce and 

the Department of Labor’s (DOL) Current Population Survey data found that nonagricultural industries employed an estimated 2.5 million working children aged 

15 to 17 in the summer months of 2017. Further, GAO found that the leisure and 

hospitality industry employed the largest number of children.

Estimated Number of Working Children Aged 15 to 17 in the United States, 2003 to 2017

Since 2003, the majority of work-related child fatalities were in agriculture, and 

while available data are incomplete, they indicate that work-related injuries have 

declined. Although agriculture employs a small percentage of working children,

DOL data indicate that from 2003 to 2016, the year for which the most recent 

data are available, over half of the 452 work-related fatalities among children

were in agriculture. Also, according to DOL estimates, the number of workrelated injuries and illnesses to children has declined, but these estimates do not 

include certain populations. While DOL is conducting a pilot study to enhance its 

work-related injury and illness data, this pilot does not include children, including 

those 14 or under. DOL has not evaluated the feasibility of measuring this 

population. As a result, DOL is missing opportunities to more accurately quantify 

injuries to children, which could better inform its compliance and enforcement 

efforts.

DOL’s Wage and Hour Division (WHD) uses a strategic enforcement approach to 

oversee compliance with the child labor provisions of the Fair Labor Standards 

Act and collaborates within DOL to exchange information on potential violations. 

WHD officials told GAO that their enforcement and compliance efforts include 

outreach to industries with vulnerable workers, including children. However, 

WHD has not developed metrics for child labor-related outreach in agriculture. 

Federal internal control standards state that management should define 

objectives clearly to enable the identification of risks, such as by defining 

objectives in measurable terms. Without such metrics, WHD may not be 

effectively addressing the risks faced by children working in agriculture.

View GAO-19-26. For more information, 

contact Cindy Brown Barnes at (202) 512-

7215 or brownbarnesc@gao.gov, or Steve 

Morris at (202) 512-3841 or morriss@gao.gov.

Why GAO Did This Study

Children aged 17 and under in the 

United States work for various 

reasons: some are encouraged to work 

to develop independence and 

responsibility; others work because of 

financial need. At the same time, 

research suggests working children are

at risk for work-related injuries and 

fatalities. GAO was asked to update its 

2002 child labor report to discuss the 

current status of working children in the 

United States, including those working 

in agriculture. 

This report examines (1) children

working in the United States since 

2003, (2) work-related fatalities and 

injuries to such children for the period, 

and (3) how DOL oversees compliance 

with the child labor provisions of the 

Fair Labor Standards Act. GAO 

analyzed federal data from several 

sources, including DOL and other 

agencies; reviewed relevant federal 

laws and regulations; and interviewed 

officials from DOL, including staff in six 

WHD district offices that were selected 

based on factors such as 

investigations with at least one child 

labor violation, and all five regional 

offices. GAO also spoke with

stakeholders knowledgeable about 

child labor, such as employer and 

employee labor groups.

What GAO Recommends

GAO is making four recommendations 

to DOL, including that DOL should 

evaluate the feasibility of measuring

injuries and illnesses to certain worker 

populations, and establish metrics for 

child labor-related outreach in 

agriculture. DOL generally agreed with 

all four recommendations.
Page i GAO-19-26 Working Children

Letter 1

Background 5

The Number of Working Children Generally Fluctuated with the 

Economy 18

Children Working in Agriculture Comprised the Majority of WorkRelated Child Fatalities, and Data on Work-Related Injuries Are 

Incomplete 26

DOL Uses a Strategic Enforcement Approach to Oversee 

Compliance with Federal Child Labor Law, but Some 

Limitations Exist 39

Conclusions 49

Recommendations for Executive Action 50

Agency Comments and Our Evaluation 51

Appendix I Objectives, Scope, and Methodology 54

Appendix II Detailed Information on Children in the United States Who Worked in 

Summer and Non-Summer Months 71

Appendix III Demographic Characteristics of Children in the United States Who 

Worked in Summer and Non-Summer Months 76

Appendix IV Detailed Information on Occupations in Which Children Aged 15 to 17 

Worked, 2016 80

Appendix V Detailed Information on Hired Child Crop Workers in the 

United States 82

Appendix VI Detailed Information on Children in the United States Who Work on 

Farms 87

Contents
Page ii GAO-19-26 Working Children

Appendix VII Information on Work-Related Child Fatalities by Industry, 2003 

to 2016 89

Appendix VIII Selected Demographic Characteristics of Work-Related Fatalities, 

Children Aged 17 and Under, 2003 to 2016 91

Appendix IX Estimated Work-Related Injuries and Illnesses to Children Aged 

17 and Under, 15 and Under, and 14 and Under 93

Appendix X Estimated Work-Related Injuries and Illnesses to Children Aged 

17 and Under, by Industry, 2003 and 2016 95

Appendix XI Comments from the Department of Labor’s Occupational Safety and 

Health Administration 97

Appendix XII Comments from the Department of Labor’s Wage and Hour Division 98

Appendix XIII GAO Contacts and Staff Acknowledgments 100

Tables

Table 1: Child Labor Provisions for Non-Agricultural Employment 6

Table 2: Non-Agricultural Hazardous Occupations Orders 7

Table 3: Agricultural Hazardous Occupations Orders 9

Table 4: Child Labor Provisions for Agricultural Employment 10

Table 5: Percentage of Work-Related Child Fatalities from 2003 to 

2016 Compared to Estimated Percentage of Children 

Working in Selected Categories, 2017 (Categories Are 

Not Mutually Exclusive) 27

Table 6: Number and Percentage of Work-Related Child Fatalities, 

by Age, 2003 to 2016 30
Page iii GAO-19-26 Working Children

Table 7: National Estimates of Work-Related Injuries to Children 

Aged 17 and under on U.S. Farms, by Age Group 35

Table 8: National Estimates of Work-Related Injuries to Household 

and Non-Household Children Aged 17 or under on U.S. 

Farms 36

Table 9: Data Sources Used in GAO Analyses for Objective I 54

Table 10: GAO Analysis of Selected Current Population Survey 

(CPS) Data Variables, 2003 to 2017 57

Table 11: Crosswalk of Census Bureau Industry Codes Used in 

GAO Analyses 59

Table 12: Selected National Agricultural Worker Survey (NAWS) 

Data Variables Used in GAO Analyses 62

Table 13: Data Sources Used in GAO Analyses of Work-Related 

Fatalities and Injuries and Illnesses to Children in 

Objective II 64

Table 14: Estimated Number of Children Who Worked in an 

Average Summer Month, by Age, 2003 to 2017 71

Table 15: Estimated Number of Children Who Worked in an 

Average Non-Summer Month, by Age, 2003 to 2017 71

Table 16: Estimated Number and Percentage of Children 

Employed during Summer Months and Non-Summer 

Months, by Age, 2003 and 2017 72

Table 17: Estimated Hours Worked by Working Children Aged 15 

to 17 Who Worked in Non-Agricultural Industries, 2003 to 

2017 73

Table 18: Estimated Hours Worked by Children Aged 15 Who 

Worked in Non-Agricultural Industries, 2003 to 2017, by 

Hours per Week 73

Table 19: Estimated Number of Children Aged 15 to 17 Working in 

Agricultural Industries, Summer and Non-Summer 

Months, 2003 to 2017 74

Table 20: Estimated Number of Children Aged 15 to 17 Who 

Worked in an Average Summer Month, by Gender, 2003 

to 2017 76

Table 21: Estimated Number of Children Who Worked in an 

Average Non-Summer Month, by Gender, 2003 to 2017 76

Table 22: Estimated Number of Children Aged 15 to 17 Who 

Worked in an Average Summer Month, by Race and 

Ethnicity, 2003 to 2017 78

Table 23: Estimated Number of Children Aged 15 to 17 Who 

Worked in an Average Non-Summer Month, by Race and 

Ethnicity, 2003 to 2017 78
Page iv GAO-19-26 Working Children

Table 24: Occupations in Which Children Aged 15 to 17 Were 

Estimated to Have Worked, 2016 80

Table 25: Age Hired Crop Workers First Worked in U.S. 

Agriculture, by Estimated Percentage, Fiscal Years 2003 

to 2016 82

Table 26: Estimated Percentage of Hired Crop Workers Aged 17 

and Under by Gender, Fiscal Years 2005 to 2016 83

Table 27: Estimated Percentage of Hired Crop Workers Aged 17 

and Under by Race and Ethnicity, Fiscal Years 2005 to 

2016 83

Table 28: Estimated Percentage of Hired Crop Workers Aged 17 

and Under From Families Below the Poverty Level, Fiscal 

Years 2005 to 2016 84

Table 29: Trends in Estimated Mean Working Days for Hired Crop 

Workers Aged 14 to 17 Working on U.S. Farms, by Age 

and Year Grouping 85

Table 30: Estimated Percentage of Hired Crop Workers Aged 17 

and Under by Documentation Status, Fiscal Years 2013 

to 2016 85

Table 31: Estimated Percentage of Hired Crop Workers Aged 17 

and Under by Region, Fiscal Years 2005 to 2016 86

Table 32: National Estimates of Children Working on U.S. Farms 

by Type of Farm, Type of Worker and Age, 2004, 2006, 

2009, 2012, 2014 87

Table 33: Number of Work-Related Child Fatalities, by Detailed 

Industry, 2003 to 2016 89

Table 34: Number and Percentage of Work-Related Child 

Fatalities, by Race and Ethnicity, 2003 to 2016 91

Table 35: Causes of Work-Related Child Fatalities, 2012 to 2016 92

Table 36: Estimated Work-Related Injuries and Illnesses to 

Children Aged 17 and Under, Aged 15 and Under, and 

Aged 14 and Under, 2003 to 2016 93

Table 37: Estimated Number of Work-Related Injuries and 

Illnesses to Children Aged 17 and Under, 2003 and 2016 95

Figures

Figure 1: Estimated Number of Working Children Aged 15 to 17 in 

the United States, 2003 to 2017 19

Figure 2: Industries in Which Children Aged 15 to 17 Worked, 

2016 22
Page v GAO-19-26 Working Children

Figure 3: Selected Federal Data on Children Working in 

Agriculture 25

Figure 4: Number of Work-Related Fatalities to Children Aged 17 

and Under and Estimated Number of Hours Worked by 

Children Aged 15 to 17, 2003 to 2016 26

Figure 5: Work-Related Child Fatalities, by Industry, 2003 to 2016 29

Figure 6: Estimated Number of Work-Related Injuries and 

Illnesses to Children Aged 17 and Under (National 

Institute for Occupational Safety and Health) and Aged 

15 to 17 (Bureau of Labor Statistics), 2003 to 2016 33

Figure 7: Wage and Hour Division (WHD) Investigation and Child 

Labor Violation Trends, Fiscal Years 2010 to 2016 41

Figure 8: Wage and Hour Division Investigations That Found a 

Child Labor Violation, by Industry, Fiscal Years 2010 to 

2016 42

Figure 9: Number of Investigations That Found Child Labor 

Violations across All Industries, by Type, Fiscal Years 

2010 to 2016 43
Page vi GAO-19-26 Working Children

Abbreviations

ASEC Annual Social and Economic Supplement

BLS Bureau of Labor Statistics

CAIS Childhood Agricultural Injury Survey

CFOI Census of Fatal Occupational Injuries

CPS Current Population Survey

DOL U.S. Department of Labor

ETA Employment and Training Administration

FLSA Fair Labor Standards Act of 1938, as amended

NASS National Agricultural Statistics Service

NAWS National Agricultural Workers Survey

NEISS-Work National Electronic Injury Surveillance SystemOccupational Supplement

NIOSH National Institute for Occupational Safety and Health

OSHA Occupational Safety and Health Administration

OSH Act Occupational Safety and Health Act of 1970, as amended

SOII Survey of Occupational Injuries and Illnesses

USDA U.S. Department of Agriculture

WHD Wage and Hour Division

WHISARD Wage and Hour Investigative Support and Reporting

Database

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Page 1 GAO-19-26 Working Children

441 G St. N.W.

Washington, DC 20548

November 2, 2018

The Honorable Rosa DeLauro 

Ranking Member 

Subcommittee on Labor, Health and Human Services, Education, and

 Related Agencies 

Committee on Appropriations 

House of Representatives

The Honorable Lucille Roybal-Allard

House of Representatives

Children in the United States are often encouraged to work because early 

work experiences are thought to develop independence and 

responsibility; some children may also work because of financial need. At 

the same time, federal research suggests that working children are at risk 

for work-related injuries or fatalities.1 Working children (aged 17 and 

under) are afforded certain protections, such as prohibitions on working in 

certain hazardous occupations,2 under the child labor provisions of the 

Fair Labor Standards Act of 1938, as amended (FLSA) and regulations 

issued by the Department of Labor (DOL)3

—the federal agency generally 

responsible for enforcing the FLSA.4 In 2002, we reported that DOL could 

 1

Department of Health and Human Services, Centers for Disease Control and Prevention, 

National Institute for Occupational Safety and Health, Young Worker Injury Deaths: A 

Historical Summary of Surveillance and Investigative Findings, Publication No. 2017-168 

(Morgantown, WV: July 2017). 

2

These protections include age-based limitations on the number of hours and times of day 

children can work and minimum ages below which children cannot work. Minimum ages 

for working children vary, as discussed later in the report. Agricultural employers are 

subject to separate child labor provisions under the Fair Labor Standards Act of 1938, as 

amended, including different age limits and occupational restrictions.

3

Pub. L. No. 75-718, 52 Stat. 1060 (codified as amended at 29 U.S.C. §§ 201-219); 29 

C.F.R. pt. 570. In addition to the child labor provisions, the FLSA also requires covered 

employers to comply with certain minimum wage and overtime requirements. 

4

Other federal laws, administered by other agencies, may also apply to working children. 

For example, under the Federal Insecticide, Fungicide, and Rodenticide Act, the 

Environmental Protection Agency has implemented measures to protect workers from 

pesticide exposure through its Worker Protection Standard, which, among other things, 

establishes a minimum age of 18 for workers engaged in certain pesticide-related tasks. 

For purposes of this report, we focus on the child labor provisions under the FLSA and its 

implementing regulations, and exclude from our scope any requirements under other laws 

and regulations. 

Letter
Page 2 GAO-19-26 Working Children

strengthen its efforts to protect children who work across all industries—

particularly those with high rates of injuries—and strengthen its data 

collection for enforcement planning.5

You asked us to update our 2002 report to describe the current status of 

working children in the United States, including those working in 

agricultural occupations, and to report on the enforcement of the FLSA 

and associated regulations. For this report, we use the term “working 

children” to describe individuals aged 17 and under, in paid employment, 

unless otherwise noted. This report examines (1) what is known about 

children working in the United States, including those working in 

agriculture; (2) what is known about work-related fatalities and injuries to 

children working in the United States, including those working in 

agriculture; and (3) how DOL oversees compliance with the child labor 

provisions of the FLSA, including any efforts to collaborate within DOL.

To address the first two objectives, we analyzed national federal data 

from several sources.6 Specifically, for the first objective, we analyzed 

employment and demographic characteristics data from DOL’s Bureau of 

Labor Statistics’ (BLS) Current Population Survey (CPS) from 2003 to 

2017,7 as well as employment and poverty data from the 2017 Annual 

Social and Economic Supplement data to produce estimates of child 

worker populations and demographic trends.8 For additional information 

on children working in agricultural occupations, we also analyzed 

employment and demographic characteristics data from DOL’s National 

Agricultural Worker Survey from fiscal years 2003 to 2016, the 

Department of Health and Human Services’ National Institute for 

 5

GAO, Child Labor: Labor Can Strengthen Its Efforts to Protect Children Who Work, 

GAO-02-880 (Washington D.C.: Sept. 27, 2002). 

6

None of the analyses in this report are intended to assess compliance with the FLSA, 

because the definitions of terms used in these data sets may not be the same as the 

definitions in the FLSA and DOL’s regulations, among other reasons.

7

Our 2002 report provided information from 1990 to 2001. In 2002, the CPS variables 

used to identify the race and ethnicity of working children, as well as the industries and 

occupations they may be employed in, significantly shifted. Accordingly, we chose to 

begin our analysis with 2003. 

8

We generally refer to these data as CPS data throughout this report. The CPS and its 

Annual and Social Economic Supplement are sponsored jointly by the Census Bureau and 

the Department of Labor’s Bureau of Labor Statistics. To produce our estimates, we 

analyzed monthly CPS data from 2003 to 2017 and data from the March 2017 CPS 

Annual and Social Economic Supplement, which contains data for calendar year 2016. 
Page 3 GAO-19-26 Working Children

Occupational Safety and Health’s (NIOSH) Childhood Agricultural Injury 

Survey for the years the data were collected during the same time 

period,9 as well as overall agricultural workforce data from the U.S. 

Department of Agriculture’s 2012 Census of Agriculture.10

To address the second objective, we analyzed data on work-related child 

fatalities from BLS’s Census of Fatal Occupational Injuries and data on 

work-related child injuries and illnesses from its Survey of Occupational 

Injuries and Illnesses for 2003 to 2016.11 For additional information on 

work-related injuries to children, we also analyzed injury and illness data 

from NIOSH’s National Electronic Injury Surveillance System from 2003 

to 2016 and the Childhood Agricultural Injury Survey (CAIS) for the years 

the data was collected.12 Given that each data set has its own strengths 

and limitations and that analysis across data sets can compound such 

limitations, we sent our analyses to the appropriate officials to ensure we 

accurately characterized the data and that our analyses across data sets 

appropriately accounted for data limitations. See appendix I for a detailed 

list of the data sources we analyzed for these objectives.

To address the third objective regarding how DOL oversees compliance 

with the child labor provisions of the FLSA, we analyzed data from DOL’s 

Wage and Hour Division’s (WHD) Wage and Hour Investigative Support 

and Reporting Database (WHISARD) from fiscal years 2010 to 2016, 

which tracks investigations, violations, and penalties assessed.13 We also 

interviewed WHD officials at the five regional offices and six selected 

district offices to obtain information on WHD’s enforcement of the child 

 9

The CAIS was conducted in 2001, 2004, 2006, 2009, 2012, and 2014. We analyzed 

CAIS data from 2004, 2006, 2009, 2012, and 2014, as this report’s scope begins with 

2003.

10The 2012 Census of Agriculture was the most recent Census for which data are 

available.

112016 is the most recent year for which data are available from these data sets.

12We analyzed CAIS data from the same selected years for all analyses (i.e., 2004, 2006, 

2009, 2012, and 2014). NIOSH combined 2 years of CAIS injury data to produce 

estimates of work-related injuries to children with less than 33 percent relative standard 

error, and thus within NIOSH’s standards for reporting.

13Data for fiscal year 2016 was the most current data available at the time of our audit 

work. Throughout this report, investigations—and any violations found and resulting 

penalties—are counted in the fiscal year in which they concluded, although the 

investigations work may have been done in a prior fiscal year.
Page 4 GAO-19-26 Working Children

labor provisions of the FLSA.

14 Specifically, in each WHD region we 

interviewed the regional Child Labor Coordinator, and in each district 

office we interviewed a WHD investigator, Community Outreach 

Resource and Planning specialist, and district director. We selected WHD 

district offices to include different concentrations of investigations with at 

least one child labor violation, obtain geographic diversity, and ensure 

representation across agricultural and non-agricultural sectors. The 

findings from our interviews with regional and district WHD staff are not 

generalizable but provide examples of WHD’s enforcement and 

compliance assistance efforts with regard to the child labor provisions of 

the FLSA.

To inform all of our objectives, we interviewed DOL staff in the national 

office, including WHD and Occupational Safety and Health Administration 

(OSHA) officials, and additional stakeholders, such as employer and 

employee labor groups, to learn about overall child labor trends in 

agricultural and non-agricultural sectors.15 We also reviewed relevant 

federal laws, regulations, and guidance pertaining to child labor.16

To assess the reliability of all of the data sets used in our study, we 

reviewed documentation, interviewed or obtained information from 

officials responsible for the data, and tested the data for inaccuracies. We 

determined that the data fields we used are sufficiently reliable for the 

purposes of our reporting objectives. See appendix I for more detailed 

information about our scope and methodology.

We conducted this performance audit from March 2017 to November 

2018 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

 14WHD has five regional offices—Atlanta, Chicago, Dallas, Philadelphia, and San 

Francisco—and 54 district offices nationwide. 

15We conducted 11 stakeholder interviews with a range of organizations, including those 

focused on employers, occupational health and safety, or working children. 

16States may also have laws protecting working children, such as state child welfare laws 

and state child labor laws; however, a review of state laws was outside the scope of this 

report. Additionally, as noted previously, other federal laws such as the Federal 

Insecticide, Fungicide, and Rodenticide Act that may apply to working children are outside 

the scope of this report.
Page 5 GAO-19-26 Working Children

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.

The child labor requirements under the FLSA and its implementing 

regulations vary, depending on the age of the child and whether or not the 

child works in agriculture. With respect to non-agricultural employment, 

children aged 16 and 17 may work in any occupation other than those 

declared by the Secretary of Labor to be particularly hazardous for such 

individuals or detrimental to their health or well-being,17 and there are no 

limits on the number of hours or times of day they may work.18 The nonagricultural employment of children aged 14 and 15 is limited to 

occupations and time periods that DOL has determined will not interfere 

with their schooling and to conditions which will not interfere with their 

health and well-being. Accordingly, DOL has issued regulations that limit 

the types of jobs, number of hours, and times of day that these children 

may work.19 For example, among other things, children aged 14 and 15 

may engage in work such as office or clerical work, certain types of food 

service, and the dispensation of gasoline, outside of school hours, subject 

to maximum daily and weekly limits. In general, children aged 13 and 

under may not be employed in non-agricultural work other than work that 

is not covered by the FLSA, such as casual babysitting, and work that is 

exempt from the child labor provisions, such as delivering newspapers.20

More details about child labor provisions for non-agricultural employment 

are in table 1.

 17See 29 U.S.C. § 203(l) and 29 C.F.R. §§ 570.50-570.68 (DOL’s “hazardous occupations

orders” for non-agricultural occupations). See table 2 for a list of these orders.

18However, working children may still be subject to the FLSA minimum wage and overtime 

provisions. Unless otherwise exempt, a child working in non-agricultural employment is 

generally entitled to receive the same minimum wage and overtime protections as adult 

workers.

19See generally 29 U.S.C. § 203(l) and 29 C.F.R. §§ 570.31-570.39. Employment that is 

not specifically permitted is prohibited. 

20See 29 U.S.C. § 213(d). In addition, children under 16 (including those 13 and under) 

may be employed by their parent, or a person standing in place of a parent, in any 

occupation other than manufacturing, mining, or an occupation declared to be hazardous 

by DOL for children aged 16 and 17. 29 U.S.C. § 203(l), 29 C.F.R. § 570.2(a)(2).

Background

Fair Labor Standards Act 

and Federal Enforcement
Page 6 GAO-19-26 Working Children

Table 1: Child Labor Provisions for Non-Agricultural Employment

Age Occupations allowed Hours allowed Times of day Other conditions

13 or undera Employment generally 

prohibited.

Not applicable. Not applicable. Not applicable.

14 and 15a Limited to those occupations 

and time periods that DOL 

has determined will not 

interfere with their schooling 

and to conditions that will 

not interfere with their health 

and well-being, such as 

office and clerical work, 

among others.b

Mining, manufacturing, and 

occupations declared to be 

hazardous by DOL for 

children aged 16 and 17 are 

expressly prohibited.

Only outside of school 

hours.c

Daily limits:

No more than 3 hours 

per day on days when 

school is in session; no 

more than 8 hours per 

day on days when school 

is not in session.

Weekly limits:

No more than 18 hours 

per week during weeks 

when school is in 

session; no more than 40 

hours per week during 

weeks when school is not 

in session.

Between Labor Day and 

June 1:

Between 7 am and

7 pm

June 1 through Labor 

Day:

Between 7 am and

9 pm

Certain exceptions apply 

for children participating in 

an approved Work 

Experience and Career 

Exploration Program, 

children participating in an 

approved Work Study 

program, and children 

who are employed as 

professional sports 

attendants, among 

others.d

16 and 17 Any occupations other than 

those declared by the 

Secretary of Labor to be 

particularly hazardous for 

the employment of children 

aged 16 and 17, or 

detrimental to their health or 

well-being.e

No specific restrictions 

for allowable work.c No restrictions for allowable work.

Certain exceptions may 

apply; for example, some 

of the hazardous 

occupations orders 

contain limited 

exemptions for eligible 

apprentices and studentlearners. 

Source: GAO review of the Fair Labor Standards Act of 1938, as amended, applicable regulations, and Department of Labor guidance. | GAO-19-26

a

Children under age 16, including those aged 13 and under, may engage in work that is not covered 

by the FLSA, such as casual babysitting; and work that is exempt from the child labor provisions, 

such as acting or performing in motion pictures, theatrical productions, or radio or television 

productions, or delivering newspapers. In addition, if they are employed by their parent, or a person 

standing in place of a parent, children under age 16 may work in any occupation other than mining, 

manufacturing, or an occupation declared to be hazardous by DOL for children aged 16 and 17.

There are no specific restrictions on the number of hours or times of day for these types of 

permissible work, although minimum wage and overtime requirements may apply.

b

Other examples include, but are not limited to, doing errand and delivery work by foot, bicycle, and 

public transportation; lifeguarding (15-year-olds only); dispensing gasoline and oil; and car cleaning, 

washing, and polishing by hand. See 29 C.F.R. § 570.34.

c

Minimum wage and overtime requirements may also apply.

d

For example, children aged 14 and 15 participating in a Work Experience and Career Exploration 

Program that meets certain requirements may be employed for up to 23 hours per week and up to 3 

hours per day when school is in session, including during school hours. 29 C.F.R. § 570.36.

