What Your Teen Can Legally Do at Work
What Power Tools Can a 16 Year Old Legally Use?
Three of the federal hazardous occupations orders do most of the work here: Order 5 covers power-driven woodworking machines, Order 14 covers circular saws, band saws, guillotine shears, chain saws, reciprocating saws, wood chippers and abrasive cutting discs, and Order 12 covers balers, compactors and paper-products machines. In ordinary employment, nobody under 18 may operate those machines, or set up, adjust, repair, oil or clean them. All three orders carry the apprentice and student-learner exemption, so a 16 or 17 year old in a registered apprenticeship or a school program with a written agreement may use them under strict written conditions.
Most pages on this topic say minors “cannot use dangerous power tools,” which is not a rule and cannot be checked against anything. The federal rules are specific. They name machines. Here is what they name.
One thing first. The hazardous occupations orders apply to everyone under 18. A 14 or 15 year old is restricted further, to a narrower list of permitted jobs that Fact Sheet #43 describes as non-manufacturing and non-hazardous, so nothing on this page is available to them at all, exemption or no exemption. The apprentice and student-learner exemption is written for 16 and 17 year olds.
What does Order 5 cover, and how wide is “woodworking machine”?
29 CFR 570.55 covers power-driven woodworking machines. Here is the definition in full, because the second half of it does most of the work and almost everybody quotes only the first half:
Power-driven woodworking machines shall mean all fixed or portable machines or tools driven by power and used or designed for cutting, shaping, forming, surfacing, nailing, stapling, wire stitching, fastening or otherwise assembling, pressing or printing wood, veneer, trees, logs, or lumber.
Note “portable.” A cordless track saw is as much in scope as a table saw bolted to the floor. Then note “fastening or otherwise assembling,” and note that the object of the whole sentence is wood, veneer, trees, logs or lumber. Those words reach further than a list of saws does.
Three activities are prohibited: operating such machines, including feeding material into them; setting up, adjusting, repairing, oiling or cleaning them; and off-bearing from circular saws and veneer clippers. Off-bearing is the job of taking the cut piece away on the outfeed side, and people are always surprised it is named separately.
Order 5 carries the apprentice and student-learner exemption.
So can a 16 year old use a cordless drill?
This page cannot tell you, and the honest reason is worth reading.
The obvious answer is that a drill is not a saw and is not named anywhere in Order 5, Order 12 or Order 14. But read the definition above again. It reaches machines and tools “used or designed for … fastening or otherwise assembling … wood, veneer, trees, logs, or lumber.” A power driver sinking screws into lumber is a portable tool driven by power, used for fastening wood. That is not a stretch of the words. It is the words.
What would settle it is a Department of Labor interpretation naming the tool. This site did not find one. No fact sheet, no opinion letter, nothing that says a cordless drill or driver is in or out of Order 5. So the site is not going to print a clearance, because a clearance would be the site’s opinion dressed as a rule, and this is a page about a teenager holding a tool.
What to do instead: ask before the shift, not after it. Your state labor department is the first call, and the federal Wage and Hour Division is the second. Child labor complaints and questions to the Wage and Hour Division are free and confidential. Ask them plainly: does the department treat a cordless drill or driver used on wood as a power-driven woodworking machine under 29 CFR 570.55. An answer from them is about your teenager and your state, which is more than this page can give you.
What does Order 14 cover?
29 CFR 570.65 is the one to memorise, because its list is the contents of a working van. It covers circular saws, band saws, guillotine shears, chain saws, reciprocating saws, wood chippers and abrasive cutting discs.
It prohibits operating or assisting to operate those machines, and it prohibits setting up, adjusting, repairing, oiling or cleaning them.
There is one exception inside the order and it is narrower than people assume. Machines equipped with full automatic feed and ejection are carved out, but that clause attaches only to the three machines in the order’s first list: circular saws, band saws and guillotine shears. Chain saws, reciprocating saws, wood chippers and abrasive cutting discs sit in a separate paragraph with no feed-and-ejection exception at all.
