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
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.
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)
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
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)
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
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
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)
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
Apply standard employment controls
Treat student workers as employees with:
Accurate time entry
Clear overtime rules (if applicable)
Consistent pay practices
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
Offboard consistently
At the end of the assignment, ensure the district:
Collects keys/badges
Disables accounts
Retrieves district devices/equipment
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.