Prohibited and Permitted Duties for Minors

Division of Labor Standards and Statistics
707 17th Street, Denver, CO 80202 | 303-318-8441
www.ColoradoLaborLaw.gov | www.LeyesLaboralesDeColorado.gov

Interpretive Notice & Formal Opinion ("INFO") #22B: Prohibited and Permitted Duties for Minors

Overview

This INFO covers what types of work are allowed for minors under age 18, under the Colorado Youth Employment Opportunity Act ("CYEOA"), C.R.S. Title 8, Article 12, Colorado Youth Employment Standards Rules, 7 CCR 1103-20 ("YES Rules"), other Colorado laws applicable to employees and employers generally, and the federal Fair Labor Standards Act ("FLSA").[^1]

Types of Work Allowed and Prohibited by Age

(1) Federal and Colorado law limit certain tasks and types of work by age and certain work conditions:

• Below age 16: Federal law allows almost no work below age 14, and a limited range at ages 14-15. That means that of the work Colorado law allows below age 16, most is allowed only if federal law doesn't apply — mainly at very small employers.
• At ages 16-17: Colorado allows more work at age 14, but federal law allows a broad range of work only at ages 16-17. That means that in Colorado, most work is allowed at ages 16 and 17, subject to hours limits for minors (described in INFO #22A) and the restrictions detailed in this INFO.

(2) Colorado and federal law prohibit all minors from performing "hazardous work" and specific types of non-hazardous work unless:

(A) the work is performed in a qualifying apprenticeship or educational program, or
(B) the Division grants an exemption from the work prohibited by only Colorado law.[^2]

(3) This INFO discusses work that is either "prohibited" or "permitted" for minors.

• Prohibited duties include:
• Hazardous duties, which are specified in the CYEOA, and violations are subject to higher penalties and damages.
  • For some of these duties, the hazard is based on where the work is performed rather than what duties are performed, so minors may not be employed to perform any work in a hazardous area. For example, a minor may not perform otherwise permissible duties (such as cleaning) in an active mine.
• Specified non-hazardous duties, which are specified in YES Rule 9, and violations are subject to lower penalties and damages.[^3]
  • Permitted work can't include non-hazardous duties that are not permitted. For example, at age 14, restaurant work is permitted but not using certain power-driven food preparation devices. So restaurants can employ 14-year-olds, just not to use prohibited devices.
• Permitted duties are specified in the CYEOA and YES Rules. Minors under 16 are generally restricted to only work that is specifically permitted.
• An employer has the burden to show that its employment of a minor is permissible.

Duties Prohibited for All Minors and Limited Exceptions

(1) All minors may not perform "hazardous" work.

What is "hazardous" work? "Hazardous" work is any (A) work where duties are deemed hazardous by Colorado or federal law — regardless of location where and for what industry the duties are performed; (B) work where duties are considered hazardous based on location of where the duties are performed; and (C) work where duties are considered hazardous based on for what industry the duties are performed. An employer who permits a minor to perform hazardous work is subject to a minimum fine of $2,000 per violation.

(A) Per Se Hazardous Duties

The following duties are designated hazardous by Colorado or federal law — regardless of location where and for what industry the duties are performed, and so any minor cannot perform any job duty involving:[^4]

• operating any high-pressure steam boiler or high-temperature water boiler;
• the risk of falling from any elevated place located 10 feet or more above the ground for non-agricultural employment and 20 feet or more above the ground for agricultural employment;
• wrecking, except an employer engaged in only manual dismantling of automobiles without the use of power-driven equipment (i.e., a pick and pull lot) may employ a minor;
• excavation operations;
• operating specific power-driven machinery:[^5] woodworking machinery; metal forming, punching, or shearing machines; bakery machines; paper products machines; shears; automatic pin-setting machines; food processing equipment, including slicers and grinders; balers and compactors; construction and industrial machines; grinding, abrasive, polishing, or buffing machines; welding machines; rolling and shaping machines; dry cleaning and commercial laundry machines; hoisting machines; conveyors; other power-driven machinery declared hazardous under federal law;[^6] and
• work expressly prohibited as hazardous under federal law,[^7] such as: manufacturing, transporting, or storing explosives; manufacturing brick, clay construction, or silica refractory products; mining (including coal), logging, oil drilling, quarrying, wrecking, or demolition; any work with exposure to radioactive substances or ionizing radiation; driving or work as an outside helper on a motor vehicle on public roads, or at a mine, logging, or excavation site, except limited public road driving at age 17; operating a power-driven bakery machine; operating a power-driven hoisting machine, including a forklift; forest fire fighting/prevention, forestry, sawmill/timber tract; roofing or excavation; slaughter of livestock, and rendering and packaging of meat; and operating various power-driven machines.[^8]

