Beware Hiring Underage Employees In Dealership Service Stations

Federal guidelines permit the employment of minors in dealership service departments, but only under certain strict conditions.

It seems that just about every car dealership operates a quick lube nowadays. These stations generate additional revenue and give customers a reason to be loyal for years to come. Of course, the real trick to an attached service station is to consistently provide efficient and excellent service. And to achieve this, you need quality lube technicians.

But, as most dealership service managers can tell you, good lube techs are hard to find — and even harder to keep. So what would you do as a service manager dealing with a staff shortage when you receive an application from "Adam," a 17-year old experienced lube tech? Let's consider a real-life scenario.

Adam Goes to Work and the DOL Visits

At the end of a chaotic week in the service station of a car dealership — made even worse by the abrupt resignation of a lube tech — the service manager, Sam, receives an application from Adam. Sam notices there is no checkmark next to the box that indicates, "I am at least 18 years old." Before Sam can toss the application, he notices that Adam has worked for nearly a year as a lube tech at another local dealership. Being so short-staffed, Sam invites Adam in for a trial run.

The next week, Adam arrives early to complete the necessary new-hire paperwork. During this process, the HR manager makes a copy of Adam's driver's license, which indicates he is only 17 years old. She asks Sam if he knows that Adam is not yet 18, to which Sam replies, "If he can change oil, I don't care if he's in middle school."

Adam's paperwork is processed and he gets right to work. After observing for a week, it is immediately clear that Adam knows what he is doing under the hood, and Sam offers Adam a full-time position. Unfortunately Adam's tenure with the dealership is short-lived when he relocates out-of-state after just a few months. Not long after, the HR manager retires from the dealership.

A year passes and the dealership receives notice of an audit from the U.S. Department of Labor. Peter, the new HR manager, takes the lead on collecting the requested documents and preparing for the onsite visit. When the investigator visits the dealership several days later to review the documents and meet with certain hourly employees, he asks whether the dealership has employed any minors. HR can think of no one and tells Ivan as much.

But, when the...