According to DOL guidance, the program is designed to provide a work experience and career 

exploration program for students who can benefit from a career-oriented education.

e

DOL has established 17 “hazardous occupations orders,” declaring certain non-agricultural 

occupations to be particularly hazardous for the employment of children between the ages of 16 and 

18 years, or detrimental to their health or well-being (referred to in this table as “occupations declared 

to be hazardous by DOL for children aged 16 and 17”). See 29 C.F.R. §§ 570.50-570.68.
Page 7 GAO-19-26 Working Children

Further, children under age 18 are generally prohibited from working in 

the 17 non-agricultural hazardous occupations that DOL has established 

by regulation, subject to limited exemptions (see table 2). These orders 

apply either on an occupational basis, irrespective of the industry, or on 

an industry basis, specifying the occupations in the industry that are not 

permitted. For example, one of the orders generally prohibits all 

occupations in connection with mining, other than coal, but allows work in 

offices, in a warehouse or supply house, in a laboratory, and in repair or 

maintenance shops not located underground, among other exceptions.21

Table 2: Non-Agricultural Hazardous Occupations Orders

Hazardous 

occupations 

order number

Hazardous occupations order title

1 Occupations in or about plants or establishments manufacturing or 

storing explosives or articles containing explosive components

2 Occupations of motor-vehicle driver and outside helper 

3 Coal mine occupations

4 Forest fire fighting and forest fire prevention occupations, timber tract 

occupations, forestry service occupations, logging occupations, and 

occupations in the operation of any sawmill, lath mill, shingle mill, or 

cooperage stock mill

5 Occupations involved in the operation of power-driven woodworking 

machines

6 Exposure to radioactive substances and to ionizing radiations

7 Occupations involved in the operation of power-driven hoisting 

apparatus

8 Occupations involved in the operation of power-driven metal forming, 

punching, and shearing machines

9 Occupations in connection with mining, other than coal 

10 Occupations in the operation of power-driven meat-processing 

machines and occupations involving slaughtering, meat and poultry 

packing, processing, or rendering

11 Occupations involved in the operation of bakery machines

12 Occupations involved in the operation of balers, compactors, and 

paper-products machines

13 Occupations involved in the manufacture of brick, tile, and kindred 

products

 2129 C.F.R. § 570.60(a).
Page 8 GAO-19-26 Working Children

Hazardous 

occupations 

order number

Hazardous occupations order title

14 Occupations involving the operation of circular saws, band saws, 

guillotine shears, chain saws, reciprocating saws, wood chippers, and 

abrasive cutting discs

15 Occupations involved in wrecking, demolition, and ship-breaking 

operations

16 Occupations in roofing operations and on or about a roof

17 Occupations in excavation operations

Source: 29 C.F.R. §§ 570.50-570.68. | GAO-19-26

Notes: Although referred to as hazardous occupations orders, the Department of Labor (DOL) has 

issued these orders by regulation. Each order describes specific work activities, including definitions 

and exceptions, that DOL has declared to be particularly hazardous for minors between the ages of 

16 and 18, or detrimental to their health or well-being. In addition, the Fair Labor Standards Act of 

1938, as amended, and DOL regulations prohibit children aged 14 and 15 from performing any work 

proscribed by these orders. This table includes only the titles of each order, not the specific work 

activities, definitions, and exemptions.

Under the FLSA, different child labor requirements apply to agricultural 

occupations.22 For example, there are no occupational restrictions for 

children aged 16 and 17 working in agriculture.23 In accordance with the 

FLSA, DOL has issued 11 hazardous occupations orders for agricultural 

occupations, declaring certain occupations to be particularly hazardous 

for children under age 16 (see table 3).24

 22For purposes of the FLSA, “agriculture” includes “farming in all its branches and among 

other things includes the cultivation and tillage of the soil, dairying, the production, 

cultivation, growing, and harvesting of any agricultural or horticultural commodities, the 

raising of livestock, bees, fur-bearing animals, or poultry, and any practices (including any 

forestry, or lumbering operations) performed by a farmer or on a farm as an incident to or 

in conjunction with such farming operations, including preparation for market, delivery to 

storage or to market or to carriers for transportation to market.” 29 U.S.C. § 203(f). Migrant 

and seasonal agricultural employees, regardless of their age and whether hired directly by 

the farmer or provided by a farm labor contractor—when covered by the FLSA—are 

entitled to the same protections under the FLSA as other farm workers, according to WHD 

guidance. 

23Minimum wage requirements may apply; however, agricultural employees are generally 

not subject to the overtime provisions of the FLSA. See 29 U.S.C. § 213(b)(12).

24See 29 U.S.C. § 213(c)(2); 29 C.F.R. §§ 570.70-570.72 (DOL’s hazardous occupations

orders for agricultural employment).
Page 9 GAO-19-26 Working Children

Table 3: Agricultural Hazardous Occupations Orders

Hazardous 

occupations 

order number

Hazardous occupations

1 Operating a tractor of over 20 power-take-off horsepower, or 

connecting or disconnecting an implement or any of its parts to or from 

such a tractor.

2 Operating or assisting to operatea any of the following machines: (1) 

corn picker, cotton picker, grain combine, hay mower, forage 

harvester, hay baler, potato digger, or mobile pea viner; (2) feed 

grinder, crop dryer, forage blower, auger conveyor, or the unloading 

mechanism of a nongravity-type self-unloading wagon or trailer; or (3) 

power post-hole digger, power post driver, or nonwalking type rotary 

tiller.

3 Operating or assisting to operatea any of the following machines: 

trencher or earthmoving equipment, fork lift, potato combine; or powerdriven circular, band, or chain saw.

4 Working on a farm in a yard, pen, or stall occupied by a bull, boar, or 

stud horse maintained for breeding purposes; or a sow with suckling 

pigs or cow with newborn calf (with umbilical cord present).

5 Felling, bucking, skidding, loading or unloading timber with butt 

diameter of more than 6 inches.

6 Working from a ladder or scaffold (painting, repairing, or building 

structures, pruning trees, picking fruit, etc.) at a height of over 20 feet.

7 Driving a bus, truck, or automobile when transporting passengers, or 

riding on a tractor as a passenger or helper.

8 Working inside a fruit, forage, or grain storage designed to retain an 

oxygen deficient or toxic atmosphere; an upright silo within 2 weeks 

after silage has been added or when a top unloading device is in 

operating position; a manure pit; or a horizontal silo while operating a 

tractor for packing purposes.

9 Handling or applying (including cleaning or decontaminating 

equipment, disposal or return of empty containers, or serving as a 

flagman for aircraft applying) agricultural chemicals classified under 

the Federal Insecticide, Fungicide, and Rodenticide Act as Category I 

of toxicity, identified by the word “poison” and the “skull and 

crossbones” on the label; or Category II of toxicity, identified by the 

word “warning” on the label.

10 Handling or using a blasting agent, including but not limited to, 

dynamite, black powder, sensitized ammonium nitrate, blasting caps 

and primer cord.

11 Transporting, transferring, or applying anhydrous ammonia.

Source: 29 C.F.R. § 570.71 | GAO-19-26

Notes: Although referred to as hazardous occupations orders, the Department of Labor (DOL) has 

issued these orders via regulation. Each agricultural occupation listed in this table has been declared 

by the DOL to be particularly hazardous for the employment of children under the age of 16. These 

orders do not apply to children employed by a parent or a person standing in place of a parent on a 

farm owned or operated by such parent or person.
Page 10 GAO-19-26 Working Children

a

“Operating or assisting to operate” includes starting, stopping, adjusting, feeding, or any other activity 

involving physical contact associated with the operation.

Children younger than 16 may generally only work in agricultural 

occupations other than the ones covered by these orders, and only 

outside of school hours (see table 4).25 Additional restrictions apply to 

children under the age of 14.26 Children of any age may be employed in 

any agricultural occupation at any time, if they are employed by their 

parent (or a person standing in place of a parent) on a farm owned or 

operated by that parent or person.27 Unlike some of the requirements for 

non-agricultural occupations, the FLSA does not limit the number of hours 

per day or week that children may work in agriculture, nor does it place 

limits on when that work may occur outside of school hours.

Table 4: Child Labor Provisions for Agricultural Employment

Age Allowable 

occupations

Allowable hours Other conditions

Under 12a, b Non-hazardous 

(agricultural).c Only outside of school hours.

Children must be employed with the consent of their parent (or 

a person standing in place of a parent) on a farm where all 

employees are exempt from the minimum wage requirements 

due to its size.d

12 and 13a Non-hazardous 

(agricultural).c Only outside of school hours.

Children must be employed either with the written consent of 

their parent (or a person standing in place of a parent); or on 

the same farm where such parent or person is employed.

 2529 U.S.C. § 213(c)(1), (c)(2). Exceptions may apply to eligible student-learners in a 

vocational agricultural program, and children who have completed certain training in 

tractor or machine operation. See 29 C.F.R. §§ 570.71-570.72.

26For example, children aged 12 and 13 must be employed either with the written consent 

of their parent (or a person standing in place of a parent); or on the same farm where their 

parent is employed. 29 C.F.R. § 570.2(b). See table 4 for more information on the specific 

restrictions for children under age 14. 

2729 U.S.C. § 213(c)(2); 29 C.F.R. §§ 570.2(b), 570.70(b).
Page 11 GAO-19-26 Working Children

Age Allowable 

occupations

Allowable hours Other conditions

14 and 15a Non-hazardous 

(agricultural).c Only outside of school hours.e Exceptions:

Student-learners in a vocational agricultural program may work 

in specified hazardous (agricultural) occupations under certain 

conditions.f

Children aged 14 to 15 who have successfully completed the 

tractor operation or machine operation training program under 

4-H (or a similar program) or a program of the U.S. Office of 

Education Vocational Agriculture Training Program may work in 

the hazardous (agricultural) occupations for which they have 

been trained. Certain conditions of employment apply for 

children working under these exemptions.g

16 and 17 All Any (no hour 

restrictions).

Not applicable.

Source: GAO review of the Fair Labor Standards Act of 1938 (FLSA), as amended, applicable regulations, and Department of Labor guidance. | GAO-19-26

a

Children of any age may be employed in any agricultural occupation if employed by their parent (or a 

person standing in place of a parent) on a farm owned or operated by that parent, and there are no 

hour restrictions for children so employed.

b

The FLSA provides that employers may apply for waivers from the Department of Labor (DOL) to 

permit local children aged 10 and 11 to be employed outside of school hours in the hand harvesting 

of short season crops under certain conditions. DOL issued regulations in 1978 setting forth the 

procedures for implementing this waiver provision. See 29 U.S.C. § 213(c)(4), 29 C.F.R. pt. 575. 

However, DOL was enjoined from issuing such waivers by a 1980 court decision resulting from a 

legal challenge to these regulations. See National Ass’n of Farmworkers Organizations v. Marshall, 

628 F.2d 604 (D.C. Cir. 1980). According to officials, DOL does not have any record that it has issued 

a waiver under this authority since 1980.

c

The FLSA provides a minimum age of 16-years-old for any agricultural occupations which DOL finds 

and declares to be particularly hazardous for persons under the age of 16. 29 U.S.C. § 213(c)(2). 

DOL has issued 11 hazardous occupations orders for agricultural employment. See 29 C.F.R. §§

570.70–570.72. In this table we refer to occupations covered by these orders as “hazardous 

(agricultural)” and occupations not covered by these orders as “non-hazardous (agricultural).”

d

The FLSA minimum wage and overtime provisions do not apply with respect to an agricultural 

employer who did not, during any calendar quarter in the preceding calendar year, use more than 500 

“man-days” of agriculture labor.

e

For children who have graduated from high school, the entire year would be considered outside of 

school hours and, therefore, their employment in agriculture would be permitted at any time.

f

For example, the child must be employed under a written agreement that provides that the work shall 

be incidental to the training.

g

For example, the employer is subject to certain supervision requirements, and must keep the child’s 

certificate of completion on file, among other things.

The child labor provisions of the FLSA do not cover all children. In 

addition to the exemptions and exceptions already discussed, some 
Page 12 GAO-19-26 Working Children

employers may not meet the criteria for FLSA coverage.28 Children may 

also be covered under a state’s child labor laws, which may provide more 

stringent child labor protections than the federal law.29

DOL, through its WHD, is the federal agency responsible for enforcing the 

FLSA, including the child labor provisions and associated regulations.30

According to DOL regulations, the child labor provisions seek to protect 

the safety, health, well-being, and opportunities for schooling of youthful 

workers.31 DOL also oversees workplace safety and health through 

OSHA, which is responsible for setting and enforcing workplace safety 

and health standards under the Occupational Safety and Health Act of 

1970, as amended (OSH Act).32 Employers must follow applicable 

workplace safety and health standards, which generally require them to 

take steps to prevent workers, including those aged 17 and under, from 

being injured or becoming ill on the job. To carry out their respective 

responsibilities, WHD and OSHA conduct inspections, investigate 

complaints, and offer compliance assistance programs and training, 

among other efforts.

To enforce the FLSA, WHD’s national office establishes annual 

performance measures for enforcement and compliance activities, 

including those related to the child labor provisions of the FLSA. WHD’s 

 28The FLSA generally covers all employees of businesses that are engaged in interstate 

commerce and that have an annual gross volume of sales or business of $500,000 or 

more (referred to as “enterprise coverage”). Even when there is no enterprise coverage, 

employees may be covered by the FLSA’s protections if they are individually engaged in 

interstate commerce or in the production of goods for interstate commerce. The FLSA’s 

“hot goods” provision, in section 12(a), permits DOL to seek a court order to prevent the 

interstate shipment of goods that were produced in or about an establishment where a 

child labor violation occurred in the past 30 days. According to DOL officials, application of 

the hot goods provision does not require that the child who was employed in violation of 

FLSA’s child labor provisions was personally engaged in the production of those goods. 

See 29 U.S.C. § 212(a).

29A review of state laws was outside the scope of this report.

30WHD is also responsible for enforcing several other statutes, including the Davis-Bacon 

Act and related acts, the Migrant and Seasonal Agricultural Worker Protection Act, and the 

Family and Medical Leave Act, among others.

3129 C.F.R. § 570.101(a). 

32Pub. L. No. 91-596, 84 Stat. 1590 (codified as amended at 29 U.S.C. §§ 553, 651-78). 

Under the OSH Act, states may choose to operate their own occupational safety and 

health programs in accordance with state plans approved by OSHA. 

DOL’s Role in Enforcing 

the Child Labor Provisions 

of the Fair Labor 

Standards Act
Page 13 GAO-19-26 Working Children

national office also establishes the planning framework used by WHD’s 5 

regional and 54 district offices to develop regional and local initiatives, 

which can include both enforcement and outreach activities. In addition, 

WHD’s national office is responsible for providing guidance and training to 

its field offices and for assessing the results of their child labor 

compliance efforts. The field offices have discretion to organize their work 

to meet performance targets, and to create and implement these initiative 

plans each fiscal year.33 WHD has also developed a Community 

Outreach Resource and Planning Specialist position for its district offices, 

whose primary duties include outreach and enforcement planning for 

WHD district offices.34 In 2010, WHD’s national office began emphasizing 

the use of data to develop its strategy for enforcement and compliance 

assistance activities, including the creation of a priority industry list, which 

would help the agency plan where to focus its enforcement activities.

Since 2010, WHD has addressed child labor as a component of its FLSA 

outreach and enforcement activities. WHD outreach efforts include 

presentations to stakeholder groups and employers. WHD’s enforcement 

actions include on-site investigations of employers and other activities 

designed to bring employers into compliance with the law. When WHD 

determines, as a result of an investigation, that an employer has violated 

the child labor provisions of the FLSA, WHD may assess penalties or take 

other enforcement actions.35 The penalties for child labor violations 

depend on the size of the business and the gravity of the violations, 

including any history of prior violations, evidence of willfulness or failure to 

take reasonable precautions, and whether any children were killed or 

injured as a result.

In 2011, WHD proposed some revisions to the FLSA agricultural child 

labor regulations. According to the proposed rule, these revisions were 

 33In addition to the national office, WHD operates offices at the regional, district, area, and 

field levels. For the purposes of this report, we generally refer to all WHD offices outside of 

the national office as “field offices,” unless otherwise noted.

34As of June 2018, WHD had a Community Outreach and Resource Planning Specialist 

staff person in the majority of WHD’s 54 district offices nationwide.

3529 U.S.C. § 216(e); 29 C.F.R. pts. 579, 580. In addition to civil money penalties, the 

FLSA also authorizes DOL to seek injunctions to halt the interstate shipment of goods 

produced in violation of the child labor provisions, 29 U.S.C. § 212(a), to seek injunctions 

against violators of the child labor provisions to compel their compliance with the law, 29 

U.S.C. § 217, and for willful violations, to seek criminal penalties including a fine of not 

more than $10,000 and/or imprisonment of not more than 6 months, 29 U.S.C. § 216(a). 
Page 14 GAO-19-26 Working Children

intended to implement specific recommendations made by NIOSH, 

increase parity between the agricultural and nonagricultural child labor 

provisions, and address other WHD-identified areas for improvement.36

After reviewing public comments, WHD withdrew the proposed rule in 

2012.37 In the notice withdrawing the proposed rule, WHD stated that it 

would instead pursue a non-regulatory approach to address the safety 

and health of children working in agriculture, such as collaborating with 

farming organizations to develop educational programs on hazardous 

agricultural work practices and conditions.38

Several key federal sources provide information on the number and 

characteristics of working children aged 17 and under in the United 

States. The CPS, compiled monthly by DOL’s BLS, is the primary source 

of labor force statistics, including for children aged 15 to 17.39 The CPS is 

a survey of U.S. households and provides nationally representative 

information on the number of working children in the United States, as 

well as how many hours they worked and the industries in which they 

 36Child Labor Regulations, Orders and Statements of Interpretation; Child Labor 

Violations—Civil Money Penalties, 76 Fed. Reg. 54,836 (Sept. 2, 2011). 

37WHD held a public hearing and received written comments on the proposed rule through 

December 2011. After consideration of the public comments, WHD announced its decision 

to pursue a non-regulatory approach to address the safety and health of children 

employed in agriculture rather than amending the existing child labor rules. 

38Child Labor Regulations, Orders and Statements of Interpretation; Child Labor 

Violations—Civil Money Penalties, 77 Fed. Reg. 31,549 (May 29, 2012).

39CPS is a joint survey sponsored by the Census Bureau and BLS. CPS estimates 

contained in this report are estimated standard errors and are presented along with an 

approximate margin of error at the 95 percent confidence level or relative standard errors. 

We express our confidence in the precision of a particular sample’s estimates with a 

confidence interval. By adding and subtracting the margin of error from the estimate, we 

construct a confidence interval that would contain the actual population value for 95 

percent of the samples that CPS could have drawn. All margins of error for CPS estimates 

presented in this report are approximations. We calculated the approximate margins of 

error following CPS guidance and technical documentation. In order to estimate the 

margin of error for estimates of our subgroups of interest, a number of approximations 

were required. As a result, the margins of error provide a general order of magnitude. A 

relative standard error is equal to the standard error of a survey estimate divided by the 

survey estimate. 

Data Sources
Page 15 GAO-19-26 Working Children

worked.40 This survey includes data regarding children aged 15 to 17 

who work in agriculture, including children on U.S. farms who were 

members of the household working for 15 or more hours per week (with 

or without pay) and children working on farms employing 10 or fewer 

workers.41 The CPS and its Annual Social and Economic Supplement 

also provide demographic information on working children, such as age, 

race, ethnicity, and family income. 

In addition to CPS data, the Department of Health and Human Services’

NIOSH and DOL also collect data specific to children aged 17 and under 

working in agriculture:

• NIOSH’s Childhood Agricultural Injury Survey (CAIS) is conducted in 

selected years by surveying a random sample of 50,000 U.S. farms.42

This survey collects data on children working in both crop and 

livestock agriculture, as well as working children on farms employing 

10 or fewer workers, and children working on U.S. farms who are 

members of the household, referred to as “household children,”

regardless of their pay status or household status.43

• DOL’s National Agricultural Workers Survey (NAWS) is an 

employment-based, annual survey of demographic, employment, and 

health characteristics of workers in crop agriculture, including those 

 40The CPS includes all people residing in the United States, including those who are 

foreign born—people who were not U.S. citizens at birth—which include legally-admitted 

immigrants, refugees, temporary residents such as students and temporary workers, and 

undocumented immigrants. The CPS data, however, do not separately identify the number 

of people in these categories.

41BLS’s CPS does not count unpaid family workers, on farms or in other family 

businesses, who work less than 15 hours per week. According to BLS officials, the CPS 

collects information on workers on farms, including those that employ 10 or fewer workers. 

BLS officials also stated that its research indicates some concerns with the data quality of 

the CPS variable used on firm size. BLS officials stated they believe that firm size can be 

better determined through surveys of establishments rather than surveys of households 

(such as the CPS).

42CAIS data were collected in 2001, 2004, 2006, 2009, 2012, and 2014. From 2001 

through 2012, CAIS was based on a sample of 50,000 U.S. farm operations from the 

Census of Agriculture. In 2014, the CAIS sample was increased to 75,000 farming 

operations. 

43For the purposes of this report, working household children are those who live and work 

without pay on a farm owned by their parents. CAIS collects data on hired labor (those 

working for pay), household labor (those living on the farm where they are working), and 

visitors (a visiting relative to the farm operation or a non-relative visitor). Working 

household children are those who live and work on a farm owned by their parents. 

Agricultural Employers: U.S. Farm 

Characteristics and Family Farms

Agricultural production has shifted to much 

larger farming operations over the last 3 

decades, even as the number of small farms 

has grown, according to the U.S. Department 

of Agriculture’s Economic Research Service. 

Overall, larger farms —those with at least $1 

million in sales—account for an increasing 

share of production, with 51 percent of the 

value of U.S. farm production coming from 

large farms in 2015, compared to 31 percent 

in 1991.

A “family farm” is any of the nation’s 

approximately 2 million farms where the 

majority of the business is owned by the 

principal operator. The U.S. Department of 

Agriculture’s Economic Research Service 

defines large-scale family farms as those with 

gross income of $1 million or more, and small 

family farms as those with a gross income of 

less than $350,000. Ninety percent of U.S. 

farms are classified as small, and these farms 

accounted for 51 percent of the land operated 

by farms in 2016, according to the Economic 

Research Service.

Source: GAO analysis of U.S. Department of Agriculture 

information. | GAO-19-26
Page 16 GAO-19-26 Working Children

on crop farms employing 10 or fewer workers.44 This survey does not 

include data on livestock agricultural workers or unpaid household 

workers.45

The primary sources of data on children who are injured or killed as a 

result of work-related incidents come from BLS and NIOSH. BLS reports 

on fatalities through its Census of Fatal Occupational Injuries, which 

collects data on fatalities through multiple sources such as death 

certificates, workers’ compensation reports, and federal and state agency 

administrative reports. BLS collects data on the number of nonfatal workrelated injuries and illnesses in its Survey of Occupational Injuries and 

Illnesses from a sample of the work-related injury and illness records that 

employers in private industry are required to maintain. NIOSH collects 

data on work-related injuries in its National Electronic Injury Surveillance 

System, which collects information from a nationally representative 

sample of hospital emergency departments to produce its annual 

estimate. NIOSH, in collaboration with the U.S. Department of 

Agriculture’s National Agricultural Statistics Service, has also collected 

data on work-related injuries to children in agriculture through the CAIS.

In our 2002 report on child labor, we made seven recommendations 

related to the report’s findings on limitations to DOL’s compliance efforts 

regarding the child labor provisions of the FLSA.46 DOL disagreed with 

many of the conclusions and recommendations in the report but has 

 44NAWS surveys hired farm workers, including crop workers, workers at nurseries, 

workers at packing houses, and workers brought to farms by labor contractors. 

Approximately 1,500 of these workers each round are randomly selected for an in-person 

interview, and NAWS conducts three rounds of interviews per year, to account for the 

seasonality of agricultural production and employment. We note that a farm employing 10 

or fewer workers may represent a large operation. 

45Migrant child workers are within the scope of NAWS and CAIS, as these surveys are 

conducted at the job site and such workers are not excluded from the survey. According to 

DOL, migrant child workers are child farm workers who generally travel to the job site such 

that the farm worker is not reasonably able to return to his or her permanent residence 

within the same day. According to agency officials, workers in the United States on a H-2A 

visa—a temporary work visa for foreign agricultural workers with a job offer for temporary 

or seasonal agricultural work in the United States—are excluded in the NAWS survey, but 

are generally included in the CPS and CAIS. 

46GAO-02-880.

Status of 2002 GAO 

Recommendations on 

Child Labor
Page 17 GAO-19-26 Working Children

implemented all but one of these recommendations.47 We recommended 

that DOL:

• provide additional guidance to staff,

• consider enhancing the CPS data collected on working children,

• routinely obtain and review data from its internal investigations 

database and use this data to ensure effective resource use for child 

labor compliance,

• use existing BLS and NIOSH data to better target compliance efforts,

• develop methods of measuring WHD’s child labor compliance efforts,

• develop additional specific, measurable goals for improving 

compliance in industries in which children face the greatest risk of 

being injured or killed, and

• provide training to all WHD staff on how to obtain information from the 

internal investigations database.

For the CPS specifically, we recommended that BLS enhance data 

collection on working children by expanding the CPS to include 14-yearolds or beginning a new cohort of another survey of children, the National 

Longitudinal Study of Youth. DOL generally agreed with this 

recommendation, and the agency conducted an assessment of the 

feasibility of expanding the CPS.

 47DOL did not implement the recommendation to use existing BLS and NIOSH data to 

better target WHD’s child labor compliance efforts, citing concerns that doing so would 

require disaggregating the data at a level that would jeopardize participants’

confidentiality. We disagreed that such disaggregation would be required.
Page 18 GAO-19-26 Working Children

According to our analysis of CPS data, the estimated number of working 

children aged 15 to 17 has generally fluctuated with the economy; 

however, this number has not reached pre-recession levels. Specifically, 

the number of children aged 15 to 17 who worked during summer 

months—June through August—was an estimated 3.3 million in 2003, 

and then reached a low of 1.9 million in 2011. By 2017, an estimated 2.5 

million children worked during summer months, which remains below prerecession levels. Fewer children worked during non-summer months—

September through May—however, they followed a similar trend (see fig. 

