The national baseline
State licensing varies, but a federal floor applies to every U.S. camp. Four rules matter most, and where state law is stricter, the stricter rule wins.
The seasonal-camp exemption
Under the Fair Labor Standards Act (§13(a)(3)), employees of an “organized camp” can be exempt from federal minimum wage and overtime if the camp either does not operate more than seven months a year, or meets a seasonal-receipts test. Two cautions: central-office staff serving a chain of camps are not covered, and some state wage laws do not recognize the exemption, in which case the state rule applies. Do not assume the exemption without checking your state.
Child-labor rules for teen employees
Camps employ a lot of teenagers, so federal youth-employment rules apply:
- 16 is the basic minimum working age; 16- and 17-year-olds may work unlimited hours in non-hazardous jobs.
- 14- and 15-year-olds may work only outside school hours, up to 8 hours on a non-school day and 40 in a non-school week, and only between 7 a.m. and 7 p.m. (extended to 9 p.m. from June 1 to Labor Day).
- Counselors who drive campers should be 18 or older; federal rules sharply restrict minors operating motor vehicles.
- Lifeguards may be 15 at pools but must be 16 at natural waterfronts.
Federal law does not require work permits, but many states do, and the seasonal wage exemption does not exempt a camp from these youth-employment limits.
OSHA bloodborne pathogens
OSHA's bloodborne-pathogens standard (29 CFR 1910.1030) covers camp staff “designated as responsible for rendering medical assistance”. In a letter addressed specifically to summer camps, OSHA explained that designated first-aid responders need an exposure-control plan, training and the offer of the hepatitis B vaccine. Staff who give first aid only as a collateral duty get a narrow exception if the camp reports blood exposures, offers the vaccine afterward, and trains on the procedure, but camp nurses and health-center staff are fully covered.
The Americans with Disabilities Act
Private camps are public accommodations under ADA Title III; municipal camps fall under Title II. The Department of Justice's position is that camps must make reasonable modifications unless they would fundamentally alter the program, must evaluate each child individually, “cannot be required to pay the cost of the reasonable modifications” onto parents, and must train staff to give medications such as insulin and glucagon. Religious organizations are exempt from Title III, and new or altered facilities must also meet ADA accessibility standards.
Related resources
Return to the founding overview, or see State licensing and Camp types.
Frequently asked questions
- Can a camp pay below minimum wage? Possibly. The FLSA seasonal-camp exemption (§13(a)(3)) can exempt an organized camp from federal minimum wage and overtime if it operates seven months or less or meets a receipts test, but some state wage laws override it, so the stricter rule applies.
- How old must camp staff be under federal law? 16 is the basic minimum. 14- and 15-year-olds may work limited hours outside school and only 7 a.m.–7 p.m. (9 p.m. in summer). Drivers should be 18+, and lifeguards must be 16 at natural waterfronts.
- What is the OSHA bloodborne-pathogens rule for camps? Staff designated to give medical assistance need an exposure-control plan, training and the offer of a hepatitis B vaccine. A narrow exception exists for collateral-duty first-aiders, but camp nurses and health staff are fully covered.
- Does the ADA apply to summer camps? Yes. Private camps are covered by ADA Title III and municipal camps by Title II. Camps must make reasonable modifications, assess each child individually, not charge parents for those modifications, and train staff to give medications. Religious organizations are exempt from Title III.
- Do camp staff under 18 need work permits? Federal law does not require them, but many states do. The seasonal wage exemption does not remove youth-employment restrictions, so check your state's work-permit and hours rules.