Exceptions for Colorado per se hazardous duties[^9]

Work Colorado law declares hazardous is allowed at age 14,[^10] with no need for an exemption, if federal law does not apply and either:

1. after, or incidental to (part of), a program of — (a) apprentice training approved by, and registered with, Colorado's State Apprenticeship Agency[^11] or the USDOL (typically for national programs), as of age 16,[^12] or (b) student-learner occupational education, through a qualifying school or program;[^13] or
2. after — (a) training approved by the state board for community colleges and occupational education, or (b) an out of state occupational education program the Division determines is comparable.

Exceptions for federal per se hazardous duties

Work federal law declares hazardous is allowed only:

• at age 16-17; and
• in a qualifying program — (a) apprenticeships in a recognized trade approved by, and registered with, USDOL or Colorado's State Apprenticeship Agency (which may consider apprenticeships in certain hazardous work), or (b) student learning in a course of study and training in a cooperative training program under a recognized state or local educational authority or similar private school program;
• under certain work conditions (training, safety, supervision, limited hours, etc.); and
• only certain hazardous job duties: roofing or excavation; slaughter of livestock, and rendering and packaging of meat; or operating various power-driven machines.

(B) Location-Based Hazardous Duties

Any duty performed at any of the following locations is considered hazardous because the location makes the duty hazardous: any area where clay construction products or silica refractory products are manufactured or packaged; any area subject to exposure to radioactive substances or ionizing radiation; or in roofing, including all work on or about a roof or area where roofing is occurring (i.e., on the ground, in an area exposed to the risk of falling material).

(C) Industry-Based Hazardous Duties

Any duty performed for any of the following industries is considered hazardous: manufacturing, transporting, using, or storing explosives may not employ minors and no employer may permit a minor access to explosives or to work with explosives; mining, logging, oil drilling, or quarrying may not employ minors and no employer may permit a minor to enter or work in close proximity to a mine or quarry, sawmill, logging operation, or oil rig; or the slaughter of livestock or poultry or rendering and packaging of meat may not employ a minor and no employer may permit a minor to perform any duties related to the slaughter, rendering, or packaging of meat, or to enter any areas where slaughter is performed.

Exception: office, clerical, or retail duties performed for "hazardous" industry where work performed at a retail location or off-site from what makes the industry hazardous.[^14]

• A minor 16 or over may perform office, clerical, or retail work for an otherwise prohibited employer if the employer demonstrates that the minor is not exposed to the hazards commonly associated with that job or industry. The burden is on the employer to demonstrate that the work performed by the minor is safe.
• Generally, this exception applies to office work that is conducted off-site or at a retail location. For example, a minor may be permitted to work at the Denver headquarters of a mining company or at a storefront location for a custom furniture company with an off-site workshop.
• An employer does not need to, but may, seek an exemption from the Division to use this exception.

How to determine whether a minor can perform hazardous work under any exception:

1. Is the work covered by federal law? → If yes, go to step 2. If no, go to step 4.
2. Is the work listed as hazardous under federal law? → If yes, go to step 3. If no, go to step 4.
3. Is the work under a federally approved apprenticeship or student-learning program? → If yes, go to step 4. If no, the work isn't allowed.
4. Is the work listed as hazardous or prohibited under Colorado law? → If yes, go to step 5. If no, the work is allowed, other than any age-limited duties.
5. Is it in a qualifying apprentice, student-learner, or occupational program under state law? → If yes, the work is allowed. If no, the work isn't allowed, unless an exemption is granted.

Note that CYEOA hours limits still apply to approved apprentices or student-learners, unless an exemption (or school release permit) allows broader work hours.