“Abrasive cutting discs” is the sleeper term. It reaches an angle grinder with a cut-off wheel and an abrasive chop saw, tools that live in the back of every trades vehicle in the country. “Reciprocating saws” reaches the demolition saw everyone calls a Sawzall. Order 14 also carries the apprentice and student-learner exemption.
What does Order 12 cover, and why is the baler different?
29 CFR 570.63 covers balers, compactors and paper-products machines. This is the retail and grocery rule rather than the construction one, and it is the one most likely to touch a teenager’s first job. It prohibits operating or assisting to operate the covered machines, and setting up, adjusting, repairing, oiling or cleaning them.
Order 12 then has two separate provisions that get merged constantly, and they are not the same thing.
570.63(c)(1) is a loading exception open to any 16 or 17 year old, apprentice or not. It permits loading materials into, but not operating or unloading, a conforming scrap paper baler or paper box compactor. It comes with conditions, including that the machine meets the applicable ANSI standard, that the controls are key-locked with the key held by an employee aged 18 or over, that the switch is kept off when the machine is not in use, and that safety notices are posted.
570.63(c)(2) is the ordinary apprentice and student-learner exemption, which is broader but requires the written program.
Load only, under 570.63(c)(1). Operate or unload, and you need the exemption at (c)(2) or you need to be 18.
What does this look like as a table?
Every row assumes federal law only, and assumes the worker is 16 or 17. Under 16, the answer is no across the board.
| Tool or machine | Order | Ordinary employment, 16 or 17 | Registered apprentice or student-learner, 16 or 17 |
|---|---|---|---|
| Table saw, miter saw, circular saw | 5 and 14 | No | Yes, under the written conditions |
| Band saw | 14 | No | Yes, under the written conditions |
| Reciprocating saw | 14 | No | Yes, under the written conditions |
| Chain saw | 14 | No | Yes, under the written conditions |
| Angle grinder with cut-off wheel, abrasive chop saw | 14 | No | Yes, under the written conditions |
| Wood chipper | 14 | No | Yes, under the written conditions |
| Guillotine shear | 14 | No | Yes, under the written conditions |
| Router, planer, jointer, power sander | 5 | No | Yes, under the written conditions |
| Power nailer or stapler | 5 | No | Yes, under the written conditions |
| Cleaning or oiling any machine above | 5, 12, 14 | No | Yes, under the written conditions |
| Off-bearing from a circular saw | 5 | No | Yes, under the written conditions |
| Loading a conforming scrap paper baler | 12 | Yes, loading only, conditions at 570.63(c)(1) | Yes |
| Operating or unloading a baler or compactor | 12 | No | Yes, under the written conditions |
| Cordless drill or driver | Not named in 5, 12 or 14, but see the Order 5 definition | This tool cannot tell you. Ask your state labor department or the Wage and Hour Division first | This tool cannot tell you. Ask your state labor department or the Wage and Hour Division first |
The last row used to say the drill was not covered by these three orders. That was a clearance built on half of a definition, and it was the one thing on this page a parent could have acted on without checking anything. The reasoning behind the change is in the cordless drill section above.
What are the written conditions, exactly?
They live in 29 CFR 570.50 and they are the whole substance of the exemption.
A registered apprentice must meet four conditions together: employment in a craft recognized as an apprenticeable trade; hazardous work that is “incidental to his training”; work that “is intermittent and for short periods of time and is under the direct and close supervision of a journeyman”; and registration with the federal Bureau of Apprenticeship and Training [now the Office of Apprenticeship] or a recognized state apprenticeship agency, or employment under a written agreement found to conform substantially to those standards.
A student-learner must be enrolled in a cooperative vocational training program under a recognized state or local educational authority, or a substantially similar private school program, and employed under a written agreement stating 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 correlated by the employer with the on-the-job training, and that a schedule of organized and progressive work processes has been prepared. The employer and the school coordinator both sign it, and both keep a copy.