1).48

 48More specifically, we define “non-summer months” as January through May and 

September through December during a calendar year. Our definitions of summer and nonsummer months are not intended to align with how summer is defined in the FLSA child 

labor regulations. We used our definition of summer and non-summer months in our 

analysis as we found this categorization to be the most workable given the arrangement 

and content of the CPS data set. These estimates have relative standard errors of 10 

percent or less.

The Number of 

Working Children 

Generally Fluctuated 

with the Economy

The Number of Working 

Children Declined until 

about 2011 and Has Since 

Increased, and Most 

Working Children Are 

Employed in NonAgricultural Industries
Page 19 GAO-19-26 Working Children

Figure 1: Estimated Number of Working Children Aged 15 to 17 in the United States, 

2003 to 2017

Notes: We defined “summer months” as June through August, and “non-summer months” as January 

through May and September through December during a calendar year. These definitions are not 

intended to align with how summer is defined in the Fair Labor Standards Act child labor regulations.

These estimates have relative standard errors of 10 percent or less. For more details, see appendix 

II.

More children work in summer months and children generally work more 

hours in the summer than they do in non-summer months, according to 

the CPS data. For more details, see appendix II.

We conducted some additional analyses focusing on hours worked by 15-

year-olds, because they are subject to different requirements than 
Page 20 GAO-19-26 Working Children

children aged 16 and 17.49 Specifically, we analyzed the number of hours 

children aged 15 worked in summer (June, July, and August) and nonsummer months—which do not necessarily correspond to any given 

school year.50 From 2003 through 2017 the percentage of working 15-

year-olds we estimated that worked 40 or more hours per week in nonagricultural industries in summer months ranged from a low of 8 percent 

in 2004 to a high of 19 percent in 2014.51 The percentage we estimated 

that worked 19 or more hours per week in non-agricultural industries in 

non-summer months ranged from a low of 14 percent in 2004 to a high of 

31 percent in 2015 (see app. II for more details).52

We also analyzed the demographic characteristics of working children. 

Our analysis of demographic characteristics of working children in CPS 

found that working females aged 15 to 17 comprised about 52 percent of 

the working child population in 2017 summer months; and the percentage 

of white-only working children decreased from 2003 to 2017, while the 

percentage of working children of other races and ethnicities—black only, 

 49Our analysis does not show whether this work complied with the FLSA, due in part to 

differences between the data and definitions used in our analysis and the applicable FLSA 

requirements. As previously discussed, under the FLSA and DOL regulations, children 

aged 14 and 15 engaged in non-agricultural occupations may generally work up to 18 

hours per week during weeks when school is in session, and up to 40 hours per week 

during weeks when school is not in session. School is generally considered to be in 

session for any week the local public school district where the child resides while 

employed is in session, and in which students are required to attend for at least one day 

or partial day. However, various exceptions may apply; for example, there are no hour 

restrictions for children employed by their parents. The data we used for our analysis do 

not allow us to determine whether school was in session, or whether an exception applies, 

for the reported hours worked by 15-year-olds.

50We were unable to tabulate the extent to which 14-year-olds worked because, according 

to BLS, such data are not collected in the CPS or in other BLS surveys.

51These estimates for summer months are for 2004 and 2014 and have relative standard 

errors of 24 percent and 20 percent, respectively. The 2009 summer estimate is the only 

estimate from 2003 to 2017 that has a relative standard error higher than or equal to 30 

percent (is 30 percent), and should be interpreted with caution.

52These estimates for non-summer months are from 2004 and 2015 and have relative 

standard errors of 19 percent and 17 percent, respectively.
Page 21 GAO-19-26 Working Children

Hispanic, and other races combined—increased during the time period,53

irrespective of industry or occupation. Our analysis of demographic 

characteristics of working children in CPS’s Annual Social and Economic 

Supplement (ASEC) also found that while 27 percent of the children who 

did not work were low-income, only 15 percent of the children who 

worked were in that category.54 Children in low-income families were less 

likely to work than their higher income counterparts. About 11 percent of 

children in low-income families worked in 2016 compared to 21 percent of 

children in higher income families. For the results of our analyses of these 

demographic characteristics, see appendix III.

Our analysis of CPS Annual Social and Economic Supplement data also 

shows that, in 2016, the vast majority of working children aged 15 to 17 

worked in non-agricultural industries,55 such as leisure and hospitality or 

wholesale and retail. As shown in figure 2, we estimated the leisure and 

hospitality industry employed over 1.1 million children aged 15 to 17, 

wholesale and retail employed about 440,000, and more than 60,000 

children aged 15 to 17 worked in the construction and mining industry.56

We conducted an additional analysis of the children working in the 

construction and mining industry and found that an estimated 40,000 (+/-

19,600) worked in construction and extraction occupations. In addition, 

according to the data, an estimated 12,000 (+/-8,800) worked in office 

and administrative support occupations.57 We recognize our analysis 

does not show whether this work complied with FLSA requirements, in 

part because we could not identify the specific work activities performed 

by the children employed in these industries. Many activities in the 

 53The CPS treats ethnicity separately from race. As a result, a child can be identified in 

the CPS as both white and Hispanic, or as both black and Hispanic, among other 

designations. For the purposes of our report, we categorized any respondent identifying 

as Hispanic, irrespective of their reported race, as Hispanic. We further categorized 

respondents who identified as being non bi- or multiracial white or black as being white

only and black only. We counted the following respondents as other races: respondents of 

two or more races, Asians, and other races such as Native American or Pacific Islander.

54In this report, we defined low-income as having income below 150 percent of the poverty 

threshold. Poverty thresholds are set by the U.S. Census Bureau and take into account 

family size and composition to determine who is in poverty.

55Industry worked is determined based on industry of longest job worked in 2016.

56The estimates for these industries have margins of error of +/-96,000, +/-64,500, and +/-

24,600, respectively.

57The relative standard error was greater than 30 percent (35 percent) and the estimate 

should be interpreted with caution.
Page 22 GAO-19-26 Working Children

construction and mining industry, such as roofing operations or activities 

about coal mines are prohibited, and some activities, such as office work,

may be permissible, depending on the circumstances.58

Figure 2: Industries in Which Children Aged 15 to 17 Worked, 2016

Notes: Our analysis does not show whether this work complied with the Fair Labor Standards Act 

(FLSA) and federal child labor regulations, due in part to a lack of precision in the data compared with 

the applicable FLSA requirements. Margins of error for estimates at the 95 percent confidence level 

are shown by chart whiskers.

a

Professional and other services, financial activities, and information include legal, accounting, and 

other professional, scientific, and technical services, among others.

b

Construction and mining industry also includes quarrying, and oil and gas extraction.

Children aged 15 to 17 worked in a variety of occupations in 2016.59 The

top three occupations were cashiers (an estimated 375,000 working 

 58See, for example, 29 C.F.R. §§ 570.53, 570.60, 570.67 (hazardous occupations order 

numbers 3, 9, and 16). As described in tables 1 and 2, the FLSA’s occupational 

restrictions vary depending on the age of the child, his or her specific occupation, and 

whether any exceptions apply. The data we used for our analysis do not allow us to 

determine the specific work activities performed, or whether an exception applies, among 

other things.

59We analyzed 2017 CPS Annual Social and Economic Supplement data, which contains 

information regarding annual work experience for 2016.
Page 23 GAO-19-26 Working Children

children), waiters and waitresses (141,000), and athletics-related 

occupations (103,000).60 See appendix IV for detailed results.

Federal data sets collect some information on children working in 

agriculture, but two we analyzed differ regarding which children they 

include.61 For example, the data sets differ in the age range of children 

included in the data sets and the extent to which they include household 

workers, which may comprise a substantial percentage of children 

working in agriculture, as shown below. Our analysis of the CPS and 

CAIS data indicates the following: 62

• CPS. According to our CPS analysis, an estimated 3.1 percent of 

children aged 15 to 17 worked in agriculture during summer months in 

2003, and 2.9 percent worked in agriculture in summer months in 

2017.63 However, because the CPS does not measure certain groups 

of children, this is an undercount of children working in agriculture.64

• CAIS. Our analysis of CAIS data suggests higher numbers of children 

working on U.S. farms than do CPS data but capture a similar trend. 

Specifically, CAIS data indicate the number of children working in 

agriculture declined from an estimated 790,000 in 2004 to 524,000 in 

 60These estimates have margins of error of +/-52,000, +/-36,000, and +/-27,000, 

respectively. Detailed occupation information is presented in appendix IV.

61These two data sets are CPS, which is sponsored jointly by the Census Bureau and the 

Department of Labor’s Bureau of Labor Statistics, as well as CAIS, which is NIOSH’s 

collaborative effort with the U.S. Department of Agriculture’s National Agricultural 

Statistics Service (NASS).

62We also analyzed data from the National Agricultural Worker Survey (NAWS), which is 

specific to hired workers in crop agriculture. See appendix V for our analyses of this data 

set.

63These estimates have a relative standard error of 21 percent and 25 percent, 

respectively. For non-summer months, we estimate 2.4 percent of working children aged 

15 to 17 worked in agriculture in 2003, and 2.6 percent in 2017. These estimates have a 

relative standard error of 23 and 25 percent, respectively. See appendix II for additional 

results on our estimates of children working in agricultural industries from 2003 to 2017.

64CPS does not count as employed those children working less than 15 hours without pay 

for a family business. Further, because the CPS does not include workers aged 14 or 

under, it is not capturing the full population of children working in agriculture. BLS officials 

stated that CPS is not able to adequately identify the extent to which children are working 

in agriculture.

Federal Agencies Collect 

Some Information on 

Children Working in 

Agriculture
Page 24 GAO-19-26 Working Children

2014 (see fig. 3).65 The CAIS also collects information on children 

aged 17 and under working on U.S. farms who were members of the 

household (“working household children”). Our analysis of CAIS data 

indicate a substantial proportion of children working in agriculture are 

household children, which is a group that BLS officials stated is not 

fully represented in the CPS.66 Our analysis indicates the number of 

working household children decreased from more than 590,000 in 

2004 to 375,000 in 2014, the most recent year for which these data 

are available.67 Further, about two-thirds of these working household 

children—an estimated 246,000—were aged 14 and under in 2014. 

See appendix VI for detailed information regarding the characteristics 

of children working on U.S. farms.

 65These estimates have margins of error of 54,000 and 42,000, at the 95 percent 

confidence level, respectively.

66Our analysis of CAIS data indicates that in 2014, for example, more than 70 percent of 

working children aged 17 and under were working household youth. CAIS uses a different 

definition of household children from CPS. CPS counts as employed any child aged 15 or 

older who works 15 or more hours per week. For purposes of the CAIS, working 

household children are those who live and work on a farm owned by their parents, 

regardless of hours worked. CAIS collects data on hired labor (those working for pay), 

household labor (those living on the farm where they are working), and visitors (a visiting 

relative to the farm operation or a non-relative visitor). 

67These estimates have margins of error at the 95 percent confidence level of 19,500 and 

15,000, respectively. Our analyses of CAIS data also show that the proportion of working 

household children to hired children working on U.S. farms has remained relatively stable. 

For example, working household children comprised approximately 75 percent of all 

children working on farms in 2004, compared to approximately 71 percent in 2014.
Page 25 GAO-19-26 Working Children

Figure 3: Selected Federal Data on Children Working in Agriculture

Notes: The Childhood Agricultural Injury Survey was conducted in certain noncontiguous years and 

its estimates include information on children aged 17 and under who work in agriculture, including 

both hired workers and household workers (those living on the farm where they are working) or 

visitors (a visiting relative to the farm operation or a non-relative visitor) regardless of their pay status 

or household status. The Current Population Survey is an ongoing monthly survey and its estimates 

include children aged 15 to 17 working in agriculture and do not capture unpaid household workers 

working fewer than 15 hours per week. The estimates for CPS in the figure represent working 

children in summer months, which we defined as June, July, and August. CPS estimates have 

relative standard errors of 27 percent or less. The estimates for CAIS have relative standard errors of 

10 percent or less.
Page 26 GAO-19-26 Working Children

According to BLS’s Census of Fatal Occupational Injuries data, the 

annual number of work-related child fatalities has declined overall since 

2003. More specifically, BLS data show a decline from 53 fatalities among 

children aged 17 and under in 2003 to 14 fatalities in 2013, and then an 

increase to 30 fatalities in 2016, the most recent year of available data. 

This trend was also similar to the trend in the number of working children 

(as presented in fig. 1) and the number of hours worked by children aged 

15 to 17 during the same time period (see fig. 4).

Figure 4: Number of Work-Related Fatalities to Children Aged 17 and Under and Estimated Number of Hours Worked by 

Children Aged 15 to 17, 2003 to 2016

Notes: The number of annual hours worked is for children aged 15 to 17 because the Current 

Population Survey does not collect information for working children aged 14 or under. BLS officials 

stated the agency does not have research regarding standard errors for estimated total hours worked 

Children Working in 

Agriculture 

Comprised the 

Majority of WorkRelated Child 

Fatalities, and Data 

on Work-Related 

Injuries Are 

Incomplete

BLS Data Indicate WorkRelated Child Fatalities 

Have Generally Declined, 

and Agricultural 

Occupations Account for 

the Largest Percentage of 

Fatalities
Page 27 GAO-19-26 Working Children

for 15- to 17-year-olds, and did not provide guidance on how to calculate such standard errors. GAO 

did not calculate the standard errors for the number of annual hours worked.

Our analysis of Census of Fatal Occupational Injuries data found that 

certain groups of working children sustained disproportionately high 

percentages of work-related fatalities from 2003 to 2016. For example, 

while we estimated fewer than 5.5 percent of working children worked in 

agriculture in any year from 2003 to 2017,68 this population sustained 

more than 50 percent of all work-related child fatalities from 2003 to 2016.

According to available BLS data, fatalities were also disproportionately 

high among children aged 15 and under, children working in a family 

business, and among children working for an employer with 10 or fewer 

workers (see table 5).

Table 5: Percentage of Work-Related Child Fatalities from 2003 to 2016 Compared to Estimated Percentage of Children 

Working in Selected Categories, 2017 (Categories Are Not Mutually Exclusive)

Number of workrelated child 

fatalities, 2003 to 

2016

Percentage of that category 

of work-related fatalities to 

total fatalities

Estimated child 

workforce 

percentage, 2017

Children working in agriculture 237a 52 3b

Children aged 15 and under 197 44 7b

Children working in a family business 192 42 3c

Children working for employer with 10 or fewer 

workers

259d 76 Not availablee

Source: GAO analysis of Census of Fatal Occupational Injuries and Current Population Survey (CPS) data. | GAO-19-26

Notes: Estimates for children working in agriculture, children aged 15 and under, children working in a 

family business in the “Estimated child workforce percentage, 2017” column are for summer 

months—which we defined as June, July and August—and have relative standard errors of 25, 9, and 

18 percent, respectively. For 2017 non-summer months, our estimates of working youth aged 15 to 

17 indicate 3 percent of children worked in agriculture, 4 percent were 15-year-olds, and 3 percent 

were children working in a family business. These estimates have relative standard errors of 25, 8, 

and 15 percent, respectively.

a

This data point is for children aged 17 and under. For children aged 15 to 17 working in agriculture, 

there were 125 work-related fatalities from 2003 to 2016. Accordingly, fatalities to children working in 

agriculture accounted for 40 percent of all fatalities to children aged 15 to 17 during the time period.

b

CPS data do not include information on children aged 14 or younger. Thus, the estimate for children 

working in agriculture is for working children aged 15 to 17, and the estimate for working children 

aged 15 and under is for working 15-year-olds.

c

This estimate is for unpaid children aged 15 to 17 working in a family business and self-employed 

children. According to BLS, self-employed workers consist of individuals who are family members 

working in a family business, as well as those who are self-employed, self-employed contractors, and 

partners or owners of an unincorporated business, professional practice, or farm. BLS’s estimate for 

work-related child fatalities working in a family business includes paid and unpaid youth.

 68The relative standard errors for all years during the period were less than 25 percent.
Page 28 GAO-19-26 Working Children

d

Employer size was unknown for 25 percent of child fatalities.

e

We analyzed CPS Annual Social and Economic Supplement data and found that, of working 

children, an estimated 474,000 out of 2.4 million (or about 20 percent of) employed 15 to 17-year-olds 

work at firms employing 9 or fewer workers, and an estimated 604,000 out of 2.4 million (or 25 

percent of) working 15 to 17-year-olds worked at firms employing 10 to 49 workers in 2016. These 

estimates have margins of error of about 58,000 and 71,000, respectively. We were unable to 

estimate the percentage that worked at firms employing 10 or fewer workers because the Annual 

Social and Economic Supplement survey does not collect or capture that specific data point.

Although children working in agriculture make up a small proportion of 

working children,69 we found that from 2003 to 2016, 52 percent of workrelated fatalities among children aged 17 and under were in agriculture,70

with 32 percent in crop agriculture specifically. The construction, mining, 

quarrying, and oil and gas extraction industries accounted for 13 percent 

of child fatalities, as shown in figure 5. For detailed information on workrelated child fatalities by industry, see appendix VII.

 69In 2017, children aged 15 to 17 comprised an estimated 2.9 percent of the working child 

population in summer months, and an estimated 2.6 percent in non-summer months, 

according to our analysis. Both of these estimates have relative standard errors of 25 

percent. BLS does not provide information on children aged 14 or under who are working, 

and thus might be employed in agriculture.

70Agriculture, as classified in the North American Industry Classification System which is 

used by the CFOI, includes non-crop agriculture, for example the raising of livestock, fish, 

or other activities such as logging; it also includes crop agriculture, for example the 

planting and harvesting of fruits, vegetables, and other foods. See appendix VII for more 

detailed information regarding work-related child fatalities by sub-industry.

Children working in agriculture
Page 29 GAO-19-26 Working Children

Figure 5: Work-Related Child Fatalities, by Industry, 2003 to 2016

Notes: The total number of fatalities to children aged 17 and under from 2003 to 2016 was 452. The 

sum of individual categories totals 451. According to Bureau of Labor Statistics officials, categories 

may not sum to totals due to the exclusion of unpublishable data. Percentages of major categories do 

not total 100 due to rounding and the exclusion of unpublishable data. The professional, business, 

and other services category includes information, professional and business services, and other 

services except public administration. The government category includes federal government, local 

government, and public administration.

a

Construction and mining industry also includes quarrying, and oil and gas extraction.

As shown in table 6, children aged 15 and under comprised 44 percent of 

the work-related child fatalities from 2003 to 2016, and those aged 14 and 

under comprised 31 percent of fatalities during the same period. We 

estimated that children aged 15 comprised 7 percent of the child 

workforce (aged 15 to 17) during summer months, and 4 percent during 

non-summer months in 2017.71

 71These estimates have relative standard errors of 9 percent and 8 percent, respectively. 

Further, children employed in agriculture comprised 74 percent of work-related fatalities 

involving children aged 15 and under, according to BLS data.

Children aged 15 and under
Page 30 GAO-19-26 Working Children

Table 6: Number and Percentage of Work-Related Child Fatalities, by Age, 2003 to 

2016

Age Number of fatalities Percentage of 

work-related child 

fatalities

Cumulative 

percentage

12 and under 73 16 16

13 25 6 22

14 44 10 31

15 55 12 44

16 110 24 68

17 145 32 100

Total 452 100

Source: GAO analysis Census of Fatal Occupational Injuries (CFOI) data. | GAO-19-26

Notes: The cumulative percentage for children aged 14 and under is more precisely 31.4 percent. 

Summing the individually rounded percent fatalities to children aged 12 and under, 13 and under, and 

14 and under would total 32 percent, but we are presenting the cumulative percentage for workrelated fatalities to children aged 14 and under as 31, based on the original, non-rounded data.

Children working in a family business accounted for about 3 percent of all 

working children, but they represented about 42 percent of all workrelated fatalities to children aged 17 and under.72

This group accounted for 76 percent of the work-related child fatalities for 

which employer size was reported from 2003 to 2016, according to BLS 

data. According to BLS officials, in 25 percent (113 out of 452) of BLS’s 

reported work-related child fatalities, the size of establishment is 

unknown. Using CPS Annual Social and Economic Supplement data, we 

estimated that in 2016, 20 percent of working children aged 15 to 17 were 

 72This estimate is for unpaid children aged 15 to 17 working in a family business and selfemployed children. According to BLS, self-employed workers consist of individuals who 

are family members working in a family business, as well as those who are self-employed, 

self-employed contractors, and partners or owners of an unincorporated business, 

professional practice, or farm. BLS’s estimate for work-related child fatalities working in a 

family business includes paid and unpaid children.

Children working in a family 

business

Children working for employers 

with 10 or fewer workers
Page 31 GAO-19-26 Working Children

working at firms employing 9 or fewer workers and an estimated 25 

percent worked at firms employing 10 to 49 workers.73

We also analyzed the demographic characteristics of working children 

aged 17 and under who incurred work-related fatalities from 2003 to 

2016. Our analysis of BLS data indicated that boys incurred 87 percent of 

these fatalities.74 In addition, of those work-related fatalities that were 

reportable by race and ethnicity,75 Hispanic children incurred 20 percent 

of them, and white only children incurred 75 percent. Further, 

transportation incidents, such as a work-related collision on or off a 

roadway with a motorized vehicle, were the cause of the highest number 

of work-related fatalities to children aged 17 and under. See appendix VIII 

for detailed results of these demographic analyses.

The two primary sources of nationwide data on child work-related injuries 

and illnesses indicate similar trends in the number of injuries and 

illnesses since 2003, yet these sources differ substantially in the 

magnitude of their estimates and methodologies for determining the 

number of working children incurring such injuries or illnesses each 

year.76 For example, our analysis of both BLS’s Survey of Occupational 

Injuries and Illnesses and NIOSH’s National Electronic Injury Surveillance 

System—Occupational Supplement data sets indicates a decrease in the 

number of work-related injuries and illnesses that children incurred from 

2006 to about 2010. BLS’s estimates continue to decrease in 2011, and 

 73We were unable to estimate the percentage that worked at firms employing 10 or fewer 

workers because the ASEC survey does not collect or capture that specific data point. 

BLS officials stated that there may be some quality concerns with the employer size 

variable in the Annual Social and Economic Supplement—which is a household survey—

and that information regarding employer size would be better captured in a survey of 

employers. 

74Because some data do not meet publication criteria, BLS reported gender information 

for 451 of the 452 work-related fatalities to children from 2003 to 2016.

75Because some data do not meet publication criteria, BLS reported race and ethnic 

information for 451 of the 452 work-related fatalities to children aged 17 and under from 

2003 to 2016.

76The two primary sources of data for child work-related injuries and illnesses, as detailed 

in appendix I, are the Survey of Occupational Illness and Injuries, for which BLS collects 

information from a sample of employer records to estimate incidence rates and counts of 

workplace injuries and illnesses, and the National Electronic Injury Surveillance SystemOccupational Supplement, for which NIOSH collects data from a sample of U.S. hospital 

emergency departments on civilian workers who were injured on the job. 

The Estimated Number of 

Work-Related Injuries and 

Illnesses to Children Has 

Declined, but Data Have 

Limitations
Page 32 GAO-19-26 Working Children

then rise from 2012 through 2016. In contrast, NIOSH estimates do not 

have a discernable increase from 2011 through 2016. However, as shown 

in figure 6, NIOSH’s estimates of the number of work-related childhood 

injuries and illnesses are generally more than 5 times higher than BLS’s 

estimates.77

 77NIOSH’s National Electronic Injury Surveillance System-Occupational Supplement

estimated the number of work-related injuries to children aged 17 and under in 2016 to be 

26,300, with an associated margin of error at the 95 percent confidence level of +/-5,800. 

The margin of error of the 2010 estimate at the 95 percent confidence level (27,300 mean 

estimate) is +/-6,900.
Page 33 GAO-19-26 Working Children

Figure 6: Estimated Number of Work-Related Injuries and Illnesses to Children Aged 17 and Under (National Institute for

Occupational Safety and Health) and Aged 15 to 17 (Bureau of Labor Statistics), 2003 to 2016

Notes: BLS’s SOII data set is more specifically for children aged 15 to 17. BLS’s Survey of 

Occupational Injuries and Illnesses data presented here includes injuries or illnesses that resulted in 

one day of missed work. As shown in appendix IX, BLS also provided estimates for work-related 

injuries and illnesses to children aged 15 and under, which ranged from a low of 90, or 0.01 percent 

of all work-related injuries and illnesses resulting in a day way from work, to a high of 420, or 0.04 

percent of all work related injuries and illnesses to children resulting in a day away from work. 

NIOSH’s National Electronic Injury Surveillance System-Occupational Supplement (NEISS-Work) 

data set counts injuries to workers who sought treatment in one of the NEISS-Work sampled 

emergency departments for an occupational injury or illness. BLS officials stated that about 5 percent 

of its estimated injuries and illnesses to adults and children in private industry, and local and state 

government in 2016 were illnesses. NIOSH technical information notes that NEISS-Work data from 

2003 to 2014 include illnesses such as those that began at work (heart attacks or stroke), chronic 

conditions, and exacerbated long-term injuries; it estimates 5 to 10 percent of all cases were such 

illnesses. NEISS-Work data from 2015 on do not capture most illnesses. Margins of error for 

estimates at the 95 percent confidence level are shown by chart whiskers. For more details, see 

appendix IX.
Page 34 GAO-19-26 Working Children

Some of the differences in the estimates may be related to how the 

agencies collect the data. Specifically, BLS relies on surveyed employer 

records to collect its data—including detailed demographic data, such as 

the injured person’s age—for individual cases serious enough to cause 

workers to miss at least one day of work.78 It provides annual estimates 

for the number of work-related injuries and illnesses to children aged 17 

and under, and separately for children aged 15 and under.79 NIOSH 

estimates, based on emergency room records, include estimates for 

work-related injuries and illnesses to children aged 17 and under, and 

separately for children aged 14 and under. See appendix IX for annual 

BLS and NIOSH estimates of work-related injuries and illnesses to 

children.

BLS data indicate that the median number of days that children missed 

work due to work-related injuries and illnesses remained relatively 

constant from 2003 to 2016. According to BLS estimates, 42 percent of 

the work-related injuries and illnesses to children aged 17 and under in 

2016 required them to miss 1 or 2 days of work, and about 10 percent of 

the injuries during this period required them to miss 31 or more days. 

