Pennsylvania Department of Labor and Industry issues guidance on youth carriers.  

Last year, the Pennsylvania Department of Labor and Industry contacted a Pennsylvania newspaper after receiving a complaint about its practices with respect to youth carriers. The primary issues were: 1) the start time for minors -- they cannot start before 5 a.m.; and 2) whether the youth carriers under 16 had or needed employment certificates.

Since then, the PNA contacted the Department to discuss this issue in more detail. The Department has now posted some guidance on this issue on its Web site: http://www.dli.state.pa.us/landi/cwp/view.asp?a=142&Q=218690. 

The Department explains that minors working as independent contractors do not need employment certificates as long as the “minors are working independently of the newspaper publisher.” Factors to be considered include whether the minors purchase the newspapers from the publisher for resale to the consumer, and whether the newspaper publisher classifies the minors as employees of the newspaper.