Intermittent and incidental are the words that decide most real cases. If a 17 year old spends the shift on the saw, the exemption is not covering it, whatever paperwork exists.
And the exemption is order by order. It reaches seven of the seventeen orders and no others, which DOL’s Fact Sheet 43 states plainly: Orders 5, 8, 10, 12, 14, 16 and 17. It does not exist at all in Order 7, power-driven hoisting apparatus, which is why a 17 year old apprentice may work on a roof but may not ride the lift up. Order 7 is also the one that most often surprises a tools-and-machines conversation, because its definition of a high-lift truck names fork lifts, tiering trucks, backhoes, front-end loaders, skid loaders, skid-steer loaders and Bobcat loaders. A registered apprentice may, under the written conditions, dig and backfill a trench under Order 17. The skid steer that digs it is Order 7 and is not exemptible for anyone under 18.
What does this look like on a real job?
Talia is 16 and enrolled in her high school’s cabinetmaking co-op, placed two afternoons a week with a local millwork shop. The written agreement is on file at the school and at the shop, signed by the shop owner and the program coordinator, and it lists the machines she will be trained on in sequence.
Under that agreement she can be taught the table saw, and she is: short supervised cuts with the lead hand at her shoulder, one step in a sequence that started with hand tools. She is not left on the saw for the afternoon, because that would stop being incidental to training and the exemption would stop applying.
On Saturdays she works at a grocery store. No written agreement there, so no exemption. She may load cardboard into the store’s scrap paper baler under the loading exception, provided the machine and the store meet the conditions, and she may not operate it or unload the bale. Her manager holds the key.
This is illustrative rather than a real shop, but the two halves of it are the two situations most families are actually in.
What if my state says something different?
Then your state probably wins. The Department of Labor’s rule is that a stricter state rule displaces the federal one, and a looser state rule does not, and where it is less restrictive, federal law applies. Several states restrict tools and machines for minors beyond the federal orders.
Check your own state first, and if there is money or a job at stake, ask your state labor department rather than the employer. This page is general information, not legal advice. For the wider framework, child labor laws explained for parents sets out the ages and hour limits that sit underneath all of this.
Questions parents keep asking
Can a 16 year old use a cordless drill at work?
This page cannot tell you, and it is not going to guess. No drill is named in Order 5, Order 14 or Order 12. But Order 5 defines a power-driven woodworking machine as any fixed or portable machine or tool driven by power and used or designed for cutting, shaping, forming, surfacing, nailing, stapling, wire stitching, fastening or otherwise assembling, pressing or printing wood, veneer, trees, logs or lumber. A driver sinking screws into lumber is a portable power tool used for fastening wood, so the definition arguably reaches it. No Department of Labor interpretation resolving cordless drills or drivers was found for this site. Put the question to your state labor department or the federal Wage and Hour Division before the shift, not after it.
Is a nail gun covered?
The Order 5 definition of a power-driven woodworking machine includes machines and tools driven by power and used or designed for nailing and stapling, so a power nailer is in scope. It is exemptible for a registered apprentice or student-learner under the written conditions, and prohibited otherwise for anyone under 18.
What about an angle grinder or a chop saw?
Order 14 names abrasive cutting discs, which brings in an angle grinder fitted with a cut-off wheel and an abrasive chop saw, and it names reciprocating saws, which brings in the ordinary reciprocating demolition saw. These are the tools a 17 year old is most likely to be handed on a job site, and they are prohibited without the exemption.
My teenager just cleans the machines after close. Is that fine?
No. Both Order 5 and Order 14 prohibit “setting up, adjusting, repairing, oiling, or cleaning” the covered machines, and Order 12 uses the same words. The machine being switched off does not take the task outside the rule.
Does a school shop class count as a student-learner program?
Not by itself. The exemption is about employment, and it requires enrollment in a cooperative vocational training program plus a written agreement signed by the employer and the school coordinator with specific terms in it. Ask to see the agreement. If nobody can produce one, the exemption is not in place. See work permits and age certificates for the paperwork that usually sits alongside it.