Unlike fatalities data, BLS injury and illnesses data show that in 2016, the 

industry that employed the most children aged 15 to 17—leisure and 

hospitality—had the most work-related injuries and illnesses to children 

aged 17 and under. For more detailed results, see appendix X.

 78BLS also collects information regarding a broad array of work-related injuries or 

illnesses from surveyed employers. It does not capture detailed case and demographic 

information regarding individual cases, such as the injured person’s age, gender, and 

race, unless the individual case is one that is serious enough to cause a worker to miss at 

least one day of work.

79BLS published some estimates for work-related injuries to 14-year-olds in certain years; 

for more information, see appendix IX. In October 2009, GAO found that disincentives for 

workers to report and for employers to record injuries affect the accuracy of BLS’s injury 

and illness data. See GAO, Workplace Safety and Health: Enhancing OSHA’s Records 

Audit Process Could Improve the Accuracy of Worker Injury and Illness Data, GAO-10-10 

(Washington, D.C.: Oct. 15, 2009).
Page 35 GAO-19-26 Working Children

NIOSH Childhood Agricultural Injury Survey (CAIS) data estimated that 

there were 4,774 work-related injuries to children aged 17 or under on 

U.S. farms, based on a combined estimate of its 2012 and 2014 data.80

CAIS data—which include both working household children aged 17 or 

under and children on farms employing 10 or fewer workers—also 

indicate that about half of the work-related injuries to children on U.S. 

farms are to those aged 14 and under (see table 7).

Table 7: National Estimates of Work-Related Injuries to Children Aged 17 and under 

on U.S. Farms, by Age Group

2004 and 2006 combined data on 

injuries (margin of error) 

2012 and 2014 combined data on 

injuries (margin of error)

Aged 10 and 

under 

2,400 (+/-1,085) 742a (+/-458)

Aged 14 and 

under 

5,385 (+/-1,611) 2,420 (+/-940)

Aged 15 to 

17 

5,067 (+/-1,346) 2,353 (+/-823)

Aged 17 and 

under

10,452 (+/-1,999) 4,774b (+/-1,191)

Source: Source: GAO analysis of Childhood Agricultural Injury Survey (CAIS) data for 2004, 2006, 2012, and 2014. | GAO-19-26

Notes: CAIS defines an injury as being any nonfatal traumatic event occurring on the farm operation 

resulting in at least 4 hours of restricted activity, or requiring professional medical treatment. CAIS 

defines a work injury as being any injury that occurred while performing work or chores on the farm 

(associated with the farm business), regardless of whether the work was performed for pay. NIOSH 

combined 2 years of CAIS data to produce an estimate with less than 33 percent relative standard 

error, and thus within NIOSH’s standards for reporting.

a

Estimate should be interpreted with caution because it has relative standard error of 32 percent.

b

Number does not total to sum of estimated number of children aged 14 and under and 15 to 17 due 

to rounding.

Further, CAIS data indicate that a substantial portion of work-related 

injuries to children on U.S. farms are incurred by children working in the 

 80CAIS defines an injury as being any nonfatal traumatic event occurring on the farm 

operation resulting in at least 4 hours of restricted activity, or requiring professional 

medical treatment. CAIS defines a work injury as being any injury that occurred while 

performing work or chores on the farm that was associated with the farm business, 

regardless of whether the work was performed for pay. NIOSH combined 2 years of CAIS 

data to produce an estimate with less than 33 percent relative standard error, and thus 

within NIOSH’s standards for reporting.

Injuries to Children 

Working in Agriculture
Page 36 GAO-19-26 Working Children

farm owner’s household, rather than children hired or visiting the farm.81

Table 8 provides further details.

Table 8: National Estimates of Work-Related Injuries to Household and NonHousehold Children Aged 17 or under on U.S. Farms

2004 and 2006 combined data

injuries (margin of error)

2012 and 2014 combined data

injuries (margin of error)

Household children 

aged 17 or under

4,722 (+/-1427) 3,258 (+/-1013)

Non-household 

children aged 17 or 

under

1,022 (+/-531) 1,516 (+/-706)

Source: GAO analysis of Childhood Agricultural Injury Survey (CAIS) data for 2004, 2006, 2012, and 2014. | GAO-19-26

Notes: While the estimated number of household children aged 17 or under incurring work-related 

injuries appears to decrease, and the estimated number of non-household children aged 17 or under 

incurring work-related injuries appears to increase from the 2004-2006 to 2012-2014 reporting 

periods, we cannot with confidence state that the trends are statistically reliable and instead note that 

there are no discernible trends. NIOSH combined 2 years of CAIS data to produce an estimate with 

less than 33 percent relative standard error, and thus within NIOSH’s standards for reporting. CAIS 

defines a household worker as a member of a farm operator’s household (farm operator, his/her 

spouse, child/step child).

In contrast to NIOSH’s Childhood Agricultural Injury Survey, BLS’s Survey 

of Occupational Illnesses and Injuries does not include data on two 

substantial groups of children working in agriculture: household children 

aged 17 or under and children working on farms employing 10 or fewer 

workers.82

BLS’s estimates of the proportion of work-related injuries and illnesses 

incurred by children working in agriculture are lower than the proportion of 

work-related child fatalities incurred by children working in agriculture. For 

example, BLS estimated that in 2016, children working in agriculture 

incurred about 1 percent of the estimated 4,760 injuries and illnesses to 

children in the workplace across all industries—while 52 percent of all 

work-related fatalities occurred among children working in agriculture 

 81CAIS defines a household worker as a member of a farm operator’s household (farm 

operator, his/her spouse, child/step child); a visitor as a visiting relative to the farm 

operation or a non-relative visitor; and a hired worker as being a paid worker or laborer 

hired directly by a farm operator. NIOSH officials we interviewed stated that they did not 

plan to conduct another CAIS and that compiling a sample large enough to meet statistical 

reporting thresholds as they have done in the past would result in a prohibitive cost.

82According to the U.S. Department of Agriculture’s Census of Agriculture, as of 2012, 

farms employing 10 or fewer hired workers employed about half of all agricultural workers.
Page 37 GAO-19-26 Working Children

(from 2003 to 2016).83 BLS officials told us that they did not have a 

definitive explanation for this difference, but noted that unlike its fatalities 

data set, many children working in agriculture were outside the scope of 

the agency’s injury and illness data set—such as those working for 

agricultural employers with 10 or fewer workers or household workers.84

BLS officials also stated that the nature of work-related injuries causing 

fatalities may be different than those resulting in nonfatal injuries; 

however, they said they did not know of any research examining this 

issue.

BLS officials said the agency has begun exploring ways to enhance the 

measurement and counting of work-related injuries and illnesses in its 

Survey of Occupational Injuries and Illnesses data and is conducting a

pilot Household Survey of Occupational Injuries and Illnesses for 2017 

and 2018, which surveys members of a household rather than employers. 

They expect results to be available at the conclusion of fiscal year 2019. 

The current pilot survey is aimed at determining the feasibility of fielding a 

statistically reliable sample of households with workers who may have 

experienced work-related injuries and illnesses. The pilot’s scope 

includes all workers in the United States 18 years and older who worked 

for pay or profit in the previous year. However, the pilot does not measure 

injuries and illnesses to children aged 17 and under, including household 

children and working children on farms employing 10 or fewer workers.85

BLS, within DOL, is the principal federal agency responsible for 

measuring labor conditions.86 Its mission is to collect, analyze, and 

disseminate essential economic information to support private and public 

decision making. BLS is responsible for producing accurate and 

statistically valid estimates of work-related injuries and illnesses at U.S. 

 83We chose to report the most current (2016) estimates of work-related injuries and 

illnesses to children; however, we also looked at estimates from 2003 to 2015.

84BLS officials told us that including data on such workers in its current employer-based 

Survey of Occupational Injuries and Illnesses would require obtaining approval from the 

Office of Management and Budget and publishing a notice in the Federal Register. The 

Paperwork Reduction Act provides that agencies may not conduct or sponsor the 

collection of information from 10 or more non-federal persons without first taking certain 

required steps, including allowing an opportunity for public comment and obtaining Office 

of Management and Budget approval, among other things. See 44 U.S.C. § 3507.

85BLS published some estimates for work-related injuries and illnesses to 14-year-olds in 

certain years, as shown in appendix IX.

86See generally 29 U.S.C. §§ 1-8.
Page 38 GAO-19-26 Working Children

workplaces.87 BLS injury and illness data collected via its Survey of 

Occupational Injuries and Illnesses are used by federal agencies and 

others to understand trends in worker health and safety. Federal 

standards for internal control state that agencies should use quality 

information to achieve agency objectives.88 These standards define 

quality information as appropriate, current, complete, accurate, 

accessible, and provided on a timely basis. BLS injury and illness data 

are not complete because they do not measure certain worker 

populations, including child household workers and those employed on 

farms with 10 or fewer workers. Without evaluating the feasibility of 

measuring injuries and illnesses to the aforementioned worker 

populations upon the completion of its pilot, DOL is missing opportunities 

to more accurately quantify injuries and illnesses to children, which could 

better inform its compliance and enforcement efforts. Further, BLS will not 

know the cost of collecting this information and whether it should explore 

other ways to get information on work-related injuries and illnesses to 

vulnerable child workers. BLS officials told us in an interview that, after 

completing the household survey pilot at the end of fiscal year 2019, they 

could consider the feasibility of enhancing reporting on certain 

populations that are currently not measured in the pilot.

 87Under the OSH Act, the Secretary of Labor is required to “compile accurate statistics on 

work injuries and illnesses which shall include all disabling, serious, or significant injuries 

and illnesses, whether or not involving loss of time from work, other than minor injuries 

requiring only first aid treatment and which do not involve medical treatment, loss of 

consciousness, restriction of work or motion, or transfer to another job.” 29 U.S.C. § 

673(a).

88GAO, Standards for Internal Control in the Federal Government, GAO-14-704G 

(Washington, D.C.: September 2014).
Page 39 GAO-19-26 Working Children

DOL’s Wage and Hour Division (WHD) uses a strategic enforcement 

approach to oversee compliance with the child labor provisions of the 

FLSA. This approach uses data to establish annual priorities and identify 

goals for investigations—agency-initiated (directed) and those initiated 

from complaints (complaint-based)—and compliance assistance, 

including outreach. Specifically, WHD uses data to create strategic 

initiatives, which include both enforcement and outreach activities, that 

focus on the working conditions of vulnerable workers, including children, 

and the industries that employ them.89 Officials from WHD’s national 

office told us they use complaint data from their internal investigation 

database (WHISARD) and CPS data to determine priority industries for 

outreach and investigations. In addition, WHD officials use federal data, 

such as CPS data, to assess labor market trends affecting vulnerable 

workers.90

WHD officials told us that child labor is an enforcement priority and child 

labor complaints from the public—particularly those involving hazardous 

working conditions—are assigned to a WHD investigator for immediate 

action. For example, one WHD investigator described going to a worksite 

 89For purposes of its enforcement and compliance assistance efforts, WHD defines 

vulnerable worker populations as those who are at higher risk of exploitation by employers 

or less likely to submit complaints in response to employer violations of worker 

protections, such as workers with disabilities, young workers, agricultural workers, and 

workers with no private right to pursue remedies on their own behalf.

90Officials stated that priority industries are those with a high prevalence of minimum wage 

and overtime violations, and those in which workers experiencing violations are less likely 

to complain. Officials stated that WHD’s priority industry list includes those industries 

employing children and those with historically high violations, such as retail, hospitality, 

and food service.

DOL Uses a Strategic 

Enforcement 

Approach to Oversee 

Compliance with 

Federal Child Labor 

Law, but Some 

Limitations Exist

DOL’s Child Labor 

Enforcement Approach 

Includes Targeted 

Investigations and 

Outreach, but It Has Not 

Evaluated These Efforts

Investigations
Page 40 GAO-19-26 Working Children

to conduct an investigation into a child labor complaint within 2 hours of 

receiving the complaint. In addition, WHD officials told us that 

investigators look for potential child labor violations in every full 

investigation they conduct under the FLSA.91 For example, five of six 

WHD investigators we spoke with told us they include specific questions 

in their interviews with employers and workers, which are designed to 

uncover potential child labor violations during worksite visits. WHD 

guidance also instructs investigators to look for the presence of children 

and the pieces of equipment covered by hazardous occupations orders 

when conducting worksite visits.

WHD officials we interviewed said that, as of 2010, child labor had been 

incorporated within the agency’s broader FLSA investigatory activity, and 

our analysis of WHISARD data indicates that there has been a general 

decline in its child labor-specific investigations since 2010. According to 

our analysis of WHISARD data, the trends in the number of FLSA 

investigations and the number of investigations with a child labor 

component generally aligned from fiscal years 2010 to 2016. During the 

same period, our analysis shows a decline in investigations primarily 

focused on child labor from fiscal years 2010 to 2015, with a slight 

increase in 2016 (see inset of fig. 7). Further, the number of investigations 

that found child labor violations stayed about the same, with a slight dip in 

fiscal years 2014 and 2015.92

 91WHD registers each investigation for internal WHD tracking purposes under the specific 

act that is the focus of the investigation, but the investigation may also cover other acts 

that WHD is responsible for enforcing. WHD may conduct several types of investigations 

including full investigations, in which investigators look for child labor violations as one 

part of the investigation, or limited investigations, such as one focused primarily on 

enforcing the child labor provisions (or other provisions) of the FLSA. WHD may find child 

labor violations in all types of investigations.

92WHD may assess civil monetary penalties for child labor violations. The amount of the 

penalty depends on various factors, such as the size of the business and the gravity of the 

violations. WHISARD data indicate that the total amount of child labor civil monetary 

penalties assessed generally decreased from a high of $2.9 million for investigations 

concluded in fiscal year 2010 to a low of $1.4 million in fiscal year 2015. For investigations 

that concluded in fiscal year 2016, WHD assessed $1.9 million in child labor civil monetary 

penalties. 
Page 41 GAO-19-26 Working Children

Figure 7: Wage and Hour Division (WHD) Investigation and Child Labor Violation Trends, Fiscal Years 2010 to 2016

Notes: In addition to the Fair Labor Standards Act (FLSA), WHD enforces multiple other statutes, 

such as the Family and Medical Leave Act, among others. In this figure, “total WHD investigations”

includes all investigations conducted under the authority of any of the laws enforced by WHD. Any 

WHD investigation may include a child labor component if a WHD investigator checks for potential 

child labor violations during the investigation, and child labor violations may be found during any 

WHD investigation. Not all FLSA investigations include a child labor component because some are 

limited investigations, which may focus on enforcing other provisions of the FLSA.
Page 42 GAO-19-26 Working Children

Child labor violations have been found across many industries, often in 

investigations that are not specifically focused on child labor. As 

previously noted, the industries in which children most commonly work 

are leisure and hospitality; wholesale and retail; and professional and 

other services, financial activities, and information. According to our 

analysis of WHISARD data for fiscal years 2010 to 2016, WHD found 

most child labor violations in the leisure and hospitality and wholesale and 

retail industries (see fig. 8). As illustrated in figure 8, WHD also found 

violations across other industries including those that employ substantially 

fewer children, such as construction and mining.93

Figure 8: Wage and Hour Division Investigations That Found a Child Labor Violation, by Industry, Fiscal Years 2010 to 2016

a

Professional and other services, financial activities, and information includes professional, scientific, 

and technical services, among others, as well as finance and real estate, and information.

b

Construction and mining also includes quarrying, and oil and gas extraction.

The most common child labor violations WHD found across all industries 

for this period were related to (1) hours standards, non-agricultural; (2) all 

prohibited occupations, non-agricultural; and (3) recordkeeping, such as 

 93Construction and mining also includes quarrying, and oil and gas extraction.
Page 43 GAO-19-26 Working Children

employer failure to maintain records of a child worker’s date of birth (see 

fig. 9).94

Figure 9: Number of Investigations That Found Child Labor Violations across All Industries, by Type, Fiscal Years 2010 to 

2016

Notes: Categories are not mutually exclusive because an investigation may find more than one type 

of violation. The “other violations” category includes investigations that found violations for shipping of 

goods in interstate commerce that have been produced in violation of the child labor provisions, 29 

U.S.C. § 212(a). “Other” and “recordkeeping” violations may be found in both agricultural and nonagricultural investigations. We also excluded 13 investigations that found a child labor violation but 

did not identify the type.

WHD Community Outreach and Resource Planning Specialists support 

WHD’s strategic enforcement approach in the field offices by conducting 

compliance assistance outreach to stakeholder groups associated with 

 94With respect to an employee subject to the FLSA’s minimum wage provisions or both 

the minimum wage and overtime pay provisions, employers are required to maintain and 

preserve records containing certain information, including the employee’s date of birth if 

the employee is under age 19. 29 C.F.R. § 516.2(a)(3).

Outreach
Page 44 GAO-19-26 Working Children

WHD’s priority industries.95 These outreach and planning specialists aim 

to increase voluntary compliance with the child labor provisions of the 

FLSA and other worker protections. Outreach specialists shared 

examples of these efforts, such as providing child labor and FLSA 

presentations and materials to stakeholders, including associations

representing employers or teachers, and disseminating information to 

high schools about DOL-approved apprenticeship programs and the 

applicable hazardous occupations orders and exemptions.

Outreach and planning specialists told us that they also stay informed 

about workplace conditions in the community, particularly those affecting 

children, through their outreach efforts. For example, one specialist told 

us that they contact stakeholders in a specific industry in part to gather 

information on potential violations and compliance issues while also 

raising awareness about WHD’s enforcement role. Another outreach and 

planning specialist discusses child labor at interagency trainings held on 

farms, and has received some worker complaints at these events.

Over time WHD has emphasized the importance of its outreach efforts 

related to child labor in agriculture to varying degrees. In 2012, when DOL 

withdrew its proposed revisions to the agricultural child labor regulations, 

DOL stated that it would conduct outreach to agricultural stakeholders, 

such as professional farming organizations.96 In addition, from fiscal years 

2011 to 2014, WHD gave explicit guidance to field offices to incorporate 

child labor-related efforts in agriculture.

However, WHD has not included child labor-related outreach efforts in 

agriculture in its guidance to the field since fiscal year 2014, and officials 

could not identify other directives asking its field staff to focus more on 

child labor in agriculture. Further, five of the six field office outreach and 

planning specialists we interviewed could not identify WHD agriculture 

outreach conducted specifically in response to the 2012 proposed rule 

 95In addition to the national office, WHD operates offices at the regional, district, area, and 

field levels. For the purposes of this report, we generally refer to all WHD offices outside of 

the national office as “field offices,” unless otherwise noted. 

96Child Labor Regulations, Orders and Statements of Interpretation; Child Labor 

Violations—Civil Money Penalties, 77 Fed. Reg. 31,549 (May 29, 2012).
Page 45 GAO-19-26 Working Children

withdrawal.97 While WHD established a metric for the number of outreach 

events involving child labor in 2018, it has not developed metrics and 

associated targets for a desired level of child labor outreach in agriculture, 

where our analysis of federal data shows a disproportionate amount of 

injuries to and fatalities of working children. Federal internal controls state 

that management should define objectives clearly to enable the 

identifications of risks, such as by defining objectives in specific and 

measurable terms to enable the design of internal control for related risks. 

Without establishing metrics and associated targets for child labor-related 

outreach in agriculture, WHD may not be effectively addressing the risk 

faced by children working in agriculture or helping to reduce their injuries 

and fatalities.

In addition, WHD has not conducted an evaluation of the effectiveness of 

its overall child labor enforcement approach since implementing the 

strategic enforcement program in 2010, which would allow WHD to draw 

conclusions about the impact or outcomes of outreach and enforcement 

activities on employers or working children. WHD officials said that they 

have used a variety of tools and techniques to evaluate progress and 

guide continuous program improvement, such as developing communities 

of practice across field offices. WHD has also had a performance metric 

for child labor in place from fiscal year 2011 to 2017, which assessed the 

extent to which WHD investigators checked for child labor violations 

during an investigation.98 However, this metric would not allow WHD to 

assess whether its child labor enforcement strategies were achieving their 

desired outcomes, nor would it allow WHD to determine the extent to 

which it was investigating establishments where substantial numbers of 

 97In July 2018, WHD officials provided us with the number of agriculture outreach events 

from fiscal year 2011 to fiscal year 2015. However, they were not able to identify which of 

these events focused on child labor. WHD officials stated that, prior to fiscal year 2017, 

WHD field staff may not have added a secondary “child labor” designation to agricultural 

outreach, because they usually cover child labor during agricultural outreach 

presentations. As a result, we were not able to accurately assess the relevance and the 

meaning of the data provided for child labor outreach in agriculture from fiscal years 2011 

to 2015.

98In fiscal year 2011, WHD identified two primary performance metrics for child labor: (1) 

the number of investigations in which child labor is examined, and (2) the percent of 

enforcement time devoted to child labor. From fiscal years 2012 to 2017, WHD identified

one primary performance metric for child labor: the percent of investigations in which child 

labor is examined.
Page 46 GAO-19-26 Working Children

children work.99 Under federal standards for internal control, management 

should design control activities to achieve objectives and respond to risks, 

such as by comparing actual performance to planned or expected results 

and analyzing significant differences.100 Without developing additional 

performance metrics, or other measures specific to its child labor 

enforcement approach, WHD cannot determine whether its investigations 

are conducted at establishments where children are likely to be working, 

and effectively targeting its limited resources.

WHD aims to supplement its internal investigation data with external 

data—including state, local, and other federal data sets—to identify 

compliance targets for its strategic enforcement approach. According to 

WHD officials, field offices plan initiatives at the beginning of the fiscal 

year to allocate resources for investigations and outreach. WHD directs 

field offices to use a range of evidence, including data, to develop these 

initiative plans, which reflect where each office expects to have the 

greatest impact, including finding violations.

According to WHD officials, they have used trend data from WHISARD, 

based on past investigation data patterns, to determine future 

enforcement and compliance activity. However, WHD national office 

officials we interviewed said WHISARD is not suited for targeting future 

enforcement action because, as an administrative database, it 

appropriately reflects past decisions and outcomes that are not 

generalizable to the general population. Further, officials told us that 

WHISARD should not be used for predictive enforcement planning as it 

does not describe current labor market conditions and anticipate future 

labor trends. However, WHD field staff in five of the six district offices we 

reviewed told us that they partly rely on WHISARD data for developing 

enforcement and compliance targets.

To supplement WHISARD data, WHD has been using external data 

sources to inform enforcement and compliance planning since 

approximately 2009. In addition, WHD national office officials reported 

 99In 2017, DOL’s Chief Evaluation Office contracted for an external evaluation examining 

the efficiency and effectiveness of WHD’s overall enforcement approach and compliance 

assistance outcomes. DOL officials told us that this evaluation will not be examining 

outcomes specific to child labor, as WHD intends to apply any insights gained from the 

evaluation into its compliance assistance across all of its program areas.

100GAO-14-704G.

WHD Incorporates Data 

into Its Child Labor 

Compliance Strategies

WHD internal investigation 

data

State and local data
Page 47 GAO-19-26 Working Children

creating a data team in 2016 to implement multiple data strategies for the 

agency, including the use of external data sources for enforcement 

planning. This data team provides data training and other support 

services to field staff, such as identifying data sources available to answer 

research questions, according to WHD officials.

WHD’s outreach and planning specialists use information from other data 

sources—including stakeholders—to help identify enforcement and 

compliance targets in local field offices. For example, one specialist told 

us that some of the data sources they use for strategic planning and 

developing initiatives include (1) local economic data, (2) information from 

community stakeholders, (3) reports from industry groups and employer 

associations, and (4) discussions with business roundtables. Another 

outreach and planning specialist told us they use workplace injury data 

collected by a state agency to monitor trends in demographic 

characteristics and employing industries. The specialist said they used 

these data to inform the field office’s decision to focus on the local 

restaurant and hospitality industry. In two districts, outreach and planning 

specialists told us they collaborate with local educational stakeholders, 

such as an association representing high school employment counselors,

to identify where children are working and inform local strategic efforts for 

child labor compliance.

Some WHD planning staff also use other federal data sources, such as 

BLS data sets, to identify enforcement and compliance targets. One 

outreach and planning specialist we met with uses federally compiled 

county specific data from the Census Bureau to assess the local 

prevalence of different industries to help inform the district office’s 

strategic enforcement. These data in conjunction with BLS data sets 

facilitated efforts to monitor local employment trends in traditional lowwage industries—such as retail and food service—overall as well as to 

track emerging trends in the local labor market. One WHD region is 

piloting a team of regional data experts that identifies and reviews federal 

data sets, among others, and helps staff incorporate useful data into their 

work. WHD officials also stated that they have reviewed BLS injury and 

illness data for general information on industries where children are being 

hurt, but the survey’s sample size limits WHD’s ability to use the data for 

more specific information on injuries and illnesses to working children. As 

noted earlier in the report, the BLS injury and illness data has some 

limitations regarding data on working children, including those working in 

agriculture, and exploring ways to more comprehensively measure 

injuries and illnesses to children could inform WHD’s strategic approach 

on how to focus their compliance and enforcement efforts.

Other federal data
Page 48 GAO-19-26 Working Children

WHD has recently begun providing training to key planning staff on the 

use of external data sources. WHD national office officials told us that in 

order to encourage field staff to use external data more consistently; they 

intend to offer more training on available external data sources. In 

addition, WHD officials stated that the data resources used by each of 

WHD’s five regions may vary based on the different competencies of field 

staff in terms of analyzing and using external data. As part of its planning 

for fiscal year 2019, WHD provided training on the use of external data in 

June 2018, and officials stated that training on external data sources 

would evolve as field office staff and WHD officials learn of promising 

practices with data.

WHD and OSHA are each responsible for enforcing certain federal 

workplace protections and have an agreement to coordinate and share 

information. OSHA inspectors conduct worksite inspections to enforce 

occupational health and safety standards, but they are not responsible for 

enforcing potential child labor violations, which are WHD’s responsibility. 

