Do state requirements concerning minor work permits apply to local governments?

After May 20, 2003, due to a statutory change to RCW 49.12.005(3), local governments are considered "employers" for purposes of the statute requiring work permits (RCW 48.12.123). Therefore, presumably, they should now be subject to the regulations adopted by the Department of Labor & Industries (L&I) imposing restrictions on the employment of minors (chapter 296-125 WAC). However, the current as of February 2004 position of the Department of Labor & Industries is that public employers are not required to obtain a minor work permit and comply with the state's minor work regulations.

This is because the current (1993) Minor Work Regulations, WAC 296-125-015 states: (4) "Employer" means any person, association, partnership, private or public corporation that employs or exercises control over the wages, hours, working conditions, or workplace of a minor, and for purposes of house-to-house sales includes any distributor or other person, association, partnership, private or public ... more.

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