Roofing Operations – FLSA Child Labor Laws for 16 and 17 Year Olds


The Fair Labor Standards Act employers from employing any child under 18 years of age, except those employed in a qualified apprenticeship or student-learner program, in occupations in roofing operations and all occupations on or about a roof because they have been deemed to be particularly hazardous for them or detrimental to their health of well-being. 29 CFR 570.67(a)



On or about a roof

Work that is youth under 18 are prohibited from performing on or about a roof includes:

  • carpentry and metal work, alterations, additions, maintenance and repair, including painting and coating of existing roofs
  • the construction of the sheathing or base of roofs (wood or metal), including roof trusses or joists
  • gutter and downspout work
  • the installation and servicing of television and communication equipment such as cable and satellite dishes
  • the installation and servicing of heating, ventilation and air conditioning equipment or similar appliances attached to roofs
  • any similar work that is required to be performed on or about roofs

29 CFR 570.67(b)


Roofing operations

Roofing operations include:

  • installing roofs, including related metal work such as flashing
  • applying weatherproofing materials and substances, such as waterproof membranes, tar, slag or pitch, asphalt prepared paper, tile, composite roofing materials, slate, metal, translucent materials, and shingles of asbestos, asphalt, wood or other materials, to roofs of buildings or other structures
  • all jobs on the ground related to roofing operations such as roofing laborer, roofing helper, materials handler and tending a tar heater

29 CFR 570.67(b)


Age certification

Employers who employ minors are not in violation of the Fair Labor Standards Act’s child labor laws if they keep on file unexpired certificates of age for each minor employed which shows the minor is the appropriate age for the work being performed, even if the child turns out not to be the appropriate age. 29 US Code 203(l)(2); 29 CFR 570.5(a); 29 CFR 570.38; 29 CFR 570.121 For more information, visit our page on Age Certificates.