However, when OSHA inspectors discover information indicating potential 

child labor violations, they may refer the cases to WHD. WHD and OSHA 

currently have a memorandum of understanding, which was signed in 

1990, to facilitate coordination by establishing a referral system to convey 

complaints and information about potential violations between the two 

agencies. The memorandum of understanding documents policies WHD 

and OSHA have agreed to implement to coordinate their enforcement and

compliance efforts. These policies include, among other things, (1) 

providing field personnel with information and training on the types of 

issues that will be referred; (2) evaluating referrals on a priority basis and 

taking appropriate action; (3) transmitting to the other agency the results 

of inspections conducted in response to referrals; (4) establishing a 

system to monitor the progress of actions taken on referrals; and (5) 

conducting periodic meetings to report on the progress of actions taken 

on the other agency’s referrals and evaluate the system.

WHD and OSHA staff told us that they exchange information with each 

other informally, and both agencies acknowledged the importance of 

collaboration in their memorandum of understanding. Some WHD field 

officials told us their offices maintain informal relationships with their 

counterparts in local OSHA field offices, which include exchanging 

referrals, sharing information, and, in some instances, coordinating on 

investigations. WHD field officials from every region we spoke with said 

their offices receive referrals or information from OSHA. For example, one 

district official told us that their office occasionally coordinates with OSHA 

WHD Does Not 

Consistently Collaborate 

with the Occupational 

Safety and Health 

Administration in Its Efforts 

to Ensure Compliance with 

Federal Child Labor Law
Page 49 GAO-19-26 Working Children

to exchange referrals and assist with investigations. Another district 

official told us they meet with officials from the local OSHA office to 

discuss violation trends and national targeting guidance.

Although the memorandum of understanding between WHD and OSHA 

states that the agencies will establish a system to monitor the progress of 

actions taken on referrals, WHD and OSHA officials told us they do not 

have a systematic way to do so. Specifically, they have no formal 

systems or consistent processes for tracking or monitoring referrals. 

Further, WHD officials told us that their internal investigations system 

does not have a way to easily track and systematically report on the 

disposition of referrals from OSHA.101 In addition, OSHA officials told us 

that they do not systematically track referrals made to WHD. OSHA 

officials told us that their field officials may periodically meet with their 

WHD counterparts, but there is no formal requirement to do so, nor any 

requirements to document such discussions. Further, WHD and OSHA 

officials acknowledged that they have not updated their memorandum of 

understanding since the original 1990 agreement. We have reported that 

agencies can strengthen their commitment to work collaboratively by 

developing ways to continually update and monitor written agreements.102

While the memorandum of understanding between WHD and OSHA 

provides a framework for sharing information, updating the memorandum 

of understanding and establishing procedures for WHD and OSHA when 

monitoring the exchange of and actions taken on referrals can help 

ensure agency officials better track the disposition of referrals. Without 

such documentation, WHD and OSHA lack the ability to ensure that they 

consistently take appropriate action to protect children from unsafe 

working conditions.

For many children, working can result in benefits such as independence 

and responsibility. However, work may also interfere with their education 

or present a physical danger to children working in certain industries, 

such as agriculture. Since our 2002 report, the overall number of working 

children in the United States has varied and, since 2011, data indicate 

that the number of children working is increasing. While most children do 

 101According to WHD national officials, while a data element for OSHA referrals exists 

within WHISARD, this data element has not been included in WHD reports and it is not

widely known or used by field staff.

102GAO, Managing for Results: Key Considerations for Implementing Interagency 

Collaborative Mechanisms, GAO-12-1022 (Washington, D.C.: Sept. 27, 2012).

Conclusions
Page 50 GAO-19-26 Working Children

not suffer injuries at work, our analyses of BLS data show that injuries to 

and fatalities among working children persist, that children in agriculture 

comprise more than half of work-related fatalities, and work-related 

fatalities among children have increased since 2013. However, BLS data 

on work-related injuries and illnesses do not measure certain 

populations—such as children working on farms with 10 or fewer workers 

and household workers, and its pilot household-based injury survey does 

not include children aged 17 and under. Without improved data regarding 

injuries and illnesses to working children in the United States, DOL will 

not have the information necessary to reliably identify types of 

establishments with a high number of work-related injuries to children, 

such as farms employing with 10 or fewer workers.

WHD officials said they have made it a priority to enforce the child labor 

provisions of the FLSA, and since 2010 they have been using available 

data to inform their strategic approach to enforcement and compliance. 

WHD has recently begun increasing the resources available to field staff 

regarding how to analyze and use external data in their enforcement and 

compliance planning, according to officials—and these efforts will 

continue to be critical to WHD’s strategic approach. However, WHD has 

not yet taken actions to determine whether its strategic efforts are paying 

off. For example, WHD has not yet developed metrics and targets for 

outreach efforts related to children working in agriculture, nor has it 

developed performance metrics specific to its strategic approach on child 

labor. In addition, WHD and OSHA have not updated their memorandum 

of understanding or established current procedures for monitoring 

referrals exchanged between the two agencies or actions taken in 

response. Establishing metrics for goals within the strategic enforcement 

approach could help ensure that actions are yielding results and children 

can safely work in a variety of industries, particularly agriculture.

We are making four recommendations to DOL:

The Acting Commissioner of the Bureau of Labor Statistics should, upon 

completion of the pilot Household Survey of Occupational Injuries and 

Illnesses, evaluate the feasibility of measuring injuries and illnesses to 

certain worker populations—specifically, children aged 17 and under, 

child household workers, and those employed on farms with 10 or fewer 

workers—in any final survey scope, or determine a way to gather 

information on these populations. (Recommendation 1)

Recommendations for 

Executive Action
Page 51 GAO-19-26 Working Children

The Administrator of the Wage and Hour Division should establish 

specific metrics and associated targets for child labor-related outreach in 

agriculture. (Recommendation 2)

The Administrator of the Wage and Hour Division should develop 

performance metrics or other measures specific to its child labor

enforcement approach, such as whether WHD investigations are 

conducted at establishments where children are likely to be working. 

(Recommendation 3)

The Administrator of the Wage and Hour Division and the Assistant 

Secretary of the Occupational Safety and Health Administration should 

update and routinely monitor the 1990 WHD and OSHA memorandum of 

understanding and establish documented procedures for monitoring the 

exchange of and actions taken on referrals. (Recommendation 4)

We provided a draft of this report to the Departments of Health and 

Human Services (HHS) and Labor (DOL) for review and comment. DOL’s 

Occupational Safety and Health Administration (OSHA) provided written 

comments that are reproduced in appendix XI. DOL’s Wage and Hour 

Division (WHD) provided written comments that are reproduced in 

appendix XII. HHS did not provide written comments on our report. HHS 

and DOL provided technical comments, which we incorporated in the 

report, as appropriate.

In its technical comments, DOL’s Bureau of Labor Statistics (BLS)

generally agreed with the recommendation that it evaluate the feasibility 

of measuring injuries and illnesses to certain worker populations—

specifically, children aged 17 and under, child household workers, and 

those employed on farms with 10 or fewer workers—in any final survey 

scope, or determine a way to gather information on these populations. 

However, BLS stated that its ability to complete a feasibility study is 

subject to budget availability. We note that this recommendation also 

allows for alternate ways, other than a feasibility study, to determine how 

best to gather information on these populations of working children, and 

maintain that it is important to do so. Given the importance of this issue, 

we encourage BLS to explore cost-effective ways to implement this 

recommendation.

In its written comments, DOL’s Wage and Hour Division stated that it 

agreed with our second recommendation to establish specific metrics and 

associated targets for child-labor related outreach in agriculture. WHD 

Agency Comments 

and Our Evaluation
Page 52 GAO-19-26 Working Children

noted that it has existing performance measures that separately track the 

number of employer outreach events and the number of events involving 

child labor, and that a new, combined metric would provide an additional 

incentive for WHD field offices to conduct child labor-related outreach 

events in agriculture. WHD generally agreed with the third 

recommendation, which originally recommended that WHD develop a 

performance metric specific to its child labor enforcement approach. In its 

written comments, WHD agreed that it could develop either an internal 

performance metric or new planning guidance and reporting requirements 

to ensure that WHD’s child labor enforcement efforts focus on industries, 

establishments, and time periods in which children are likely to be 

working or injured. Although we agree that planning guidance and 

reporting requirements can encourage field office staff to focus more on 

child labor; we continue to believe it is important to include a 

measurement of WHD’s overall child labor enforcement approach as part 

of any new planning guidance and reporting requirements. We have thus

broadened the recommendation to include other measures. 

WHD and OSHA generally agreed with our fourth recommendation, to 

update the memorandum of understanding between WHD and OSHA and 

establish documented procedures for monitoring the exchange of and 

actions taken on referrals. Specifically, WHD and OSHA agreed to work 

together to review and update their memorandum of understanding and to 

evaluate the efficacy of the existing referral process, and propose actions 

to improve the process as appropriate. While WHD and OSHA correctly 

observe that we do not identify any instances where WHD or OSHA failed 

to take action on a referral, we also note in the report that the agencies 

have no formal systems or consistent processes for tracking or monitoring 

referrals. As we stated in our report, we believe that without establishing 

documented procedures for tracking the disposition of referrals, WHD and 

OSHA cannot ensure that they are consistently taking appropriate action 

to protect children from unsafe working conditions.

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies to the appropriate 

congressional committees, the Secretary of the Department of Health and 

Human Services, and the Secretary of the Department of Labor. In 

addition, the report will be available at no charge on the GAO website at 

http://www.gao.gov.
Page 53 GAO-19-26 Working Children

If you or your staff have any questions about this report, please contact 

us at (202) 512-7215 or brownbarnesc@gao.gov or at (202) 512-3841 or 

morriss@gao.gov. Contact points for our Offices of Congressional 

Relations and Public Affairs may be found on the last page of this report. 

GAO staff who made key contributions to this report are listed in appendix 

XIII.

Cindy Brown Barnes

Director, Education, Workforce and Income Security

Steve D. Morris

Director, Natural Resources and Environment
Appendix I: Objectives, Scope, and 

Methodology

Page 54 GAO-19-26 Working Children

To identify what is known about children working in the United States, 

including those working in agriculture,1 we obtained and analyzed 

monthly and yearly data from two national data sets from the Department 

of Labor (DOL):

• Bureau of Labor Statistics’ (BLS) Current Population Survey (CPS)2

from 2003 to 2017, and

• Employment and Training Administration’s National Agricultural 

Workers Survey (NAWS) for 2003 to 2016.3

We also collected information from two other sets of survey data for 

certain non-contiguous years:

• Department of Health and Human Services’ National Institute for 

Occupational Safety and Health’s (NIOSH) Childhood Agricultural 

Injury Survey (CAIS), and

• U.S. Department of Agriculture’s (USDA) National Agricultural 

Statistics Service’s Census of Agriculture.

The years of data we analyzed varied by data source, based on the 

availability of data and the number of cases needed to develop national 

estimates (see table 9).

Table 9: Data Sources Used in GAO Analyses for Objective I

Data file Organization responsible Type of information in file used in 

analyses

Population GAO 

examined

Time frame 

covered by data

Current Population 

Survey (CPS), 

including its 

Annual Social and 

Economic 

Supplement 

(ASEC)

Department of Labor 

(DOL)’s Bureau of Labor 

Statistics (BLS); Census 

Bureau

Hours, occupations, and industries in 

which children worked; and 

demographic characteristics of child 

workforce, including gender, race and 

ethnicity, and low-income status

Children aged 15 to 17 2003 to 2017a

 1

None of the analyses in this report are intended to assess compliance with the Fair Labor 

Standards Act (FLSA). Among other reasons, the definitions of terms used in these data 

sets may not be the same as the definitions in the FLSA and DOL’s regulations.

2

CPS is sponsored jointly by BLS and the Census Bureau.

3

NAWS data are organized by fiscal year.

Appendix I: Objectives, Scope, and 

Methodology

Objective I Data Sources
Appendix I: Objectives, Scope, and 

Methodology

Page 55 GAO-19-26 Working Children

Data file Organization responsible Type of information in file used in 

analyses

Population GAO 

examined

Time frame 

covered by data

National 

Agricultural Worker 

Survey (NAWS)

DOL’s Employment and 

Training Administration

Age first worked in agriculture, 

demographic characteristics of child 

hired agricultural labor workforce, 

including gender, race and ethnicity, 

poverty status, experience mixing and 

applying pesticides

Hired farm workers in 

crop agriculture, aged 

14 to 17

Fiscal years 2003

to 2016

Childhood 

Agricultural Injury 

Survey (CAIS)

Department of Health and 

Human Services’ National 

Institute for Occupational 

Safety and Health (NIOSH)

Number and characteristics of children 

on farms who worked

Household and hired 

children aged 17 and 

under on U.S. crop or 

livestock farms

2004, 2006, 

2009, 2012, 

2014b

Census of 

Agriculture

U.S. Department of 

Agriculture’s National 

Agricultural Statistics 

Service

Number of farms that employ 10 or 

fewer workers

All farm operations 2002, 2007, 2012

Source: GAO analysis of various data sets. | GAO-19-26

a

We analyzed data from the 2017 ASEC, which provides information about the industries and 

occupations that children reported they were working in, as well as about working children families’

low-income status during the prior year (i.e., calendar year 2016).

b

The CAIS was conducted in 2001, 2004, 2006, 2009, 2012, 2014. This report’s scope is from 2003 

onward.

The CPS is the primary source of federal government statistics on 

employment and unemployment in the United States. The basic monthly 

survey collects information on employment, such as employment status, 

occupation, and industry, as well as demographic characteristics, among 

other things. The survey is based on a sample of the civilian, noninstitutionalized population of the United States. About 55,000 households 

are interviewed monthly based on area of residence, to represent 

individual states and the country as a whole.4 In addition to the standard 

questions from the basic CPS monthly survey, the Annual Social and 

Economic Supplement (ASEC) includes additional questions of 

households and provides supplemental data on work experience; income 

components, such as earnings from employment; and noncash benefits, 

such as health insurance coverage, among other things. ASEC data on 

employment and income refer to the preceding calendar year, although 

demographic data refer to the time of the survey. This report used data 

from the March 2017 ASEC, which refers to employment and income 

during calendar year 2016.

 4

The total sample also includes additional households that are not interviewed for various 

reasons, such as not being reachable.
Appendix I: Objectives, Scope, and 

Methodology

Page 56 GAO-19-26 Working Children

DOL’s NAWS is an employment-based, annual survey of demographic, 

employment, and health characteristics of hired farm workers in crop 

agriculture, including crop workers, workers at nurseries, workers at 

packing houses,5 and includes workers brought to farms by contractors. 

NAWS does not include animal agricultural workers, unpaid household 

workers, or H-2A visa workers.6 Each year, approximately 1,500 workers 

are randomly selected for an interview. Interviews are conducted three 

times per year to account for the seasonal and regional fluctuations of 

agricultural production and employment. All interviews are conducted in 

person and the interviewer documents respondents’ answers directly on 

the paper questionnaire. Respondents are generally interviewed directly 

at their work site, and only currently employed persons are interviewed.

The CAIS farm operator survey is a NIOSH collaborative effort with the 

U.S. Department of Agriculture’s National Agricultural Statistics Service 

(NASS) to produce national and regional estimates of the number of 

individuals under age 20 on U.S. operated farms by various demographic 

characteristics.7 NIOSH has collaborated with NASS to collect injury and 

demographic data regarding farm workers aged 20 and under via the 

CAIS for certain years, including the years 2001, 2004, 2006, 2009, 2012, 

and 2014. From 2001 through 2012, CAIS was based on a sample of 

50,000 U.S. farm operations from the Census of Agriculture, which was 

increased to 75,000 farming operations for the 2014 survey. For this 

report, we analyzed CAIS results for children aged 17 and under from the 

2004 to 2014 surveys. Estimates include household children (a member 

of a farm operator’s household), hired children (a paid worker hired 

directly by a farm operator), and visiting child (a visitor to the farm, 

whether a relative or not).

The Census of Agriculture is sponsored by the USDA’s National 

Agricultural Statistics Service (NASS), and collects information about any 

operation from which $1,000 or more of agricultural products were 

 5

Packing and canning operation workers are eligible to be interviewed if the operation is 

adjacent to or located on the contacted employer’s farm and at least 50 percent of the 

produce being packed or canned originated from the employer’s farm.

6

An H-2A visa is a temporary work visa for foreign agricultural workers with a job offer for 

temporary or seasonal agricultural work in the United States. The H-2A visa program is 

generally open to nationals of countries that the Secretary of Homeland Security has 

designated as eligible to participate and that list is renewed annually. 

7

CAIS defines a farm as being any crop and/or livestock operation with $1,000 or more of 

gross agricultural production within a calendar year.
Appendix I: Objectives, Scope, and 

Methodology

Page 57 GAO-19-26 Working Children

produced and sold, or normally would have been sold, during the census 

year. To do this, NASS creates a list of agricultural operations that 

potentially meet the definition of a farm in order to provide information on 

the characteristics of farm operations and farm operators at the national, 

state, and county levels. The Census of Agriculture includes information 

regarding the number of farms by size and type, inventory and values for 

crops and livestock, and operator demographic characteristics. When 

NASS summarizes the Census of Agriculture, it assigns the data from an 

individual report to the principal county—which is the county in which the 

majority of the operator’s agricultural products are produced.

To describe what is known regarding children working in the United 

States, including those working in agriculture, we analyzed CPS data in a 

variety of ways. Table 10 presents a list of the CPS variables we 

analyzed.

Table 10: GAO Analysis of Selected Current Population Survey (CPS) Data Variables, 2003 to 2017

CPS variable Use in report

CPS monthly data

Number of working 

children 

Pemlr Determine number of working children in summer and nonsummer months for children aged 15 to 17.

Hours usually worked Pehruslt Determine hours usually worked in summer and non-summer 

months for children aged 15 to 17.

Self employed Prdtcow1 Identify self-employed persons based on primary job.

Race and ethnicity Pehspnon, Prdtrace, Ptdtracea Determine race and ethnicity information.

Gender Pesex Determine trends in employment by gender.

Agricultural work Pragna, Prdtcow1 To identify those working in agricultural, or non-agricultural 

industries.

Non-paid working in a 

family business

Prdtcow1 To identify an unpaid child working in a family business or 

farm

CPS 2017 Annual Social And Economic Supplement (ASEC) Datab

Industry Industry To identify the industry of the longest job in which the 

respondent worked.

Occupation Wemocg, Occup To identify the occupation of the longest job among major 

groups, and occupation of longest job among more detailed 

groups.

Low-income status Famlis To identify whether a respondent is from a household 

experiencing poverty, and to determine the ratio of the 

family’s income to the CPS’s low-income level.

Source: GAO analysis of Current Population Survey (CPS) data. | GAO-19-26

Notes: For Annual Social and Economic Supplement (ASEC) data, we determined whether a 

respondent had worked the previous year by identifying those respondents who had checked yes for 

Objective I Quantitative 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 58 GAO-19-26 Working Children

the WRK_CK variable, which indicates the interviewer checked yes that the respondent had worked 

the previous year.

a

The prdtrace variable changed in August 2005. Accordingly, we analyzed prdtrace from 2003 to July 

2005 and ptdtrace from August 2005 to 2017.

b

2017 Annual Social and Economic Supplement data reports calendar year 2016 information.

• Number of children who worked. To estimate the extent to which 

children aged 15 to 17 worked during summer and non-summer 

months, we defined summer months as June through August, and 

defined non-summer months as January through May and September 

through December for each calendar year, and averaged estimates 

for summer and non-summer months.8 We analyzed the pemlr 

variable, which is based on BLS’s definition of an employed person, to 

determine the number of children who worked. According to BLS’s 

definition, employed people are those who, during the reference week 

(a) did any work at all (for at least 1 hour) as paid employees; worked 

in their own businesses, professions, or on their own farms; or worked 

15 hours or more as unpaid workers in an enterprise operated by a 

family member or (b) were not working, but who had a job or business 

from which they were temporarily absent because of vacation, illness, 

bad weather, childcare problems, maternity or paternity leave, labormanagement dispute, job training, or other family or personal reasons 

whether or not they were paid for the time off or were seeking other 

jobs. Each employed person is counted only once, even if he or she 

holds more than one job.

• Weekly hours worked. To estimate the hours worked during summer 

and non-summer months, we analyzed the pehruslt variable—the sum 

of the pehrusl1 and perhrusl2 variables indicating primary and 

secondary jobs—that indicates a respondent’s usual weekly work 

hours worked. In addition, we developed categorical thresholds to 

describe hours worked per week in the summer and non-summer 

months, and we included both primary and secondary jobs in this 

analysis.

• Industries worked. To identify the industries in which children aged 

15 to 17 worked and the occupations they held in 2016, we obtained 

and analyzed 2017 CPS Annual and Social Economic Supplement 

 8

Our definitions of summer and non-summer months are not intended to align with how 

summer is defined in the FLSA child labor regulations. We used our definition of summer 

and non-summer months in our analysis as we found this categorization to be the most 

workable given the arrangement and contents of the CPS data set. We did not account for 

the extent to which some schools may have year-round calendars, or differentiate 

between varying school calendars between schools.
Appendix I: Objectives, Scope, and 

Methodology

Page 59 GAO-19-26 Working Children

(ASEC) data. More specifically, we categorized the industries that 

children may be working in using the following crosswalk of the 

Census Bureau classification systems regarding industry information. 

See table 11.

Table 11: Crosswalk of Census Bureau Industry Codes Used in GAO Analyses

GAO categorical 

variable 

2012 Census industry 

classification code

2012 North American 

Industry Classification 

System (NAICS) code

All agriculture 0170, 0180-0290 111-115

Agriculture: crop 

production 

0170 111

Agriculture: non-crop 

agriculture

0180-0290 112-115 

Construction and mininga 0370-0490, 0770 21, 23

Educational and health 

services

7860-8470 61-62

Manufacturing 1070–3990 31-33

Wholesale and retail 

trade

4070–5790 42, 44 -45

Transportation and 

utilities

6070–6390, 0570–0690 22, 48- 49

Leisure and hospitality 8560–8690 71-72

Other 6470-6780, 6870-7190, 7270-

7790, 8770-9290, 9370-9590 

51, 52-53, 54-56, 81, 92 

Source: GAO analysis of Census Bureau information. | GAO-19-26

Note: “Other” includes financial activities, information, professional and business services, other 

services, and public administration.

a

Construction and mining industry includes quarrying, and oil and gas extraction.

• Gender. To describe trends in the gender of working children, we 

analyzed 2003-2017 CPS basic monthly data.

• Race and ethnicity. This analysis is of the pehspnon, prdtrace and 

ptdtrace variables,9 which indicate a respondent’s identified race and 

ethnicity, and the pemlr variable, which indicates the child was 

employed, as defined by CPS. CPS treats ethnicity separately from 

race. As a result, a child can be identified in CPS as both white and 

Hispanic, or as both black and Hispanic, among other considerations. 

For the purposes of our report, we categorized any respondent 

 9

The race variable changed from prdtrace to ptdtrace in August 2005.
Appendix I: Objectives, Scope, and 

Methodology

Page 60 GAO-19-26 Working Children

identifying as Hispanic, irrespective of their reported race, as 

Hispanic. We further categorized respondents who identified as not 

being bi- or multiracial white or black as being white only and black 

only. We categorized respondents of two or more races, as well as 

Asians and other specific races such as Native American or Pacific 

Islander, as other races.10

• Low-income status. We obtained data from CPS’s March 2017 

ASEC to identify children aged 15 to 17 who had had worked in 

calendar year 2016. We analyzed their reported family income (famlis 

variable) as it compares to the CPS ASEC’s poverty thresholds.11 For 

this analysis, we defined “low-income” as any individual whose family 

income was below 150 percent of their poverty threshold.12 We 

utilized CPS ASEC data to determine the percentage of working 

children that were from low-income families and the percentage who 

were from higher income families (with income at least 150 percent of 

the poverty threshold), compared to non-working children. We also 

determined the percentage of working children from low-income 

families who worked 20 hours or more per week.

CPS estimates contained in this report are estimated standard errors and 

presented along with an approximate margin of error at the 95 percent 

confidence level or relative standard errors. We express our confidence in 

the precision of a particular sample’s estimates with a confidence interval. 

By adding and subtracting the margin of error from the estimate, we 

construct a confidence interval that would contain the actual population 

value for 95 percent of the samples that CPS could have drawn. All 

margins of error for CPS estimates presented in this report are 

approximations. We calculated the approximate margins of error following 

 10Due to relatively small numbers of respondents identifying themselves as Asian and 

other races, as well as certain bi-racial and other racial categories, we are only able to 

report white only, black only, Hispanic, and “other races” race and ethnicity information.

11Poverty thresholds are set by the U.S. Census Bureau and take into account family size 

and composition to determine who is in poverty. Famlis is the CPS ASEC variable that 

describes the ratio of family income to the poverty threshold, and is available for all 

individuals, regardless of family type. A person whose family income is less than 100 

percent of the poverty thresholds is categorized as “in poverty.” CPS ASEC 

documentation notes that a family is a group of two persons or more residing together and 

related by birth, marriage, or adoption. Any related subfamily member is counted as within 

a primary family. For the purposes of our analysis, the poverty status of an individual in a 

family is based on their family’s income. The poverty status of individuals who are not in a 

family is based on their own income. 

12According to a Census Bureau official, the Census Bureau does not officially define lowincome.
Appendix I: Objectives, Scope, and 

Methodology

Page 61 GAO-19-26 Working Children

CPS guidance and technical documentation. In order to estimate the 

margin of error for estimates of our subgroups of interest, a number of 

approximations were required. As a result, the margins of error provide a 

general order of magnitude. A relative standard error is equal to the 

standard error of a survey estimate divided by the survey estimate.

We conducted a data reliability assessment of the CPS variables included 

in our analyses. We reviewed technical documentation and related 

publications and websites with information about the data. We spoke with 

the appropriate officials at BLS to resolve any questions about the data 

and identify any known limitations. We also conducted electronic testing, 

where feasible, to check for logical consistency, missing data, and 

consistency with data reported in technical documentation. In general, we 

analyzed our estimates and determined they had relative standard errors 

of 10 percent or less, except where noted.13 We determined that the 

variables we used from the data we reviewed from the CPS were 

sufficiently reliable for the purposes of our reporting objectives.

