Many Texas public school districts hire high school students for summer roles—supporting summer programs, clerical and departmental work, campus organization projects, childcare support, and limited food service assistance. These positions can benefit both students and districts, but they also introduce unique compliance, safety, and supervision considerations because the workers are minors in a school environment.

Compliance Considerations

1. Follow youth employment requirements

Districts should ensure roles for minors comply with applicable youth employment rules, including:

• • Federal FLSA youth employment requirements
  • Texas Workforce Commission (TWC) guidance for employing minors

Because restrictions can vary by age and task type, districts should confirm that duties and schedules are appropriate for the student’s age.

2. Align with district governance and procedures

Before posting or placing student workers, confirm the role and assignment process aligns with:

• • Board policy
  • Local administrative regulations
  • Campus/department-specific procedures (as applicable)

3. Create minor-appropriate job descriptions before posting

Pre-approved job descriptions are a key risk control. Build roles that clearly define what the student worker can and cannot do, including:

• • Minimum age requirement
  • Essential functions appropriate for minors
  • Explicit exclusions (e.g., no power-driven equipment, no driving district vehicles)
  • Work location(s), plus whether offsite work or travel is permitted
  • Identified supervisor

• • • “School-appropriate” duties (examples may include):
      • Clerical/office support
      • Library support and campus organization projects
      • Tutoring/academic program support
      • Technology inventory (excluding repairs)
      • Event setup/light duty tasks
    • Defined hours, break periods, and scheduling controls

Student Safety Best Practices

1. Create a “Do Not Assign to Minors” task list (and enforce it)

One of the most effective controls is a written Do Not Assign to Minors list. Require supervisors to sign an acknowledgment that they reviewed the list and will comply.

Common examples of tasks to restrict or avoid for minors (not exhaustive):

• • Power-driven machinery (many shop tools; compactors/balers; certain grounds equipment)
  • Roof work or ladder work at heights (changing gym lights, rooftop access)
  • Driving on district business (errands; transporting items or people)
  • Chemical-intensive work (certain custodial stripping/waxing chemicals, pesticides/herbicides, solvents)
  • Meat slicers and certain commercial kitchen equipment (food service duties must be tightly scoped)
  • Working alone in isolated areas (warehouses, mechanical rooms, remote campuses)

2. Add heat illness prevention if students work outdoors

For roles involving grounds, athletics support, or facilities support, implement a heat illness prevention plan that includes:

• • Hydration and access to water
  • Shade and cooling breaks
  • Acclimatization (gradual exposure)
  • Work/rest cycles
  • Training on heat illness symptoms
  • Clear escalation procedures

Also ensure injury reporting is simple and immediate—student workers may hesitate to report injuries or near-misses unless expectations are explicit.

Human Resources / Execution

1. Use a structured onboarding process for student workers

A Day 1 orientation checklist should include:

• • Reporting location and supervisor contact info; call-in procedures
  • Dress code and workplace expectations
  • Timekeeping basics (including no off-the-clock work)
  • Campus access controls (badges, keys, restricted areas)
  • Confidentiality expectations (including FERPA awareness if exposure is possible)
  • Technology acceptable use and password/security practices

2. Maintain minor-appropriate supervision and boundaries

Even as employees, student workers remain minors. Districts should build supervision practices that prevent foreseeable boundary issues, including:

• • Avoid assignments that create unsupervised one-on-one situations with younger students
  • Establish clear boundaries (examples):
    • No driving district vehicles
    • No transporting students
    • No being alone with a child in a closed room
    • “Open door” or observable workspace practices
  • Confirm completion of required district trainings (commonly child abuse reporting, harassment prevention, and general safety)

3. Protect confidential and sensitive information

Student workers may inadvertently access restricted records. Consider controls such as:

• • Avoid granting SIS access unless absolutely necessary
  • Restrict access to cumulative folders, discipline/504/IEP records, health records, and other protected information
  • Require a signed confidentiality acknowledgment
  • Instruct supervisors not to assign tasks that expose protected records

4. Apply standard employment controls

Treat student workers as employees with:

• • Accurate time entry
  • Clear overtime rules (if applicable)
  • Consistent pay practices

5. Screening and background check alignment

Follow district procedures for screening, including any fingerprinting/criminal history checks required by the role. Given the school environment, districts often apply stricter screening norms. Consider classifying roles as:

• • Tier 1: No student contact
  • Tier 2: Student contact with corresponding screening and training requirements per district policy (e.g., criminal history checks, sex offender registry checks, summer program requirements)

End-of-Summer Offboarding and Documentation

1. Offboard consistently

At the end of the assignment, ensure the district:

• • Collects keys/badges
  • Disables accounts
  • Retrieves district devices/equipment

2. Maintain an audit trail

Retain documentation such as:

• • Age verification
  • Assigned duties / job description
  • Training completion records
  • Supervisor acknowledgments (including “Do Not Assign to Minors” compliance)
  • Scheduling compliance records

Summer student worker programs can be successful when districts plan proactively. The most effective risk controls typically include minor-appropriate job descriptions, a signed “Do Not Assign to Minors” list, structured onboarding, clear supervision boundaries, confidentiality protections, and consistent offboarding documentation.

For more risk management resources, please contact an Insurance & Risk Management Advisor today.