(2) All minors may not perform non-hazardous work duties specified by applicable law.

The CYEOA and YES Rules further prohibit all minors from performing any of the following non-hazardous work duties:

• working with age-restricted substances or age-restricted employers:[^15]
• selling, dispensing, or serving alcoholic beverages, except minors may bus tables or handle empty alcoholic beverage containers;[^16]
• selling cigarettes, tobacco, or nicotine products;[^17]
• working in the marijuana industry;[^18]
• working in adult entertainment venues and strip clubs;[^19]
• working in casinos or other gambling establishments, except as permitted by the Colorado Limited Gaming Act;[^20] and
• working in locations where the primary activity is illegal, such as brothels or illegal gambling operations.
• working with known toxic or hazardous substances, including carcinogens, pesticides, corrosive materials, flammable or explosive substances, items with a skull and crossbones or "poison" on the label, and fumes or gases that are known to be hazardous to humans.[^21]
• working in confined spaces. Confined spaces have (a) limited entry and exit; (b) little to no ventilation; and (c) are not intended for human occupancy. Examples of prohibited confined spaces include tanks, ducts, silos, sewers, and utility tunnels.[^22]
• operating power-driven lawn equipment, unless (a) the minor receives adequate safety training, (b) the equipment and its use comply with applicable OSHA regulations, (c) the use of the equipment is not otherwise prohibited, and (d) the minor may not perform any maintenance or repair of the equipment.[^23]
• working in any manner that would violate occupational safety and health standards, as determined by the Occupational Safety and Health Administration.[^24]

Duties Expressly Permitted for Minors

The CYEOA and YES Rules explicitly permit all minors to perform some work and limit some minors to perform other kinds of work based on age.

(1) Duties Permitted for Minors Under 14

Minors under 14 are prohibited from most jobs, except those specifically allowed. The permitted jobs vary depending on whether federal law applies. Colorado law allows more work for minors under 14 than federal law.

Generally, the casual employment permitted under Colorado law is not subject to federal law. For example, baby-sitting and casual lawn work are unlikely to be subject to federal law, but may be subject to federal jurisdiction if performed on behalf of a larger enterprise, such as a commercial landscaping company or multistate babysitting agency.[^25]

(A) Requirements for all jobs worked by a minor under 14

Minors under 14 are not permitted to perform any work unless the minor has received appropriate first-aid and safety training and the employer ensures the work is adequately supervised by an adult.[^26] Adequate supervision does not always require an adult to be physically present. An employer must determine the appropriate level of training and supervision in each circumstance. When determining the appropriate level of training and supervision, employers should consider the following:

• The nature and hazards of the work involved. Some work, such as using power-driven lawn equipment, poses a greater risk of injury and requires more supervision.
• The location of the work. Less supervision is required in an area familiar to the minor, but more supervision is required when the work is in a distant or unfamiliar location.
• The individual minor. Some minors are relatively mature and experienced, so less supervision is required. If the minor has no experience (for example, it is their first time babysitting), a closer degree of supervision is required.

(B) Specific duties permitted for minors under 14

If federal law applies:

• Minors of any age are permitted to work (a) delivering newspapers or (b) acting or performing.
• Minors over 12 are permitted to perform non-hazardous agricultural work. Hazardous agricultural work is defined by federal law for minors under 16[^27] and includes: operating a tractor over 20 PTO horsepower; operating or working with a corn picker, cotton picker, grain combine, hay mower, forage harvester, hay baler, potato digger, mobile pea viner, feed grinder, crop dryer, forage blower, auger conveyor, unloading mechanism of a nongravity-type self-unloading wagon or trailer, power post-hole digger, power post driver, or nonwalking-type rotary tiller; operating or working with a trencher or earthmoving equipment, forklift, potato combine, or power-driven circular, band or chain saw; working in a yard, pen, or stall occupied by a bull, boar, or stud horse maintained for breeding purposes; a sow with suckling pigs; or a cow with a newborn calf (with umbilical cord present); felling, buckling, skidding, loading, or unloading timber with a butt diameter or more than 6 inches; driving a bus, truck or automobile to transport passengers, or riding on a tractor as a passenger or helper; 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; handling or applying toxic agricultural chemicals identified by the words "danger," "poison," or "warning," or a skull and crossbones on the label; handling or using explosives; and transporting, transferring, or applying anhydrous ammonia.