To provide additional information regarding the agricultural child labor 

work force—in particular hired child crop workers—we analyzed NAWS 

data regarding hired farm workers in crop agriculture aged 17 and under. 

More specifically, to determine trend information where possible, we 

constructed a time variable by aggregating fiscal year 2005 to 2008, fiscal 

year 2009 to 2012, and fiscal year 2013 to 2016 data to develop a set of 

responses filtered for 17-year-olds and under that we would be able to 

report in a statistically reliable fashion at the 95 percent confidence level. 

To estimate the percentage of 14-, 15-, 16-, and 17-year-olds, we worked 

with ETA officials to determine a methodology to apply the NAWS 

population inflator to our estimated percentages and determine a 

population estimate for our time periods.14 With respect to our analysis of 

NAWS data regarding identified characteristics of farm workers in crop 

agriculture, we analyzed the variables shown in table 12.

 13For our estimates of the numbers of working children, we analyzed the estimates for 15-, 

16-, and 17-year-olds for all years from 2003 to 2017 and determined they have relative 

standard errors of 10 percent or less.

14The NAWS population inflator is derived from the USDA’s Census of Agriculture, which 

was conducted in 2002, 2007, 2012, and 2017. Because the time frames covered by the 

NAWS population inflator in some cases fall in the midst of the time period variable we 

constructed, we worked with NAWS to determine the appropriate population inflator 

measure.
Appendix I: Objectives, Scope, and 

Methodology

Page 62 GAO-19-26 Working Children

Table 12: Selected National Agricultural Worker Survey (NAWS) Data Variables Used in GAO Analyses

Report topic Variable Use in report

Gender Gender Report percentage of hired crop workers aged 17 and under by gender in 

2005 to 2008, fiscal years 2009 to 2012, and 2013 to 2016.

Race and ethnicity B01 and B02 Report percentage and estimated population of hired crop workers aged 

17 and under in fiscal years 2005 to 2008, 2009 to 2012, and 2013 to 

2016.

Family poverty status Fampov Percentage of hired crop workers aged 17 and under below the poverty 

level in 2005 to 2008, 2009 to 2012, and 2013 to 2016.

Intensity of work: days worked Fwrdays Mean working days for hired crop workers aged 14 to 17 working on U.S. 

farms, by age in 2005 to 2008, 2009 to 2012, and 2013 to 2016.

Age first worked in agriculture Agefrstfw Age range that respondent reported he or she began working, for 2005 

to 2008, 2009 to 2012, and 2013 to 2016. 

Documentation status Currstat Report percentage of hired crop workers aged 17 and under by 

documentation status in 2013 to 2016.

Region worked Region6 Report percentage of hired crop workers aged 17 and under by region 

worked in 2005 to 2016.

Mixed/applied pesticides in last year Np01f Report percentage of hired crop workers aged 14 to 17 working on U.S. 

farms, by age that loaded, mixed or applied pesticides in last 5 years.

Source: GAO analysis of Department of Labor Employment and Training Administration’s National Agricultural Workers Survey (NAWS) data. | GAO-19-26

Notes: NAWS data are organized by fiscal year. According to Employment and Training 

Administration officials, to determine farm workers’ poverty status as reported in NAWS, a poverty 

threshold was calculated for each worker based on the worker’s family size and the U.S. Department 

of Health and Human Services’ poverty guidelines for the calendar year that matches the year for 

which the worker answered the family income question. Workers’ family incomes were then 

compared to the poverty thresholds calculated for their family size and poverty status was assigned. 

Income was not adjusted for the amount of time the respondent was present in the United States in 

the calendar year in which income was reported.

Due to the relatively small samples, at least 2 years of data are to be 

combined for national-level analyses, according to a NAWS methodology 

document.15 All mean estimates were rounded to the nearest whole 

number. Given the relatively small size of the data sets, to present 

conservative estimates, we rounded estimates’ margin of errors up to the 

nearest whole number. We conducted a data reliability assessment of the 

NAWS variables included in our analyses. We reviewed technical 

documentation and related publications and websites with information 

about the data. We spoke with the appropriate officials at the Employment 

and Training Administration to resolve any questions about the data and 

 15Due to relatively small sample sizes for respondents aged 17 and under, we opted to 

present one aggregated estimate for fiscal years 2003 to 2016 for the region a respondent 

worked in and the variable indicating whether a respondent had mixed or applied 

pesticides in the last year.
Appendix I: Objectives, Scope, and 

Methodology

Page 63 GAO-19-26 Working Children

identify any known limitations. We also conducted electronic testing, 

where feasible, to check for logical consistency, missing data, and 

consistency with data reported in technical documentation. We 

determined that the variables we used from the data we reviewed from 

NAWS were sufficiently reliable for the purposes of our reporting 

objectives.

To provide additional information regarding children working in 

agriculture—in particular, household children working on farms and 

livestock agriculture—we obtained information from the Department of 

Health and Human Services’ National Institute for Occupational Safety 

and Health (NIOSH) Childhood Agricultural Injury Survey (CAIS). We 

reviewed agency documentation regarding its methodology for compiling 

the data, and interviewed agency officials regarding our results. We 

reviewed the agency’s code used to tabulate results and reported results 

only within CAIS reporting parameters, with a relative standard error of 33 

percent of less.

To provide information regarding the extent to which the agricultural 

workforce worked on farms employing 10 or fewer workers, we obtained 

information from the United States Department of Agriculture’s Census of 

Agriculture. We reviewed agency documentation regarding its 

methodology for compiling the data, and interviewed agency officials 

regarding our results. We reviewed the agency’s code used to tabulate 

results and reported results only within USDA reporting parameters.

We interviewed officials from DOL’s Bureau of Labor Statistics, 

Employment and Training Administration, and Wage and Hour Division; 

the Department of Health and Human Services’ NIOSH; and the 

Department of Agriculture regarding the data available and our analyses 

of the numbers and demographic characteristics of working children.

To describe what is known about the work-related fatalities and injuries to 

working children, including those in agriculture, we primarily relied on data 

from two national data sets maintained by Bureau of Labor Statistics––the 

Census of Fatal Occupational Injuries (CFOI) and the Survey of 

Occupational Injuries and Illnesses (SOII). We also collected information 

from two other injury and illness data sets, the National Electronic Injury 

Surveillance System––Occupational Supplement (NEISS-Work) and the 

Childhood Agricultural Injury Survey (CAIS) (see table 13). The years of 

data we analyzed were from 2003 to 2016 for the CFOI, SOII, and 

NEISS-Work, and selected years for CAIS.

Objective II Data Sources 

and Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 64 GAO-19-26 Working Children

Table 13: Data Sources Used in GAO Analyses of Work-Related Fatalities and Injuries and Illnesses to Children in Objective II

Source: GAO analysis of Department of Labor and Department of Health and Human Services’ National Institute for Occupational Safety and Health data. | GAO-19-26

a

The Childhood Agricultural Injury Survey was conducted in 2001, 2004, 2006, 2009, 2012, 2014. 

This report’s scope is from 2003 onward.

The Census of Fatal Occupational Injuries (CFOI) is an annual count of 

fatal workplace injuries, and is a federal-state cooperative program that 

has been implemented in all 50 states, and the District of Columbia. BLS 

uses diverse state, federal, and independent data sources to identify, 

verify, and describe fatal work injuries to ensure counts are as complete 

and accurate as possible. The CFOI also covers workers on farms of any 

size, including those employing 10 or fewer workers, and self-employed, 

family, and federal government workers. We conducted a data reliability 

assessment of the CFOI variables included in our analyses. We reviewed 

technical documentation and related publications and websites with 

information about the data. We spoke with the appropriate officials at BLS 

to resolve any questions about the data and identify any known 

limitations. We reviewed the CFOI analyses conducted by BLS to identify 

any unexpected values or logical inconsistencies in the results. We 

determined that the summary data provided were sufficiently reliable for 

the purposes of our reporting objectives.

Data file Organization 

responsible

Type of information in file used in 

analyses

Population GAO 

examined

Time frame 

covered by data

Census of Fatal 

Occupational 

Injuries 

Department of Labor’s 

Bureau of Labor Statistics 

Ages, occupations, and industries in 

which children suffered work-related 

fatalities, including demographic 

characteristics of child fatalities 

including gender and race and 

ethnicity of child

Working children aged 17 

and under

2003 to 2016 

Survey of 

Occupational 

Injuries and 

Illnesses 

Department of Labor’s 

Bureau of Labor Statistics 

Numbers of, ages, and industries in 

which children incurred work-related 

injuries and illnesses

Working children aged 15 

to 17

2003 to 2016

National Electronic 

Injury Surveillance 

System—

Occupational 

Supplement 

Department of Health and 

Human Services’

National Institute for 

Occupational Safety and 

Health 

Numbers of and ages in which 

children incurred work-related injuries 

and illnesses

Working children aged 14 

to 17

2003 to 2016

Childhood 

Agricultural Injury 

Survey 

Department of Health and 

Human Services’

National Institute for 

Occupational Safety and 

Health 

Extent to which children on farms 

incurred work-related injuries

Household and hired 

children aged 17 and 

under on U.S. crop or 

livestock farms

2004, 2006, 

2009, 2012, 

2014a
Appendix I: Objectives, Scope, and 

Methodology

Page 65 GAO-19-26 Working Children

The Survey of Occupational Injuries and Illnesses (SOII) is an annual 

estimate of workplace injuries and illnesses based on a survey of 

employers. The SOII is the largest occupational injury and illness 

surveillance system in the country, providing injury and illness counts and 

rates for a variety of employer, employee, and case characteristics based 

on a sample of approximately 230,000 establishments. According to BLS, 

for the purposes of the SOII an occupational injury is any injury, such as a 

cut, fracture, sprain, amputation, and so forth, which results from a workrelated event or from a single instantaneous exposure in the work 

environment. Detailed case data and worker demographics, including 

race and ethnicity, are collected for cases that require a day away from 

work. SOII estimates the number and frequency (incidence rates) of 

workplace injuries and illnesses based on recordkeeping logs kept by 

employers during the year. These records reflect the employer’s 

understanding of which cases are work-related and meet other 

recordkeeping requirements established by the U.S. Department of 

Labor’s Occupational Safety and Health Administration.16

In addition to injury and illness counts, survey respondents are asked to 

provide additional information for the subset of nonfatal cases that 

involved at least 1 day away from work, beyond the day of injury or 

illness. Employers answer several questions about these cases, including 

the demographics of the worker, the nature of the disabling condition, the 

event and source producing that condition, and the part of body affected. 

We conducted a data reliability assessment of the SOII variables included 

in our analyses. We reviewed technical documentation and related 

publications and websites with information about the data. We spoke with 

the appropriate officials at BLS to resolve any questions about the data 

and identify any known limitations. We reviewed the SOII analyses 

conducted by BLS to identify any unexpected values or logical 

inconsistencies in the results. We determined that the summary data 

provided were sufficiently reliable for the purposes of our reporting 

objectives.

To provide additional information regarding work-related injuries incurred 

by children, we obtained and analyzed data from the NEISS-Work public 

portal. The NEISS-Work data are collected by the NIOSH Division of 

Safety Research in partnership with the U.S. Consumer Product Safety 

Commission. NIOSH collects data from a nationally representative 

 16See generally 29 C.F.R. pt. 1904.
Appendix I: Objectives, Scope, and 

Methodology

Page 66 GAO-19-26 Working Children

sample of 67 U.S. hospital emergency departments. Coders at 

participating hospitals review all emergency department records to 

capture nonfatal work-related injuries and illnesses that occurred on the 

job to civilian workers.17 An injury is considered work-related if the work 

was for pay or other compensation; doing agricultural production; or 

working as a volunteer for an organized group. NEISS-Work data from 

2003 to 2014 include data for illnesses that began at work, such as heart 

attacks and strokes, and chronic conditions. According to NIOSH, illness 

cases comprise about 5 to 10 percent of all total annual NEISS-Work 

case estimates. Data from 2015 do not capture most illnesses that began 

at work. We conducted a data reliability assessment of the NEISS-Work 

variables included in our analyses. We reviewed technical documentation 

and related publications and websites with information about the data. We 

spoke with the appropriate officials at NIOSH to resolve any questions 

about the data and identify any known limitations. We determined that the 

variables we used from the data we reviewed from NEISS-Work were 

sufficiently reliable for the purposes of our reporting objectives.

To provide additional information regarding the number of work-related 

injuries incurred by child workers, including household workers, on U.S. 

farms, we worked with NIOSH to obtain information from its Childhood 

Agricultural Injury Survey (CAIS). This survey is designed to produce 

national and regional estimates of the number of individuals under age 20 

on U.S. operated farms by various injury characteristics. CAIS injury 

information is for all individuals under age 20 on farms for the years 2001, 

2004, 2006, 2009, 2012, and 2014. This includes children aged 17 and 

under living on, working on, or visiting the farm. More specifically, CAIS 

defines a household worker as being a member of the farm operator’s 

household (farm operator, his/her spouse, child/step child); a visitor as 

being a visiting relative to the farm operation or a non-relative visitor; and 

a hired worker as being a paid worker or laborer hired directly by the farm 

operator. Injury data include information on whether an injury was workrelated or not, the nature of the injury, the source of injury, the type of 

injury event, and the body part injured. Demographic information for all 

injured children was also collected. CAIS defines an injury as being any 

 17According to NIOSH officials, each case in NEISS-Work represents a “worker” who 

sought treatment in one of the NEISS-Work sampled emergency departments for an 

occupational injury, including occupational exposures. Hospital coders abstracting the 

medical records for NEISS-Work are instructed by NIOSH to identify a case as a “worker”

if at least one place in his or her emergency department medical record notes that injury 

occurred while the patient was working.
Appendix I: Objectives, Scope, and 

Methodology

Page 67 GAO-19-26 Working Children

nonfatal traumatic event occurring on the farm operation resulting in at 

least 4 hours of restricted activity, or requiring professional medical 

treatment. CAIS defines a work injury as being any injury that occurred 

while performing work or chores on the farm that was associated with the 

farm business, regardless of whether the work was performed for pay. 

We reviewed the code NIOSH used to tabulate our requested results and 

only reported results within CAIS reporting parameters, i.e. those with a 

relative standard error of 33 percent or less. We conducted a data 

reliability assessment of the CAIS variables included in our analyses. We 

reviewed technical documentation and related publications and websites 

with information about the data. We spoke with the appropriate officials at 

NIOSH to resolve any questions about the data and identify any known 

limitations. We reviewed the CAIS analyses conducted by NIOSH to 

identify any unexpected values or logical inconsistencies in the results.

We determined that the summary data provided were sufficiently reliable 

for the purposes of our reporting objectives.

We performed additional analyses with CPS data to support our work for 

this objective. To calculate total worked hours for each year, we 

calculated monthly hours worked from CPS basic monthly data by 

multiplying the pehruslt variable (usual weekly worked hours) by 52 and 

divided by 12. We then estimated the total hours worked by multiplying 

the monthly hours worked by our population estimations of the number of 

working children.18 We analyzed the prdtcow1 variable to estimate the 

percentage of unpaid children working in a family business and selfemployed children aged 15 to 17. We analyzed the CPS ASEC noemp 

variable to estimate the percentage of children working for employers with 

9 or fewer workers, and 10 to 49 workers.

We identified limitations with the comparability of data across data sets, 

which results in risks in analyzing data across data sets. To minimize 

such risks, we reviewed documentation, and interviewed or obtained 

information from officials responsible for the data to ensure our 

characterization of the data and our results is accurate and the data are 

sufficiently reliable for the purposes of our reporting objectives.

 18BLS officials stated the agency does not have research regarding standard errors for 

estimated total hours worked for 15- to 17-year-olds, and did not provide guidance on how 

to calculate such standard errors. GAO did not calculate the standard errors for the 

number of annual hours worked.
Appendix I: Objectives, Scope, and 

Methodology

Page 68 GAO-19-26 Working Children

To assess how DOL oversees compliance with the child labor provisions 

of the FLSA, we analyzed administrative data collected by DOL’s Wage 

and Hour Division (WHD), conducted interviews with WHD and OSHA, 

and reviewed relevant federal laws, regulations, and guidance. To 

examine WHD’s child labor enforcement efforts over time, we analyzed 

data from WHD’s Wage and Hour Investigative Support and Reporting 

Database (WHISARD), which includes information on investigations and 

violations related to child labor. For our reporting period of fiscal years 

2010 to 2016, we requested data on all WHD investigations and 

findings.19 We analyzed total number of investigations with child labor 

findings and violations by fiscal year,20 registration act,21 and industry. 

Before performing our own analysis, we requested many of these 

numbers from WHD, which we then calculated on our own and 

highlighted differences for WHD to comment on. After consulting with 

WHD officials, we excluded certain unusual types of investigations and 

investigations with no violations or penalties assessed that were closed 

due to the employer shutting down or being unlocatable.

In addition, we interviewed officials from DOL’s Wage and Hour Division 

and Occupational Safety and Health Administration. We also conducted 

interviews with WHD staff at the national office, all five regional offices,

and six selected district offices. We identified and selected WHD district 

offices based on the concentration of investigations with at least one child 

labor violation and geographical diversity, including areas with 

representation across agricultural and non-agricultural sectors.

We measured the concentration of investigations with child labor 

violations, by using WHISARD summary data provided by WHD officials 

to calculate an average total number of these investigations for the most 

recent 3 fiscal years (2014 to 2016) and our total 7 fiscal year reporting 

 19WHD provided data for all investigations that were not dropped and that concluded 

during the time period, except for non-enforcement agency investigations under the DavisBacon Act and certain other investigations where complainants did not give permission to 

use their names. WHD identified at least one child labor violation that was not in our data 

because the permission to use the complainant’s name was lacking.

20Throughout this report, investigations—and any violations found and resulting 

penalties—are counted in the fiscal year in which they concluded, although the 

investigations work may have been done in a prior fiscal year.

21In WHISARD, each investigation is registered under the act that was the official focus of 

the investigation. However, investigations registered under acts other than the FLSA can 

check for, identify, and result in penalties for child labor violations.

Objective III Data Sources 

and Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 69 GAO-19-26 Working Children

period (2010 to 2016), for each district office.22 We then categorized 

district offices by high, medium, and low averages for investigations with 

child labor violations using the 3-year average.23 For our final selections, 

we primarily used the 3-year averages to ensure that the selected offices 

had recent experience with investigations that resulted in child labor 

violations. Our final selections—Austin, Des Moines, Pittsburgh, Raleigh, 

Sacramento, and San Francisco—represent locations with a mix of high, 

medium, and low average number of investigations with child labor 

violations, across all five WHD regions.

In each WHD region we conducted semi-structured interviews with the 

regional Child Labor Coordinator, and in each district office we 

interviewed a WHD investigator, Community Outreach Resource and 

Planning specialist, and district director. The findings from our 

discussions with regional and district WHD staff are not generalizable. 

However, the interviews provide examples of WHD’s enforcement and 

compliance assistance efforts with regard to the child labor provisions of 

the FLSA.

In addition, we interviewed representatives from a range of organizations, 

including those focused on business and advocacy, such as the National 

Consumers League, National Children’s Center for Rural and Agricultural 

Health and Safety, Farmworker Action Network, Center for Worker Health 

at Wake Forest School of Medicine, North Carolina Agribusiness Council, 

California Farm Bureau Federation, AgSafe, Labor Occupational Health 

Program University of California-Berkeley, Iowa Federation of Labor AFLCIO, and Iowa Farm Bureau. We also held one group interview with the 

Association of Farmworker Opportunity Programs, with representatives 

from a variety of farm worker and labor organizations.

 22WHD began a new data-driven enforcement strategy and also revised the nonagriculture child labor regulations in fiscal year 2010. As such, we reviewed DOL’s actions 

from fiscal year 2010 to fiscal year 2016 to focus on the most current DOL enforcement 

practices and regulations.

23The 3-year averages for “total investigations with child labor violations” were categorized 

as follows: “low” was 0-9 investigations, “medium” was 10-19 investigations, and “high”

was 20 or more investigations.
Appendix I: Objectives, Scope, and 

Methodology

Page 70 GAO-19-26 Working Children

Finally, we reviewed relevant federal laws, regulations, and guidance

pertaining to child labor. We also reviewed WHD’s guidance to the field 

for fiscal years 2011 to 2018 and federal standards for internal control.24

We conducted a data reliability assessment of WHISARD variables 

included in our analyses. We reviewed technical documentation and 

spoke with officials to discuss our analysis plan, as well as to resolve any 

questions about the data and any known limitations. We also conducted 

electronic testing, where feasible, to check for logical consistency and 

missing data. We found some deficiencies in variables we used from the 

data, including that according to the integrity report, several variables we 

used in our analysis were less than 95 percent reliable when traced back 

to original investigation records. However, we determined that this was 

the best available data and that it was unlikely that our findings would be 

materially different due to the probable amount of incorrectly recorded 

data.

We conducted this performance audit from March 2017 through 

November 2018 in accordance with generally accepted government 

auditing standards. Those standards require that we plan and perform the 

audit to obtain sufficient, appropriate evidence to provide a reasonable 

basis for our findings and conclusions based on our audit objectives. We 

believe that the evidence obtained provides a reasonable basis for our 

findings and conclusions based on our audit objectives.

 24WHD’s fiscal year 2018 enforcement and compliance assistance plans regarding child 

labor were finalized during the course of our review and were incorporated into our 

analysis.
Appendix II: Detailed Information on Children 

in the United States Who Worked in Summer 

and Non-Summer Months

Page 71 GAO-19-26 Working Children

Table 14: Estimated Number of Children Who Worked in an Average Summer 

Month, by Age, 2003 to 2017

(In thousands)

Year 15-year-olds 16-year-olds 17-year-olds Total

2003 499 1,108 1,703 3,310

2004 434 1,070 1,467 2,970

2005 486 1,125 1,618 3,228

2006 444 1,253 1,676 3,373

2007 358 1,068 1,673 3,099

2008 353 947 1,402 2,702

2009 254 787 1,257 2,297

2010 240 545 1,141 1,925

2011 243 590 1,083 1,916

2012 267 638 1,106 2,012

2013 240 641 1,111 1,993

2014 257 647 1,127 2,031

2015 283 717 1,262 2,263

2016 310 799 1,321 2,430

2017 274 857 1,353 2,485

Source: GAO analysis of Current Population Survey (CPS) monthly data. | GAO-19-26

Notes: Numbers rounded to nearest thousands. Individual age totals may not sum to combined total 

due to rounding. Summer months include June, July, and August for each calendar year. These 

definitions are not intended to align with how summer is defined in federal child labor regulations. The 

estimates averaged these summer months. We analyzed the estimates for 15-, 16-, and 17-year-olds 

in 2003, 2011, and 2017 and determined they have relative standard errors of 10 percent or less.

Table 15: Estimated Number of Children Who Worked in an Average Non-Summer 

Month, by Age, 2003 to 2017

(In thousands)

Year 15-year-olds 16-year-olds 17-year-olds Total

2003 294 807 1,376 2,476

2004 273 851 1,287 2,411

2005 281 843 1,362 2,486

2006 275 891 1,448 2,613

2007 252 802 1,401 2,455

2008 220 688 1,223 2,131

2009 189 537 1,024 1,749

2010 152 457 933 1,542

Appendix II: Detailed Information on Children 

in the United States Who Worked in Summer 

and Non-Summer Months
Appendix II: Detailed Information on Children 

in the United States Who Worked in Summer 

and Non-Summer Months

Page 72 GAO-19-26 Working Children

Year 15-year-olds 16-year-olds 17-year-olds Total

2011 142 421 849 1,412

2012 157 462 828 1,446

2013 141 493 905 1,538

2014 164 496 990 1,650

2015 186 536 1,004 1,726

2016 185 575 1,049 1,810

2017 171 668 1,099 1,938

Source: GAO analysis of Current Population Survey (CPS) monthly data. | GAO-19-26

Notes: Numbers rounded to nearest thousands. Individual age totals may not sum to combined total 

due to rounding. Non-summer months include January through May and September through 

December for each calendar year. These definitions are not intended to align with how summer is 

defined in federal child labor regulations. The estimates averaged these non-summer months. We 

analyzed the estimates for 15-, 16-, and 17-year-olds in 2003, 2011, and 2017 and determined they 

have relative standard errors of 10 percent or less.

Table 16: Estimated Number and Percentage of Children Employed during Summer Months and Non-Summer Months, by Age, 

2003 and 2017

(In thousands)

2003 2017

Number (percentage) 

during summer month

Number (percentage) 

during non-summer 

month

Number (percentage) 

during summer month

Number (percentage) 

during non-summer month

15-year-olds 499 (11.7%)a 294 (7.2%) 274 (6.7%) 171 (4.1%)

16-year-olds 1,108 (26.1%) 807 (19.0%) 857 (19.2%) 668 (14.7%)

17-year-olds 1,703 (39.8%) 1,376 (32.1%) 1,353 (31.4%) 1,099 (24.4%)

Source: GAO analysis of Current Population Survey (CPS) monthly data. | GAO-19-26

Notes: Percentages rounded to nearest tenth of a percent. Summer months include June, July, and 

August for each calendar year. Non-summer months include January through May and September 

through December for each calendar year. These definitions are not intended to align with how 

summer is defined in federal child labor regulations. The estimates averaged these summer and nonsummer months.

a

The percentage estimate for 15-year-olds in 2003 non-summer months has a relative standard error 

that is higher than 10 percent but less than 30 percent.
Appendix II: Detailed Information on Children 

in the United States Who Worked in Summer 

and Non-Summer Months

Page 73 GAO-19-26 Working Children

Table 17: Estimated Hours Worked by Working Children Aged 15 to 17 Who Worked in Non-Agricultural Industries, 2003 to 

2017

(Numbers in thousands)

Summer months Non-summer months

Year Worked 40 

hours or more 

Percentage 

worked 40 

hours or more

Estimated number of 

working 15- to 17-

year-olds that year 

Worked 19 

hours or more 

Percentage 

Worked 19 hours 

or more

Estimated number of 

working 15- to 17-

year-olds that year 

2003 342 10.7 3,197 745 30.9 2,413

2004 329 11.5 2,852 723 30.9 2,337

2005 384 12.4 3,109 767 31.7 2,417

2006 393 12.1 3,239 850 33.4 2,544

2007 389 13.0 2,984 818 34.4 2,376

2008 317 12.4 2,553 665 32.2 2,065

2009 230 10.5 2,185 527 31.2 1,692

2010 214 11.6 1,837 415 27.9 1,487

2011 188 10.3 1,819 402 29.8 1,347

2012 202 10.5 1,919 405 29.2 1,390

2013 229 12.0 1,900 476 32.0 1,488

2014 235 12.1 1,943 540 33.7 1,603

2015 282 13.0 2,175 558 33.2 1,679

2016 349 15.0 2,323 587 33.6 1,747

2017 326 13.6 2,407 663 35.2 1,882

Source: GAO analysis of Current Population Survey (CPS) monthly data. | GAO-19-26

Notes: For our analysis, we did not estimate the number of hours for respondents reporting their 

hours as “varies” based on the results of what other respondents reporting discrete numbers of hours 

worked. Summer months include June, July, and August for each calendar year. Non-summer 

months include January through May and September through December for each calendar year. 

