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Referring child-labor hazards between OSHA and WHD

Summary OSHA reminded its regional and area offices to use a referral system with the Wage and Hour Division for matters involving workers under 18. The 1999 memo directed staff to review the earlier interagency agreement and make referrals as needed. The posted page does not say whether that historical procedure remains in force.
Document
Federal guidance
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1999-07-13-2
Date issued
July 13, 1999
Status
Unknown
The memo refers offices to a 1991 interagency agreement and historical instruction; the posted page does not establish whether the referral procedure remains in force.
Status last verified October 9, 2026
Topics
Workplace Safety Child Labor Enforcement
Source
View the official document

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The current status of this document is unclear
The memo refers offices to a 1991 interagency agreement and historical instruction; the posted page does not establish whether the referral procedure remains in force. It may no longer reflect the agency's current position. Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
About this page: The full text below is the official document from Occupational Safety and Health Administration (OSHA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.

DATE: July 13, 1999

MEMORANDUM FOR: REGIONAL ADMINISTRATORS; STATE DESIGNEES

THROUGH: R. DAVIS LAYNE, DEPUTY ASSISTANT SECRETARY

FROM: RICHARD FAIRFAX, DIRECTOR, DIRECTORATE OF COMPLIANCE PROGRAMS

SUBJECT: Child Labor: Importance of the Referral System Established in the Memorandum of Understanding (MOU) between the Employment Standards Administration (ESA), Wage and Hour Division, and OSHA

On February 28, 1991, OSHA published CPL 2.92, Memorandum of Understanding (MOU) between the Employment Standards Administration, Wage Hour Division, and the Occupational Safety and Health Administration (OSHA). Subsequently, on June 3, 1991, OSHA published a change to CPL 2.92 to correct the IMIS code provided for tracking referrals related to child labor issues and to clarify that referrals received from ESA/WH under the MOU were considered Safety and Health Agency Referrals.

The MOU between ESA/WH and OSHA sets forth a working relationship between the two agencies in order to protect the health and well-being of the Nation's work force. It established a referral system between the two agencies which provides for a coordinated enforcement effort, thereby securing the highest level of compliance with the Occupational Safety and Health Act (OSH Act) and the various Federal Wage and Hour Laws.

This memorandum is sent to bring your attention to the importance of this document and the referral system established within the MOU. Adherence to the referral system is important in OSHA's efforts to provide more effective protection for young workers, who are especially vulnerable to workplace hazards. Young workers in this situation are those employees who are less than 18 years old. Please ensure that both the Regional and Area Office staff are aware of this document and make referrals to ESA as necessary.

Because this document is voluminous, we have not included it with this memorandum. It is available on OSHA's website at:

http://www.osha.gov/OshDoc/Directive_data/CPL_2_92.html

If you have any questions, please contact Renee Carter or William Smith in the Office of General Industry Compliance Assistance at (202) 693-1850.

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