If federal law does not apply and only Colorado law applies:

• Minors of any age are permitted to perform: newspaper delivery; acting, performing, and modeling work; school work and supervised educational activities; and home chores/work for a parent who is not paid for the work.
• Minors over nine are permitted to work: delivering handbills, advertising, and advertising samples; shoeshining; gardening and lawn care with no power-driven lawn equipment; cleaning of walks with no power-driven snow-removal equipment; caddying on golf courses; and casual work at the employer's home not otherwise prohibited.
• Minors over 12 are permitted to work: baby-sitting; door-to-door selling and delivering merchandise; gardening and lawn care with two types of power-driven equipment: electric hand-held leaf blowers and electric string-type weed trimmers, provided adequate safeguards are met; cleaning of walks using power-driven snow-removal machinery, provided adequate safeguards are met; selling and delivering periodicals; and performing non-hazardous agricultural work, using the same definition of "hazardous" as federal law summarized above.

(2) Duties Permitted for Minors 14 and 15

Minors aged 14 and 15 are permitted to perform some work but are limited to only work specifically permitted. Colorado law allows 14- and 15-year-olds to perform more types of work than federal law, but still is limited to work specifically permitted.

(A) If federal law applies, minors over 14 are permitted to perform: office and clerical work, including operating office equipment; retail work: cashiering, selling, modeling, artwork, advertising work, window trimming, comparative shopping, bagging and carrying out customer orders; price marking or tagging; assembling orders; packing and shelving; errand and delivery work by foot, bicycle, and public transport; janitorial and custodial work, including the operation of vacuum cleaners and floor waxers; loading/unloading personal gear on motor vehicles that the minor will use at work: light, non-power-driven hand tools; personal protective gear; or other personal items; work at gas stations, including dispensing gasoline, oil, and other consumer items; courtesy service, car cleaning, washing, and polishing; at 15, lifeguarding at pools or water parks, but not natural water bodies (river, lake, etc.) until age 16; and intellectual or artistically creative work (such as programming, music, visual arts, teaching/tutoring, peer counseling).

(B) If only Colorado law applies, minors over 14 are permitted to perform: non-hazardous manufacturing, construction, and repair work; parks or recreation work, such as recreation aides or conservation projects; work operating automatic and enclosed elevators; warehousing, storage, and other vehicle loading/unloading work; in gasoline service, changing tires,[^28] and supervised use of manual hoists; and all work permitted by federal law for minors over 14.

(C) Food and Service Jobs for 14- and 15-year-olds. Under both Colorado and federal law, minors over 14 are permitted to work in food service, restaurants, hotels, and other public accommodations. Because Colorado law provides stronger protections for food and service workers, these restrictions apply to all employment. So minors aged 14 and 15 can perform only the following duties for food and service jobs: use dishwashers, toasters, automatic coffee machines, heat lamps and food warmers, and microwaves; clean equipment; and clean vegetables and fruits, and the wrapping, sealing, labeling, weighing, pricing, and stocking of items.

(3) Duties permitted for minors 16 or older

Minors 16 or older are permitted to perform all the duties permitted for both minors under 14 and minors 14 and older (without any additional age-specific conditions) and the following duties in food and service jobs: cooking, baking, or heating food over 140°F, including rotisseries, broilers, and other high-temperature cooking devices; handling hot liquids or oils; using knives without wearing cut-proof gloves; using hazardous power-driven machinery, including food slicers, grinders, mixers, and pizza dough rollers; and entering freezers or meat coolers, except occasionally and briefly to retrieve an item.

Heat Protections for All Minors

Employers must provide minors of any age working outdoors with protection from heat illness. The protections are the same that must be provided to agricultural workers. For full information on the required heat protection, see INFO #12C.