These definitions are not intended to align with how summer is defined in federal child labor 

regulations, and this analysis is not intended to assess whether this work complied with federal child 

labor requirements.

Table 18: Estimated Hours Worked by Children Aged 15 Who Worked in Non-Agricultural Industries, 2003 to 2017, by Hours 

per Week

(Numbers in thousands)

Summer months Non-summer months

Year Worked 40 

hours or 

more 

Percentage 

worked 40 hours 

or more

Total estimated 

number of 

working 15-

year-olds 

Worked 19 

hours or more

Percentage 

worked 19 hours 

or more

Total estimated 

number of working 

15-year-olds

2003 40 8.5a 465 47 16.9a 278

2004 31 7.6a 405 35 13.8a 254
Appendix II: Detailed Information on Children 

in the United States Who Worked in Summer 

and Non-Summer Months

Page 74 GAO-19-26 Working Children

(Numbers in thousands)

Summer months Non-summer months

Year Worked 40 

hours or 

more 

Percentage 

worked 40 hours 

or more

Total estimated 

number of 

working 15-

year-olds 

Worked 19 

hours or more

Percentage 

worked 19 hours 

or more

Total estimated 

number of working 

15-year-olds

2005 46 10.5a 442 40 15.4a 258

2006 50 12.1a 410 49 19.0a 260

2007 38 11.6a 325 48 20.7a 234

2008 38 11.6a 325 42 20.7a 203

2009 19 8.3b 232 41 23.2a 176

2010 27 12.5a 216 32 22.7a 141

2011 28 12.5a 222 33 25.5a 128

2012 28 11.7a 237 34 23.4a 145

2013 33 15.0a 217 38 30.2a 127

2014 44 18.6a 239 46 30.4a 152

2015 32 12.2a 267 53 30.5a 173

2016 43 15.1a 283 48 27.8a 173

2017 36 14.2a 257 42 26.0a 160

Source: GAO analysis of Current Population Survey monthly data. | GAO-19-26

Notes: For our analysis, we did not estimate the number of hours for respondents reporting their 

hours as “varies” based on the results of what other respondents reporting discrete numbers of hours 

worked. Summer months include June, July, and August for each calendar year. Non-summer 

months include January through May and September through December for each calendar year. 

These definitions are not intended to align with how summer is defined in federal child labor 

regulations, and this analysis is not intended to assess whether this work complied with federal child 

labor requirements.

a

Estimate has a relative standard error greater than 10 percent but less than 30 percent.

b

Estimate should be interpreted with caution because it has a relative standard error between 31 and 

50 percent.

Table 19: Estimated Number of Children Aged 15 to 17 Working in Agricultural 

Industries, Summer and Non-Summer Months, 2003 to 2017

(Numbers in thousands)

Summer months Non-summer months

Year Estimated number Estimated number

2003 104 59

2004 111 67

2005 113 65

2006 130 65

2007 109 74
Appendix II: Detailed Information on Children 

in the United States Who Worked in Summer 

and Non-Summer Months

Page 75 GAO-19-26 Working Children

Summer months Non-summer months

Year Estimated number Estimated number

2008 145 63

2009 109 53

2010 82 47

2011 89 59

2012 88 52

2013 83 48

2014 86 42

2015 84 43

2016 101 57

2017 71 49

Source: GAO analysis of Current Population Survey (CPS) data. | GAO-19-26

Notes: Estimates are rounded to the nearest thousand. Summer months include June, July, and 

August for each calendar year. Non-summer months include January through May and September 

through December for each calendar year. These definitions are not intended to align with how 

summer is defined in federal child labor regulations, and this analysis is not intended to assess 

whether this work complied with federal child labor requirements. All estimates have a relative 

standard error of less than 30 percent.
Appendix III: Demographic Characteristics of 

Children in the United States Who Worked in 

Summer and Non-Summer Months

Page 76 GAO-19-26 Working Children

Gender. Our analysis of Current Population Survey (CPS) basic monthly 

data found that working females aged 15 to 17 comprised about 52 

percent of the working child population in 2017 summer months, and 53 

percent in non-summer months. Tables 20 and 21 present detailed 

results of our analysis.

Table 20: Estimated Number of Children Aged 15 to 17 Who Worked in an Average 

Summer Month, by Gender, 2003 to 2017

(In thousands)

Year Female Male

2003 1,614 1,697

2004 1,525 1,446

2005 1,653 1,575

2006 1,621 1,753

2007 1,524 1,576

2008 1,357 1,346

2009 1,123 1,174

2010 945 980

2011 968 948

2012 1,054 958

2013 1,027 966

2014 1,034 997

2015 1,114 1,148

2016 1,214 1,217

2017 1,294 1,190

Source: GAO analysis of Current Population Survey (CPS) monthly data. | GAO-19-26

Notes: Summer months include June, July, and August for each calendar year. These definitions are 

not intended to align with how summer is defined in federal child labor regulations. The estimates 

averaged these summer months.

Table 21: Estimated Number of Children Who Worked in an Average Non-Summer 

Month, by Gender, 2003 to 2017

(In thousands)

Year Female Male

2003 1,280 1,196

2004 1,267 1,144

2005 1,297 1,189

2006 1,379 1,235

Appendix III: Demographic Characteristics of 

Children in the United States Who Worked in 

Summer and Non-Summer Months
Appendix III: Demographic Characteristics of 

Children in the United States Who Worked in 

Summer and Non-Summer Months

Page 77 GAO-19-26 Working Children

Year Female Male

2007 1,277 1,177

2008 1,148 983

2009 928 821

2010 822 720

2011 753 659

2012 753 693

2013 815 723

2014 867 782

2015 883 842

2016 986 823

2017 1,034 904

Source: GAO analysis of Current Population Survey (CPS) monthly data. | GAO-19-26

Notes: Non-summer months include January through May and September through December for 

each calendar year. These definitions are not intended to align with how summer is defined in federal 

child labor regulations. 

Race and ethnicity. Our analysis of CPS basic monthly data found that 

from 2003 to 2017 the percentage of children aged 15 to 17 who worked 

during summer months and identified as white only declined, and the 

percentage of this age group that identified as other races or ethnicities—

black only, Hispanic, or other races combined—increased.1 More 

specifically, the percentage of working Hispanic children was 15.7 percent 

in 2017; the percentage of black only children was 9.7 percent; other 

races was 8.3 percent; and working white only children was 66 percent in 

2017.2

 1

These estimates have relative standard errors of less than 10 percent. CPS treats 

ethnicity separately from race. As a result, a child can be identified in CPS as both white 

and Hispanic, or as both black and Hispanic, among other considerations. For the 

purposes of our report, we categorized any respondent identifying as Hispanic, 

irrespective of their reported race, as Hispanic. We further categorized respondents who 

identified as not being bi- or multiracial white or black as being white only and black only. 

We counted the following respondents as other races: respondents of two or more races, 

Asians, and other races such as Native American or Pacific Islander.

2

These estimates are for children working during summer months. The race and ethnic 

composition of working children during non-summer months was similar. More specifically, 

the percentage of working Hispanic children during non-summer months was 16.7 percent 

in 2017, the percentage of black only children was 8.9 percent, and working children of 

other races increased was 7.8 percent, while working white only children was 67 percent 

in 2017.
Appendix III: Demographic Characteristics of 

Children in the United States Who Worked in 

Summer and Non-Summer Months

Page 78 GAO-19-26 Working Children

Table 22: Estimated Number of Children Aged 15 to 17 Who Worked in an Average 

Summer Month, by Race and Ethnicity, 2003 to 2017

(In thousands)

Year White only Black only Hispanic Other races

2003 2,544 252 351 164a

2004 2,314 240 270 147a

2005 2,503 222 351 152a

2006 2,598 265 349 161a

2007 2,334 264 349 152a

2008 2,002 248 322 131a

2009 1,730 191a 271 104a

2010 1,458 137a 243 87a

2011 1,455 168a 225 69a

2012 1,444 177a 272 119a

2013 1,405 159a 300 128a

2014 1,446 169a 290 126a

2015 1,573 212 312 166a

2016 1,621 232 377 200a

2017 1,651 240 389 205a

Source: GAO analysis of Current Population Survey (CPS) monthly data. | GAO-19-26

Notes: CPS treats ethnicity separately from race. As a result, a child can be identified in CPS as both 

white and Hispanic, or as both black and Hispanic, among other considerations. For the purposes of 

our report, we categorized any respondent identifying as Hispanic, irrespective of their reported race, 

as Hispanic. We further categorized respondents who identified as not being bi- or multiracial white or 

black as being white only and black only. We counted bi- and multiracial respondents, as well as 

Asians, and other specific races such as Native American or Pacific Islander, as other races. Summer 

months include June, July, and August for each calendar year. These definitions are not intended to 

align with how summer is defined in federal child labor regulations.

a

This estimate has a relative standard error greater than 10 percent and less than 30 percent.

Table 23: Estimated Number of Children Aged 15 to 17 Who Worked in an Average 

Non-Summer Month, by Race and Ethnicity, 2003 to 2017

(In thousands)

Year White only Black only Hispanic Other races 

2003 1,902 196 268 110a

2004 1,876 175 235 125a

2005 1,915 181 268 122a

2006 1,948 225 308 132

2007 1,816 218 296 125a

2008 1,581 177 268 105a
Appendix III: Demographic Characteristics of 

Children in the United States Who Worked in 

Summer and Non-Summer Months

Page 79 GAO-19-26 Working Children

Year White only Black only Hispanic Other races 

2009 1,340 133 204 73a

2010 1,176 125 179 61a

2011 1,082 104a 166 60a

2012 1,047 110a 200 89a

2013 1,121 106a 218 93a

2014 1,141 145 257 107a

2015 1,173 162 267 123a

2016 1,210 158 308 133

2017 1,291 172 324 152

Source: GAO analysis of Current Population Survey (CPS) monthly data. | GAO-19-26

Notes: CPS treats ethnicity separately from race. As a result, a child can be identified in CPS as both 

white and Hispanic, or as both black and Hispanic, among other considerations. For the purposes of 

our report, we categorized any respondent identifying as Hispanic, irrespective of their reported race, 

as Hispanic. We further categorized respondents who identified as not being bi- or multiracial white or 

black as being white only and black only. We counted bi- and multiracial respondents, as well as 

Asians, and other specific races such as Native American or Pacific Islander, as other races. Nonsummer months include January through May and September through December for each calendar 

year. These definitions are not intended to align with how summer is defined in federal child labor

regulations

a

This estimate has a relative standard error greater than 10 percent and less than 30 percent.

Low-income status.3 Our analysis of CPS ASEC data found that for 

2016, working children aged 15 to 17 were less likely to be from lowincome families than children who did not work: 15 percent and 27 

percent, respectively.4 Further, our analysis found that this trend was 

consistent across varying working hours; in 2016 about 16 percent of 

children working 20 or more hours per week and about 14 percent of 

children working less than 20 hours were from low-income families.

 3

In this report, we defined low-income as having income below 150 percent of the poverty 

threshold. Poverty thresholds are set by the U.S. Census Bureau and take into account 

family size and composition to determine who is in poverty. According to a Census Bureau 

official, the Census Bureau does not have an official definition of low-income.

4

This analysis was conducted for all individuals, regardless of family type. The poverty 

status for persons aged 15 to 17 who are not related to anyone in a household (e.g., living 

alone or a foster child) is determined by their own income. CPS ASEC documentation 

notes that a family is a group of two persons or more residing together and related by 

birth, marriage, or adoption. Any related subfamily member is counted as within a primary 

family. For the purposes of our analysis, the poverty status or low-income status of 

individuals in a family is based on their family’s income. The poverty/low-income status of 

individuals who are not in a family is based on their own income. 
Appendix IV: Detailed Information on 

Occupations in Which Children Aged 15 to 17 

Worked, 2016

Page 80 GAO-19-26 Working Children

Table 24: Occupations in Which Children Aged 15 to 17 Were Estimated to Have 

Worked, 2016

(In thousands)

Occupation title Estimated number of 

working children 

(margin of error)

Cashiers 375 (+/-52)

Waiters and waitresses 141 (+/-36)

Athletes, coaches, umpires, and related workers 103 (+/-27)

Child care workers 90 (+/-24)

Miscellaneous agricultural workers, including animal breeders 87 (+/-23)

Cooks 86 (+/-26)

Retail salespersons 84 (+/-26)

Food preparation workers 83 (+/-22)

Lifeguards and other recreational and all other protective 

service workers

79 (+/-24)

Food preparation and serving related workers, all other 

including dining room and cafeteria attendants and bartender 

helpers

77 (+/-23)

Hosts and hostesses, restaurant, lounge, and coffee shop 71 (+/-22)

Counter attendants, cafeteria, food concession, and coffee 

shop

69 (+/-24)

Janitors and building cleaners 64 (+/-21)

Laborers and freight, stock, and material movers, hand 58 (+/-20)

Packers and packagers, hand 58 (+/-27)

Grounds maintenance workers 55 (+/-20)

Stock clerks and order fillers 54 (+/-21)

Office clerks, general 52 (+/-21)

Customer service representatives 51 (+/-21)

Dishwashers 49 (+/-22)

Recreation and fitness workers 46 (+/-19)

Other teachers and instructors 45 (+/-18)

Combined food preparation and serving workers, including fast 

food

42 (+/-17)

Miscellaneous entertainment attendants and related workers 37 (+/-18)

Cleaners of vehicles and equipment 33 (+/-18)

Receptionists and information clerks 25 (+/-13)

Construction laborers 22 (+/-15)a

Food servers, non-restaurant 21 (+/-12)a

Driver/sales workers and truck drivers 15 (+/-11)a

Appendix IV: Detailed Information on 

Occupations in Which Children Aged 15 to 

17 Worked, 2016
Appendix IV: Detailed Information on 

Occupations in Which Children Aged 15 to 17 

Worked, 2016

Page 81 GAO-19-26 Working Children

Occupation title Estimated number of 

working children 

(margin of error)

Nonfarm animal caretaker 14 (+/-11)a

Teacher assistants 11 (+/-9)a

Secretaries and administrative assistants 11 (+/-9)a

Carpenters 11 (+/-10)a

Maids and housekeeping cleaners 11 (+/-8)a

Bookkeeping, accounting, and auditing clerks 10 (+/-9)a

Ushers, lobby attendants, and ticket takers 10 (+/-9)a

Counselors 10 (+/-8)a

Nursing, psychiatric, and home health aides 10 (+/-7)a

Security guards and gaming surveillance officers 9 (+/-8)a

Miscellaneous healthcare support occupations, including 

medical equipment preparers

9 (+/-7)a

Source: GAO analysis of Current Population Survey (CPS) 2017 Annual Social and Economic Supplement (ASEC) data, which reports

calendar year 2016 information. | GAO-19-26

Notes: Data in parentheses represent the margin of error at the 95 percent confidence level. This 

analysis is not intended to assess whether this work complied with federal child labor requirements.

a

This estimate has a relative standard error between 30 and 50 percent and should be interpreted 

with caution.
Appendix V: Detailed Information on Hired 

Child Crop Workers in the United States

Page 82 GAO-19-26 Working Children

Estimated number of hired working children in crop agriculture. Our 

analysis of National Agricultural Worker Survey (NAWS) data found that 

from fiscal years 2005 to 2008 about 43,000 children aged 17 and under 

on average worked on U.S. crop farms—about 3.1 percent of the total 

hired crop worker population. Further, from fiscal years 2009 to 2012 

there were about 30,000 children aged 17 and under on average (1.8 

percent), and from fiscal years 2013 to 2016 about 34,000 on average 

(2.1 percent).

Age first worked in agriculture. Our analysis of NAWS data indicates 

that more than one-third of hired crop workers—both adults and 

children—began working in U.S. agriculture at age 18 or under. More 

specifically, in the fiscal year 2003 to 2016 reporting period, between 6 

and 8 percent of hired crop workers began working at age 13 or under, 

and another 30 to 34 percent began working at age 14 to 18.1 Table 25 

presents specific results.

Table 25: Age Hired Crop Workers First Worked in U.S. Agriculture, by Estimated 

Percentage, Fiscal Years 2003 to 2016

Age first worked in 

U.S. agriculture 

Estimated percentage of all hired 

crop workers (margin of error) 

0- to 13-years-old 7 (+/-1)

14- to 18-years-old 32 (+/-2)

19- to 21-years-old 18 (+/-1)

22- to 24-years-old 11 (+/-1)

25- to 34-years-old 32 (+/-2)

Source: GAO analysis of National Agricultural Worker Survey (NAWS) data. | GAO-19-26

Notes: Data in parentheses represent the margin of error at the 95 percent confidence level. All mean 

estimates are rounded to the nearest whole number, and margin of errors are rounded up to the next 

whole number. The National Agricultural Worker Survey (NAWS) survey does not identify the discrete 

age at which a respondent first worked in U.S. agriculture. Accordingly, it is not possible to identify the 

extent to which those reporting they first worked in U.S. agriculture between age 14 and 18 started 

working at age 14, 15, etc. This analysis is not intended to assess whether this work complied with 

federal child labor requirements.

Gender. Our analysis of National Agricultural Worker Survey (NAWS) 

data identified no discernible trends with respect to the gender of the 

hired child crop workers during the time periods we reviewed. However, 

our analysis shows that hired crop workers aged 17 and under were more 

often male than female. See table 26.

 1

These ranges are estimates at the 95 percent confidence level.

Appendix V: Detailed Information on Hired 

Child Crop Workers in the United States 
Appendix V: Detailed Information on Hired 

Child Crop Workers in the United States

Page 83 GAO-19-26 Working Children

Table 26: Estimated Percentage of Hired Crop Workers Aged 17 and Under by 

Gender, Fiscal Years 2005 to 2016

Fiscal years Percentage of females

(margin of error)

Percentage of males

(margin of error)

2005 to 2008 19 (+/-18)a 81 (+/-18)

2009 to 2012 24 (+/-9) 76 (+/-9)

2013 to 2016 30 (+/-15) 70 (+/-15)

Source: GAO analysis of National Agricultural Worker Survey (NAWS) data. | GAO-19-26

Note: Data in parentheses represent the margin of error at the 95 percent confidence level. All mean 

estimates are rounded to the nearest whole number, and margin of errors are rounded up to the next 

whole number. While the estimated percentage of female hired child crop workers appears to 

increase, and the percentage of males decrease, the margin of errors overlap among mean 

estimates. Therefore, we cannot with confidence state that the trends are statistically reliable and 

instead note that there are no discernible trends.

a

Estimate has a relative standard error between 31 and 50 percent and should be interpreted with 

caution.

Race and ethnicity. Our analysis of NAWS data found no discernible 

trends with respect to the trends in Hispanic and white only hired child 

crop workers during the time periods we reviewed. Table 27 presents 

detailed results.

Table 27: Estimated Percentage of Hired Crop Workers Aged 17 and Under by Race 

and Ethnicity, Fiscal Years 2005 to 2016

Fiscal years Percentage Hispanic

(margin of error)

Percentage white only

(margin of error)

2005 to 2008 74 (+/-18) 25 (+/-18)a

2009 to 2012 50 (+/-17) 50 (+/-17)

2013 to 2016 65 (+/-17) 34 (+/-17)

Source: GAO analysis of National Agricultural Worker Survey (NAWS) data. | GAO-19-26

Notes: Data in parentheses represent the margin of error at the 95 percent confidence level. All mean 

estimates are rounded to the nearest whole number, and margin of errors are rounded up to the next 

whole number. We separately analyzed black only and “other races”—defined as Native American, 

Pacific Islander, and persons of two or more races—for the time periods noted, but did not obtain 

statistically reportable results for respondents aged 17 and under.

a

Estimate has a relative standard error between 31 and 50 percent and should be interpreted with 

caution.

Poverty status. Our analysis of NAWS data indicates a substantial 

percentage of hired child crop workers come from families experiencing 

poverty. More specifically, our analysis shows that between 74 and 92 

percent of hired crop workers aged 17 and under in the fiscal year 2005 
Appendix V: Detailed Information on Hired 

Child Crop Workers in the United States

Page 84 GAO-19-26 Working Children

to 2008 review period came from families below the poverty level, as 

defined for purposes of NAWS,2 whereas in the fiscal year 2013 to 2016 

review period, between 42 and 76 percent did. Table 28 presents specific 

details for the fiscal year 2005 to 2008, 2009 to 2012, and 2013 to 2016 

reporting periods.

Table 28: Estimated Percentage of Hired Crop Workers Aged 17 and Under From 

Families Below the Poverty Level, Fiscal Years 2005 to 2016

Fiscal years Percentage below 

the poverty level

(margin of error)

Percentage above 

the poverty level

(margin of error)

2005 to 2008 83 (+/-9) 17 (+/-9)

2009 to 2012 77 (+/-13) 23 (+/-13)

2013 to 2016 59 (+/-17) 41 (+/-17)

Source: GAO analysis of National Agricultural Worker Survey (NAWS) data. | GAO-19-26

Notes: Data in parentheses represent the margin of error at the 95 percent confidence level. 

Percentages may not total to 100 due to rounding. According to Employment and Training 

Administration officials, to determine farm workers’ poverty status as reported in NAWS, a poverty 

threshold was calculated for each worker based on the worker’s family size and the U.S. Department 

of Health and Human Services’ poverty guidelines for the calendar year that matches the year for 

which the worker answered the family income question. Workers’ family incomes were then 

compared to the poverty thresholds calculated for their family size and poverty status was assigned. 

Income was not adjusted for the amount of time the respondent was present in the United States in 

the calendar year in which income was reported.

Mean farm work days per year. Our analysis of NAWS data indicates 

that hired crop workers aged 17 and under worked an estimated 70 days 

in the fiscal year 2013 to 2016 reporting period.3 Table 29 presents the 

detailed results of the mean estimated number of days worked for 

children aged 14 to 17.

 2

According to Employment and Training Administration officials, to determine farm

workers’ poverty status as reported in NAWS, a poverty threshold was calculated for each 

worker based on the worker’s family size and the U.S. Department of Health and Human 

Services’ poverty guidelines for the calendar year that matches the year for which the 

worker answered the family income question. Workers’ family incomes were then 

compared to the poverty thresholds calculated for their family size and poverty status was 

assigned. Income was not adjusted for the amount of time the respondent was present in 

the United States in the calendar year in which income was reported.

3

At the 95 percent confidence level, the estimated number of days that crop workers on 

U.S. farms aged 17 or under worked were between 55 and 85 days for the fiscal year 

2013 to 2016 reporting period.
Appendix V: Detailed Information on Hired 

Child Crop Workers in the United States

Page 85 GAO-19-26 Working Children

Table 29: Trends in Estimated Mean Working Days for Hired Crop Workers Aged 14 to 17 Working on U.S. Farms, by Age and 

Year Grouping

Fiscal years 2005 to 2008 Fiscal years 2009 to 2012 Fiscal years 2013 to 2016

Worker age Mean estimated number of 

days (margin of error days)

Mean estimated number of 

days (margin of error days)

Mean estimated number of

days (margin of error days)

14-years-old 126 (+/-74) 82 (+/-35)a 65(+/-42)a

15-years-old 77 (+/-13) 71 (+/-50)a 101 (+/-43)a

16-years-old 94 (+/-31) 63 (+/-14) 57 (+/-16)

17-years-old 95 (+/-42) 94 (+/-31) 74 (+/-24)

Total aged 17 years and 

under

93 (+/-24)a 78 (+/-16) 70 (+/-15)

Total aged 18 years and 

older

195 (+/-8) 190 (+/-8) 194 (+/-8)

Source: GAO analysis of National Agricultural Worker Survey (NAWS) data. | GAO-19-26

Notes: Data in parentheses represent the margin of error at the 95 percent confidence level. All mean 

estimates are rounded to the nearest whole number, and margin of errors are rounded up to the next 

whole number. This analysis is not intended to assess whether this work complied with federal child 

labor requirements.

a

Estimate has a relative standard error between 31 and 50 percent and should be interpreted with 

caution.

Documentation status. According to our analysis of NAWS data, which 

is self-reported by workers, from 2013 to 2016, the majority of hired crop 

workers aged 17 and under were U.S. citizens, with some participation in 

the hired crop work force by children holding green cards or who were 

unauthorized workers, as defined for purposes of NAWS. Table 30 

presents details.

