Can a 17 Year Old Work on a Roof?

Search this question and you get the same sentence a dozen times: you must be 18, no exceptions. That sentence is wrong, and being wrong in the other direction is worse, so here is the whole rule rather than half of it.

What does the federal roofing rule actually say?

Roofing is Hazardous Occupation Order 16, codified at 29 CFR 570.67. Its title is worth reading slowly: “Occupations in roofing operations and on or about a roof.” Two categories, not one.

“Roofing operations” is the obvious half. The regulation defines it as all work connected with installing roofs, including related metal work such as flashing, and applying weatherproofing materials to roofs. Then comes the part that catches employers out: the term “also includes all jobs on the ground related to roofing operations such as roofing laborer, roofing helper, materials handler and tending a tar heater.”

So a 17 year old who never leaves the driveway, loading bundles and keeping the tar heater going, is doing prohibited work. Staying off the roof is not a defense.

What counts as “on or about a roof”?

This is the half almost nobody prints, and it is where most real families run into the rule. The same section defines “on or about a roof” to include carpentry and metal work, alterations, additions, maintenance and repair, “including painting and coating of existing roofs”; the construction of roof sheathing, trusses and joists; “gutter and downspout work”; the installation and servicing of television and communication equipment such as cable and satellite dishes; and the installation and servicing of heating, ventilation and air conditioning equipment attached to roofs.

The Department of Labor’s plain-language Fact Sheet #74 goes further and says the rules reach “standing or working on a ladder or scaffold at or near the roof, as well as working from or being transported to or from the roof in mechanical devices such as hoists.”

Read that list against the jobs teenagers actually get. Gutter cleaning. Dish installation. Helping at an HVAC company. Painting. None of those advertise themselves as roofing, and all of them are inside Order 16.

Who is exempt, and what does the exemption require?

Order 16 ends with one sentence that changes the answer: 29 CFR 570.67(c) says “This section shall not apply to the employment of apprentices or student-learners under the conditions prescribed in 570.50 (b) and (c).” Fact Sheet #74 puts it in ordinary English: the rules allow 16 and 17 year olds employed under a bona fide apprenticeship or student-learner program to perform work that would otherwise be prohibited.

That is not a permission slip. The conditions in 29 CFR 570.50 are strict, and all of them have to hold at once.

For a registered apprentice, all four of these: the apprentice is employed in a craft recognized as an apprenticeable trade; the hazardous work is “incidental to his training”; that work “is intermittent and for short periods of time and is under the direct and close supervision of a journeyman”; and the apprentice is registered with the federal Bureau of Apprenticeship and Training [now the Office of Apprenticeship] or a recognized state apprenticeship agency, or employed under a written agreement the Secretary of Labor finds substantially conforms to those standards.

For a student-learner, the teenager must be enrolled in a cooperative vocational training program under a recognized state or local educational authority, or a substantially similar program at a private school, and must be employed under a written agreement providing that the hazardous work is incidental to the training, that it is intermittent, for short periods and under the direct and close supervision of a qualified and experienced person, that the school gives safety instruction which the employer correlates with the on-the-job training, and that a schedule of organized and progressive work processes has been prepared. The agreement is signed by both the employer and the school coordinator, and both keep a copy on file.

Two words do most of the work. Intermittent and incidental. A 17 year old apprentice cannot be put on a roof for eight hours a day and called exempt. If roof work is the job rather than a slice of the training, the exemption is not doing what the employer thinks. Note the age floor too: the exemption is written for 16 and 17 year olds, and a 15 year old does not get it.

Why can an apprentice go on the roof but not ride the lift up?

This is the asymmetry that turns the rule from an academic point into a practical one.

Power-driven hoisting apparatus is Order 7, at 29 CFR 570.58, and it contains no apprentice or student-learner exemption at all. Its opening line bars the work of operating, tending, riding upon, working from, repairing, servicing or disassembling an elevator, crane, derrick, hoist or high-lift truck, with only narrow exclusions such as riding an unattended automatic passenger elevator. The regulation defines a hoist as a power-driven apparatus for raising or lowering a load by applying a pulling force, and a manlift as a device intended for conveying persons on an endless belt, cable or chain.

That phrase “high-lift truck” is the part almost everyone misses, and the regulation defines it by name. It covers fork lifts, fork trucks, fork lift trucks, tiering trucks, backhoes, front-end loaders, skid loaders, skid-steer loaders, Bobcat loaders and stacking trucks. Low-lift trucks and low-lift platform trucks, which move materials without tiering them, are outside it. So a forklift, a skid steer and a backhoe sit in the same order as the crane, and none of them is exemptible for anybody under 18.

Put the two orders side by side. Roofing is exemptible. The machinery that carries a worker up to the roof is not. Fact Sheet #74 is explicit that being transported to or from a roof in mechanical devices such as hoists is inside the roofing rules, and Order 7 independently bars riding upon or working from that equipment with no exemption available.

If an employer says the apprenticeship covers everything, ask how he is getting up there and who is running the lift. Whether a particular aerial lift meets those definitions is a fact question, and the safe assumption is that a minor neither operates it nor rides it.

What does this look like on a real job?

Elias is 17 and two months into a state-registered sheet metal apprenticeship. His crew is servicing a rooftop condenser on a two-storey commercial building.

Because his program is registered and the work is a genuine part of his training, Order 16 does not stop him from being on that roof. His journeyman goes up the building’s permanent access ladder with him and stays with him. Elias is up there for about forty minutes, doing one supervised task on the unit, then comes down. That fits the four conditions: apprenticeable craft, incidental to training, intermittent and short, direct and close supervision.

What Elias does not do is ride the lift the crew used to get the replacement coil onto the roof, and he does not operate it. Order 7 has no exemption, so his apprentice status does nothing for him there. An adult crew member runs the lift and sends the material up.

This example is illustrative rather than a real crew, but the split it shows is the one small employers most often get wrong.

How dangerous is roofing, really?

Honestly: it is the outlier. In 2024, BLS recorded a fatal injury rate for roofers of 48.7 per 100,000 full-time equivalent workers, from 104 deaths, against an all-worker rate of 3.3. That is roughly fifteen times the national figure, and it is why the conditions on the exemption are written as tightly as they are. The comparison across trades is in which trades are actually dangerous, and the ranking most people carry in their head turns out to be wrong in both directions.

Falls are not a carelessness problem you can train a teenager out of in an afternoon. They are inherent to the work, which is why federal law treats roof work as a category rather than a judgment call.

Could my state be stricter?

Yes, and several are. The Department of Labor’s rule is that where a state child labor law is less restrictive than federal law the federal law applies, and where a state law is more restrictive, the state law applies. Some states restrict roof work for minors more tightly than Order 16 does.

Check your state before your teenager takes a job that involves height, and if the answer matters financially or legally, ask your state labor department or a lawyer. This page is general information, not legal advice. A good next step is what your teen can legally do at work, and if the job is attached to a training program, what age a teen can start an apprenticeship covers how registration actually happens.