• When it is over 80 degrees Fahrenheit:
• Provide cool, clean, and close drinking water on shifts and breaks;
• Provide adequate shade for employees to use during rest, meal, cool-down, and other breaks; and
• Provide additional, preventative, cool-down rest when needed.
• When it is over 95 degrees Fahrenheit or other increased risk conditions apply:
• Provide Additional Rest Time. Employees must not perform more than two hours of work before at least 10 minutes of rest are provided.
• Provide notice to employees of their rights to drinking water, shade, and cool-down breaks.

For More Information: Visit the Division website, email [email protected], or call 303-318-8441. For federal law, see Child Labor Bulletin 101, visit www.dol.gov, or call 866-4USWAGE.

[^1]: U.S.C. Title 29, Chapter 8; see also FLSA regulations, including C.F.R. Title 29, Parts 570-579.
[^2]: The Division may grant an exemption from work prohibited by only Colorado law. For more information on exemptions, see INFO #22A.
[^3]: INFO #22A has the schedule of penalties and damages applicable to violations of the CYEOA.
[^4]: YES Rules, 7 CCR 1103-20, Rule 8.
[^5]: Examples of prohibited machines are contained in YES Rules, 7 CCR 1103-20, Rule 8.6.
[^6]: See Child Labor Bulletin 101 for more information regarding hazardous work under federal law.
[^7]: YES Rules, 7 CCR 1103-20, Rule 9.2.1. An employer subject to only Colorado law is subject to YES Rule 9.2 even though YES Rule 9.2 incorporates federal law.
[^8]: See Child Labor Bulletin 101 for more information regarding hazardous work under federal law.
[^9]: C.R.S. § 8-12-110(1). For details or more information on federal law, consult the USDOL or its materials.
[^10]: While state law allows exemption at 14, the Division would not grant an exemption for work covered by federal law, because federal law prohibits such work before that age. For more information on exemptions, see INFO #22A.
[^11]: Visit Apprenticeship Colorado (apprenticeship.colorado.gov), Colorado's State Apprenticeship Agency as of July 1, 2023, for resources such as: an apprenticeship program directory; apprenticeship postings; information for employers interested in apprenticeships; and contact information for questions. See C.R.S. Title 8, Article 15.7 (apprenticeship law).
[^12]: See C.R.S. § 8-15.7-101 (defining apprentice as someone 16 or older, unless other law sets a higher age). For a minor age 16-17, approval of a registered apprenticeship by Colorado's State Apprenticeship Agency, which can approve work Colorado law deems hazardous, means the work is permitted by the CYEOA, subject to applicable hours limits for minors.
[^13]: C.R.S. § 8-12-110(1)(b) ("a public school, local district college, community and technical college, federally funded work-training program, or private occupational school approved by the private occupational school division").
[^14]: YES Rules, 7 CCR 1103-20, Rule 8.12.
[^15]: YES Rules, 7 CCR 1103-20, Rule 9.2.2.
[^16]: Colorado Liquor Rules, 1 CCR 203-2, Reg. 47-913.
[^17]: C.R.S. § 44-7-103(4.5).
[^18]: C.R.S. § 44-10-307(1)(d).
[^19]: YES Rules, 7 CCR 1103-20, Rule 9.2.2.
[^20]: C.R.S. § 44-30-103(14); 1 CCR 207-1-1.
[^21]: YES Rules, 7 CCR 1103-20, Rule 9.2.3.
[^22]: YES Rules, 7 CCR 1103-20, Rule 9.2.5.
[^23]: YES Rules, 7 CCR 1103-20, Rule 9.2.6.
[^24]: YES Rules, 7 CCR 1103-20, Rule 9.2.7. When applying YES Rule 9.2.7, the Division will only find a violation if OSHA finds a violation.
[^25]: The Division offers these examples for the purpose of guidance only. Please consult an attorney for further guidance.
[^26]: YES Rules, 7 CCR 1103-20, Rule 9.4.2.
[^27]: 29 C.F.R. § 570.71; see Child Labor Bulletin 102.
[^28]: Except not inflating or changing tires mounted on rims with removable retaining rings.

INFOs are not binding law, but are the officially approved Division opinions and notices on how it applies and interprets various statutes and rules. The Division continues to update and post new INFOs; email [email protected] with any suggestions. To be sure to reference up-to-date INFOs, rules, or other material, visit ColoradoLaborLaw.gov. Last updated June 3, 2026