Table 30: Estimated Percentage of Hired Crop Workers Aged 17 and Under by 

Documentation Status, Fiscal Years 2013 to 2016

Fiscal years Citizen

(margin of error)

Green card

(margin of error)

Unauthorized

(margin of error)

2013 to 2016 73 (+/-16) 12 (+/-10)a 15 (+/-13)a

Source: GAO analysis of National Agricultural Worker Survey (NAWS) data. | GAO-19-26

Notes: Data in parentheses represent the margin of error at the 95 percent confidence level. All mean 

estimates are rounded to the nearest whole number, and margin of errors are rounded up to the next 

whole number. Table does not include results for Other Work Authorization, the results of which were 

not reportable for the time periods. NAWS also does not include workers employed on H-2A visas in 

its survey or in the survey results.

a

Estimate has a relative standard error between 31 and 50 percent and should be interpreted with 

caution.
Appendix V: Detailed Information on Hired 

Child Crop Workers in the United States

Page 86 GAO-19-26 Working Children

Region worked. Our analysis of NAWS data found a relatively even 

distribution of hired crop workers in the California, Midwest, and 

Northwest regions, with somewhat fewer workers in the Southeast and 

Southwest, for the time period from fiscal year 2005 to 2016. Table 31

presents the detailed results.

Table 31: Estimated Percentage of Hired Crop Workers Aged 17 and Under by Region, Fiscal Years 2005 to 2016

Region States Percentage of workers

in region

(margin of error)

California California 21 (+/-9)

East Connecticut, Delaware, Kentucky, Maine, Maryland, Massachusetts, New 

Hampshire, New Jersey, New York, North Carolina, Pennsylvania, Rhode Island, 

Tennessee, Vermont, Virginia, and West Virginia

15 (+/-8)

Midwest Illinois, Indiana, Iowa, Kansas, Michigan, Minnesota, Missouri, Nebraska, North 

Dakota, Ohio, South Dakota, and Wisconsin

23 (+/-10)

Northwest Colorado, Idaho, Montana, Nevada, Oregon, Utah, Washington, and Wyoming 21 (+/-8)

Southeast Alabama, Arkansas, Florida, Georgia, Louisiana, Mississippi, and South Carolina 11 (+/-5)

Southwest Arizona, New Mexico, Oklahoma, and Texas 10 (+/-6)

Source: GAO analysis of National Agricultural Worker Survey (NAWS) data. | GAO-19-26

Notes: Data in parentheses represent the margin of error at the 95 percent confidence level. All mean 

estimates are rounded to the nearest whole number, and margin of errors are rounded up to the next 

whole number. The NAWS is not administered in Alaska or Hawaii.

Applied or mixed pesticides within the last year. Our analysis of 

NAWS data shows that from 2003 to 2016, an estimated 14 percent (+/-

13 percent) of 16-year-olds and 8 percent (+/-7 percent) of 17-year-olds 

reported that in the past 12 months they had loaded, mixed, or applied 

pesticides.4

 4

These estimates have relative standard errors of between 31 and 50 percent and should 

be interpreted with caution. This analysis is not intended to assess whether this work 

complied with any applicable federal requirements, such as federal child labor 

requirements or the Environmental Protection Agency’s Worker Protection Standard. 
Appendix VI: Detailed Information on Children 

in the United States Who Work on Farms

Page 87 GAO-19-26 Working Children

Table 32: National Estimates of Children Working on U.S. Farms by Type of Farm, Type of Worker and Age, 2004, 2006, 2009, 

2012, 2014

Source: GAO analysis of Childhood Agricultural Injury Survey 2004, 2006, 2009, 2012, 2014 data. | GAO-19-26

Notes: The National Institute for Occupational Safety and Health’s (NIOSH) Childhood Agricultural 

Injury Survey defines a farm as being any crop and/or livestock operation with $1,000 or more of 

gross agricultural production within a calendar year. Farm type is determined by the type of 

production indicated for the respondent which represents the largest proportion of gross income for 

the farm operation. Working household children are defined as a member of the farm operator’s 

household who performed work or chores on the farm (regardless of pay), and is a subset of 

household children. Hired children are defined as children hired directly by the farm operator and paid 

for work performed on the farm. These exclude working household children and contract laborers. 

Data in parentheses represent the margin of error at the 95 percent confidence level. This analysis is 

not intended to assess whether this work complied with federal child labor requirements.

NIOSH also calculated the estimated number of children aged 12 and 

under in 2014 that worked on a U.S. farm, and estimated there were 

Appendix VI: Detailed Information on 

Children in the United States Who Work on 

Farms

Farm type Worker type Age 2004

(margin of 

error) 

2006

(margin of 

error)

2009

(margin of 

error)

2012

(margin of 

error)

2014

(margin of 

error)

Crop Working 

household

14 and 

under

158,811 (+/-

10,676)

121,513 (+/-

9,855)

107,097 (+/-

9,259)

99,571 (+/-

10,474)

100,288 (+/-

8,522)

15 to 17 87,811 (+/-

6,315)

76,662 (+/-

5,998)

64,350 (+/-

5,894)

64,448 (+/-

18,853) 

52,132 (+/-

4,733)

Total under 

18

246,622 (+/-

13,275)

198,175 (+/-

12,177)

171,447 (+/-

12,038)

164,019 (+/-

13,777)

152,420 (+/-

10,539)

Hired 14 and 

under

21,799 (+/-

4,929) 

15,378 (+/-

3,967) 

11,454 (+/-

4,092) 

10,059 (+/-

2,656) 

12,131 (+/-

2,954) 

15 to 17 84,561 (+/-

9,816)

75,446 (+/-

9,179)

52,101 (+/-

7,619)

56,194 (+/-

9,243)

67,195 (+/-

8,653)

Total under 

18

106,360 (+/-

11,785)

90,823 (+/-

10,741)

63,556 (+/-

9,937)

66,253 (+/-

9,967)

79,326 (+/-

9,643)

Livestock Working 

household

14 and 

under

228,838 (+/-

14,388)

192,802 (+/-

12,571)

171,374 (+/-

12,681)

142,377 (+/-

13,255)

145,549 (+/-

10,108)

15 to 17 115,245 (+/-

8,110)

106,205 (+/-

7,844)

94,087 (+/-

7,589)

81,688 (+/-

8,171) 

77,866 (+/-

5,892)

Total under 

18

344,083 (+/-

17,587)

299,007 (+/-

16,064)

265,460 (+/-

15,996)

224,064 (+/-

17,301)

223,415 (+/-

13,073)

Hired 14 and 

under

21,460 (+/-

5,917) 

14,036 (+/-

3,169) 

8,836 (+/-

2,325) 

12,934 (+/-

3,083) 

10,130 (+/-

2,785) 

15 to 17 71,190 (+/-

8,677)

79,360 (+/-

9,424)

51,003 (+/-

7,562)

51,505 (+/-

7,697)

58,389 (+/-

7,824)

Total under 

18

92,649 (+/-

11,358)

93,396 (+/-

10,635)

59,838 (+/-

8,103)

64,439 (+/-

8,953)

68,519 (+/-

8,522)

Total crop 

and livestock

Working 

household and 

hired

All under 

18

789,714 (+/-

54,006)

681,401 (+/-

49,617)

560,301 (+/-

46,074)

518,775 (+/-

49,998)

523,680 (+/-

41,777)
Appendix VI: Detailed Information on Children 

in the United States Who Work on Farms

Page 88 GAO-19-26 Working Children

68,866 (+/-7,023) working household children on crop farms, and 102,260 

(+/-8,328) working household children on livestock farms. Further, NIOSH 

calculations estimate the number of hired children aged 12 and under that 

worked on a U.S. farm in 2014 as being 2,693 (+/-1,186) on crop farms 

and 3,538 (+/-1,936) on livestock farms. Data in parentheses represent 

the margin of error at the 95 percent confidence level.
Appendix VII: Information on Work-Related 

Child Fatalities by Industry, 2003 to 2016

Page 89 GAO-19-26 Working Children

Table 33: Number of Work-Related Child Fatalities, by Detailed Industry, 2003 to 2016

General industry Detailed industry Sub-industry Number Percentage of total

Agriculture 237 52.4

Crop production 143 31.6

Oilseed and grain 

farming

19 4.2

Vegetable and melon 

farming

8 1.8

Fruit and tree nut 

farming

6 1.3

Other crop farming 24 5.3

Animal production and 

aquaculture

67 14.8

Cattle ranching and 

farming

56 12.4

Other animal production 6 1.3

Forestry and logging 5 1.1

Fishing, hunting and trapping 9 2.0

Support activities for agriculture 

and forestry

11 2.4

Construction and Mining 59 13.1

Mining, quarrying, and oil and 

gas extraction

3 0.7

Construction 56 12.4

Manufacturing 10 2.2

Wood product manufacturing 5 1.1

Wholesale and Retail Trade 33 7.3

Wholesale trade 14 3.1

Retail trade 19 4.2

Transportation and 

Warehousing

12 2.7

Truck transportation 9 2.0

Leisure and Hospitality 34 7.5

Arts, entertainment, and 

recreation

14 3.1

Accommodation and food 

services

20 4.4

Professional, business, and 

other services

55 12.2

Information 3 0.7

Appendix VII: Information on Work-Related 

Child Fatalities by Industry, 2003 to 2016
Appendix VII: Information on Work-Related 

Child Fatalities by Industry, 2003 to 2016

Page 90 GAO-19-26 Working Children

General industry Detailed industry Sub-industry Number Percentage of total

Professional and business 

services

31 6.9

Professional, scientific, 

and technical services

3 0.7

Administrative and 

support and waste 

management and 

remediation services

28 6.2

Educational and health services 5 1.1

Health care and social 

assistance

4 0.9

Other services, except public 

administration

16 3.5

Government, including public 

administration

11 2.4

Public administration 6 1.3

Source: GAO analysis of Census of Fatal Occupational Injuries (CFOI) data. | GAO-19-26

Note: Totals for general industries may not total the sum of detailed industries and sub-industries, 

because some data for detailed industries or sub-industries did not meet BLS publication criteria.
Appendix VIII: Selected Demographic 

Characteristics of Work-Related Fatalities, 

Children Aged 17 and Under, 2003 to 2016

Page 91 GAO-19-26 Working Children

With respect to gender, the data from BLS’s Census of Fatal 

Occupational Injuries show that 87 percent of the children killed due to 

work-related injuries were boys,1 and about 56 percent of the workrelated fatalities were incurred by children aged 16 or older. Boys aged 17 

and under suffered a work-related fatality about seven times more often 

than girls.

With respect to race and ethnicity, most children incurring work-related 

fatalities were white only (75 percent), as shown in table 34.

Table 34: Number and Percentage of Work-Related Child Fatalities, by Race and 

Ethnicity, 2003 to 2016

White only Hispanic Black only Other races Total

Number of children 340 89 11 11 451

Percentage of 

children

75 20 2 2 99a

Source: GAO analysis of Census of Fatal Occupational Injuries (CFOI) data. | GAO-19-26

Notes: The number of work-related fatalities reported in this table is one less than reported in table 3 

because, according to BLS, the fatality in table 3 did not meet publication criteria. Respondents who 

reported they were of Hispanic ethnicity and any race (for example, black and Hispanic) were counted 

as Hispanic; respondents who report they were of Hispanic ethnicity and two or more races were 

counted as Hispanic; respondents who did not report Hispanic ethnicity who also identified as two or 

more races were counted as “other races.”

a

Percentage does not sum to 100 percent due to rounding.

With respect to the event or exposure that contributed to a child’s death,2

our analysis of BLS data indicate that, from 2012 to 2016, 61 percent of 

the 119 work-related fatalities incurred by children aged 17 and under 

were due to a work- and transportation-related accident, including 

roadway incidents involving motorized land vehicles. Table 35 provides 

details on the types of event or exposure that caused the work-related 

child fatalities from 2012 to 2016.

 1

BLS reported gender information for 451 of the 452 work-related fatalities to children 

during the time period.

2

Our analysis was of the event or exposure, but not the source for a work-related fatality. 

Appendix VIII: Selected Demographic 

Characteristics of Work-Related Fatalities, 

Children Aged 17 and Under, 2003 to 2016
Appendix VIII: Selected Demographic 

Characteristics of Work-Related Fatalities, 

Children Aged 17 and Under, 2003 to 2016

Page 92 GAO-19-26 Working Children

Table 35: Causes of Work-Related Child Fatalities, 2012 to 2016

Event or exposure general 

category

Event or exposure specific 

category

Number Percentage 

to total for 

time period

Violence and other injuries 

by persons or animals

11 9

Intentional injury by person 6 5

Injury by person—

unintentional or intent 

unknown

3 3

Animal and insect related 

incidents

2 2

Transportation incidents 72 61

Animal and other nonmotorized vehicle 

transportation incidents

5 4

Pedestrian vehicular incident 4 3

Water vehicle incident 3 3

Roadway incident involving 

motorized land vehicle

26 22

Non-roadway incident 

involving motorized land 

vehicle 

33 28

Fire 1 1

Fall, slip, trip 5 4

Fall to lower level 5 4

Exposure to harmful 

substances or environments

5 4

Exposure to electricity 3 3

Exposure to other harmful 

substances

2 2

Contact with objects and 

equipment

23 19

Struck by objects or 

equipment

14 12

Caught in or compressed by 

equipment or objects

8 7

Source: GAO analysis of Census of Fatal Occupational Injuries (CFOI) data. | GAO-19-26

Notes: Totals for categories may contain subcategories not shown elsewhere, which did not meet 

Bureau of Labor Statistics publication criteria. Accordingly, some totals do not sum to that total’s 

specific subcategories. This analysis is not intended to assess whether this work complied with 

federal child labor requirements.
Appendix IX: Estimated Work-Related Injuries 

and Illnesses to Children Aged 17 and Under, 

15 and Under, and 14 and Under

Page 93 GAO-19-26 Working Children

Table 36: Estimated Work-Related Injuries and Illnesses to Children Aged 17 and Under, Aged 15 and Under, and Aged 14 and 

Under, 2003 to 2016

Bureau of Labor Statistics (BLS) Survey of Occupational Illness 

and Injuries (SOII)

National Institute for Occupational Safety and 

Health (NIOSH) National Electronic Injury 

Surveillance System – Occupational Supplement 

(NEISS-Work)

Year Total 

estimated 

number of 

work related 

injuries and 

illnesses

involving 

days away 

from work 

in 

thousands

Aged 15 to 

17, 

estimated 

number of 

injuries and 

illnesses in 

thousands

(margin of 

error)

Aged 15 to 

17, 

estimated 

percentage

of total 

injuries 

and 

illnesses 

that 

involved a 

day away 

from work

Aged 15 

and under, 

estimated 

number of 

injuries 

and 

illnesses 

(margin of 

error)a

Aged 15 

and under, 

estimated 

percentage

of total 

injuries 

and 

illnesses

Aged 17 and 

under, 

estimated 

number of 

injuries and 

illnesses in 

thousands 

(margin of 

error)

Aged 17 

and under, 

estimated 

percentage

of injuries 

and 

illnesses to 

total 

injuries and 

illnesses

Aged 14 

and under 

estimated 

number of 

injuries and 

illnesses in 

thousands 

(margin of 

error)

Aged 14 

and under,

estimated 

percentage

of total 

injuries 

and 

illnesses

2003 1,316 9.0 (+/-.457) 0.68% 220 (+/-69) .02% 54.8 (+/-11.1) 1.6% 3.8 (+/-1.6) 0.10%

2004 1,259 7.9 (+/-.431) 0.62% 200 (+/-67) .02% 53.9 (+/-11.7) 1.6% 3.7 (+/-1.7) 0.10%

2005 1,235 7.7 (+/-.423) 0.62% 90 (+/-44) .01% 54.7 (+/-13.7) 1.6% 3.2 (+/-1.4) 0.10%

2006 1,184 7.6 (+/-.313) 0.64% 190 (+/-47) .02% 56.1 (+/-14.8) 1.6% 3.4 (+/-1.7) 0.10%

2007 1,159 6.2 (+/-.301) 0.53% 420 (+/-76) .04% 53.6 (+/-13.5) 1.6% 4.8 (+/-2.3) 0.10%

2008 1,078 6.6 (+/-.325) 0.61% 130 (+/-42) .01% 40.1 (+/-12.2) 1.3% Not Reportable

2009 965 4.8 (+/-.291) 0.50% 180 (+/-52) .02% 29.4 (+/-7.5) 1.1% 2.8 (+/-1.5) 0.10%

2010 933 4.2 (+/-.245) 0.45% 280 (+/-59) .03% 27.3 (+/-6.9) 1.0% 2.7 (+/-1.5) 0.10%

2011 918 3.3 (+/-.232) 0.36% 200 (+/-53) .02% 28.0 (+/-7.7) 1.0% Not Reportable

2012 919 4.1 (+/-.250) 0.45% 110 (+/-38) .01% 27.2 (+/-6.3) 1.0% 3.2 (+/-1.5) 0.10%

2013 917 4.1 (+/-.259) 0.45% 120 (+/-42) .01% 30.4 (+/-8.2) 1.10% Not Reportable

2014 916 4.3 (+/-.268) 0.47% 140 (+/-91)b .02% 25.2 (+/-5.4) 0.90% Not Reportable

2015 902 5.2 (+/-.294) 0.57% 140 (+/-45) .02% 22.9 (+/-4.4) 0.90% Not Reportable

2016 892 5.1 (+/-.288) 0.57% 270 (+/-64) .03% 26.3 (+/-5.8) 0.80% 3.2 (+/-1.9)b 0.10%

Source: GAO analysis of Survey of Occupational Injuries and Illnesses (SOII) and National Electronic Injury Surveillance System—Occupational Supplement (NEISS-Work) data. | GAO-19-26

Notes: BLS published some estimates for work-related injuries and illnesses to 14-year-olds in certain 

years. More specifically, BLS from 2003 to 2015 estimated that there were 40 work-related injuries 

and illnesses to 14-year-olds in private industry in 2003; 20 in 2006; 120 in 2007; 60 in 2010; 120 in 

2011; 70 in 2012; 20 in 2013; 70 in 2014; and it estimated that there were 30 work-related injuries 

and illnesses to 14-year-olds in local government in 2009. These estimates have relative standard 

errors of 30 percent or less, except for the 2003, 2009 and 2013 estimates, which have relative 

standard errors higher than 30 but less than 50 percent and should be interpreted with caution; and a 

2005 estimate which we are not reporting because it has a relative standard error greater than 50 

percent. Further, estimates for 2008 to 2013 are for workers at private and public entities, while 

estimates from 2003 to 2008 are for private entities only. Total days away from work in this table are 

for private industry only. BLS estimated that in its data about 5 percent of injuries and illnesses in 

private industry and federal, local, and state government were illnesses. NIOSH technical information 

notes that NEISS-Work data from 2003 to 2014 include illnesses such as those that began at work 

(heart attacks or stroke), chronic conditions, and exacerbated long-term injuries; it estimates 5 to 10 

percent of all cases were such illnesses. The mean estimate for NEISS-Work may be higher than that 

Appendix IX: Estimated Work-Related 

Injuries and Illnesses to Children Aged 17 

and Under, 15 and Under, and 14 and Under
Appendix IX: Estimated Work-Related Injuries 

and Illnesses to Children Aged 17 and Under, 

15 and Under, and 14 and Under

Page 94 GAO-19-26 Working Children

listed because some observations were omitted to protect confidentiality related to the underlying 

individual data or other reasons. NEISS-Work data from 2015 onward do not capture most illnesses. 

Data in parentheses represent the margin of error at the 95 percent confidence level.

a

Table shows only private sector data for BLS’s SOII work-related injuries to children aged 15 and 

under. Number represents BLS’s estimate for children 15 or under who incurred a work-related injury 

resulting in at least one day of missed work. Estimates ranged from 90 to 420 such children.

b

This estimate has a relative standard error above 30 percent and less than 50 percent and should be 

interpreted with caution.
Appendix X: Estimated Work-Related Injuries 

and Illnesses to Children Aged 17 and Under, 

by Industry, 2003 and 2016

Page 95 GAO-19-26 Working Children

Table 37: Estimated Number of Work-Related Injuries and Illnesses to Children Aged 17 and Under, 2003 and 2016

2003 2016

Industry Sub-industry Weighted 

estimate 

(margin of 

error)

Number of 

working 

children aged 

15 to 17 in 

industry

Median 

days 

away 

from 

work

Weighted 

estimate 

(margin of 

error)

Number of 

working 

children aged 

15 to 17 in 

industry 

(margin of 

error) 

Median 

days away 

from work

Construction 500 (+/-133) 99,938 44 80 (+/-58)a 64,939 (+/-

24,587)

4

Educational and 

health services

560 (+/-101) 292,337 4 290 (+/-54) 259,092 (+/-

41,430)

4

Educational 

servicesc 136,596 60 (+/-25) 131,098 (+/-30,663)

6

Health care and 

social assistance

550 (+/-102) 155,741 4 230 (+/-49) 127,994 (+/-

29,966)

4

Financial Activities 130 (+/-52) 59,770 2 35,304 (+/-

16,933)

Finance and 

insurance

20 (+/-19)a 31,877 25 24,231 (+/-

15,462)a

Real estate and 

rental and leasingc 120 (+/-62) 27,893 2 11,072 (+/-7,632)a

Information 100 (+/-40) 81,240 2 30 (+/-23)a 28,425 (+/-

15,947)

2

Leisure and 

hospitality

3,940 (+/-448) 1,352,958 3 2,900 (+/-

284)

1,150,060 (+/-

95,973)

3

Accommodation 

and food services

3,560 (+/-502) 1,031,256 3 2,500 (+/-

284)

879,821 (+/-

85,907)

3

Arts entertainment 

and recreation

380 (+/-73) 321,702 3 400 (+/-82) 270,239 (+/-

39,682)

5

Manufacturing 280 (+/-61) 52,923 5 80 (+/-28) 48,977 (+/-

19,248)

3

Natural resources 

and mining

100 (+/-31) 138,563 2 110 (+/-35) 109,900 (+/-

28,488)

38

Agriculture forestry 

fishing and hunting

100 (+/-51) 138,080 2 50 (+/-30)a 109,900 (+/-

28,488)

7

Other services 

except public 

administration

290 (+/-85) 234,527 2 80 (+/-63)a 130,511 (+/-

31,631)

10

Professional and 

business services

240 (+/-91) 188,919 23 140 (+/-62) 111,500 (+/-

30,088)

2

Administrative and 

waste services

190 (+/-92) 135,612 23 30 (+/-28)a 72,773 (+/-

23,535)

3

Appendix X: Estimated Work-Related Injuries 

and Illnesses to Children Aged 17 and 

Under, by Industry, 2003 and 2016
Appendix X: Estimated Work-Related Injuries 

and Illnesses to Children Aged 17 and Under, 

by Industry, 2003 and 2016

Page 96 GAO-19-26 Working Children

2003 2016

Industry Sub-industry Weighted 

estimate 

(margin of 

error)

Number of 

working 

children aged 

15 to 17 in 

industry

Median 

days 

away 

from 

work

Weighted 

estimate 

(margin of 

error)

Number of 

working 

children aged 

15 to 17 in 

industry 

(margin of 

error) 

Median 

days away 

from work

Professional and 

technical servicesc 53,307 110 (+/-65)a 38,727 (+/-20,008)

2

Trade 

transportation and 

utilities

2,830 (+/-283) 718,283 6 1,040 (+/-

122)

468,038 (+/-

65,025)

3

Retail trade 2,250 (+/-273) 665,917 5 960 (+/-124) 431,141 (+/-

63,186)

3

Transportation and 

warehousing

440 (+/-97) 18,537 8 60 (+/-25) 27,168 (+/-

15,908)a 6

Wholesale trade 130 (+/-63) 33,829 2 Not 

reportableb 9,728 (+/-7,366)a Not reportableb

Total 8,970 (+/-457) 3,234,645 4 4,760 (+/-

271)

2,433,501 3

Source: GAO analysis of Survey of Occupational Injuries and Illnesses and Current Population Survey March 2017 ASEC data. | GAO-19-26

Notes: Annual Social and Economic Supplement (ASEC) data report information for the previous 

calendar year. Subcategories will not always add to totals because some data do not meet 

publication criteria. Industries combine into two domains: goods producing and service producing. 

Goods producing—with a weighted estimate of 270 (+/- 62) and median days away from work of 7 in 

2016—includes construction, manufacturing, and natural resources and mining. Service providing—

with a weighted estimate of 4,490 (+/- 273) and median days away from work of 3 in 2016—includes 

educational and health services, information, leisure and hospitality, other services except public 

administration, professional and business services, and trade transportation and utilities.

a

Relative standard error greater than 30 and less than 50, and should be interpreted with caution.

b

Estimate is not reportable as relative standard error is 50 or higher.

c

Educational services, as well as professional and technical services subcategories do not have data 

for 2003. Real estate and rental and leasing subcategory does not have estimate for 2016.
Appendix XI: Comments from the Department 

of Labor’s Occupational Safety and Health 

Administration

Page 97 GAO-19-26 Working Children

Appendix XI: Comments from the 

Department of Labor’s Occupational Safety 

and Health Administration
Appendix XII: Comments from the Department 

of Labor’s Wage and Hour Division

Page 98 GAO-19-26 Working Children

Appendix XII: Comments from the 

Department of Labor’s Wage and Hour 

Division
Appendix XII: Comments from the Department 

of Labor’s Wage and Hour Division

Page 99 GAO-19-26 Working Children
Appendix XIII: GAO Contacts and Staff 

Acknowledgments

Page 100 GAO-19-26 Working Children

Cindy Brown Barnes, (202) 512-7215 or brownbarnesc@gao.gov

Steve D. Morris, (202) 512-3841 or morriss@gao.gov

In addition to the individuals named above, Nagla’a El-Hodiri (Assistant 

Director), Thomas Cook (Assistant Director), Maria Gaona (Analyst-inCharge), Michelle Munn (Analyst-in-Charge), Danny Berg, T.C. Corless, 

Sarah Cornetto, Charles Culverwell, Caitlin Cusati, Justin Fisher, Kirsten 

Lauber, Patricia Moye, and Moon Parks made significant contributions to 

this report. Also contributing to this report were Eric Charles, Mimi 

Nguyen, Dan C. Royer, Almeta Spencer, Kiki Theodoropoulos and Kate 

van Gelder.

Appendix XIII: GAO Contacts and Staff 

Acknowledgments

GAO Contacts

Staff 

Acknowledgments

(101943)
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