Proposed: Minimum Employment Age Raised to 18

Summary#

On July 2, 2022, the government published the proposed Regulations Amending the Canada Labour Standards Regulations (Employees Under 18 Years of Age).
If adopted, the rules in the Canada Labour Standards Regulations (CLSR) that now refer to age 17 would be changed to refer to age 18, tightening limits on hazardous and night work for people under 18 in federally regulated workplaces. This is a proposal (not yet law) and was expected to come into force by spring 2023 if the linked changes to the Canada Labour Code are proclaimed.

What it does#

• Raises the age reference in the Canada Labour Standards Regulations (CLSR) from 17 to 18.
• Keeps the rule that anyone under 18 cannot be employed in work listed as hazardous, or in work likely to harm their health or safety.
• Keeps the night-work ban: employees under 18 may not work between 11:00 p.m. and 6:00 a.m..
• Requires employers to record the age of employees who are under 18.
• Makes two small wording fixes in the regulations (one English phrasing change and one French time formatting update).
• The change is meant to align the CLSR with amendments already passed to the Canada Labour Code (via the Budget Implementation Act, 2018, No. 2) and with Canada’s international obligation under the International Labour Organization (ILO) Minimum Age Convention, 1973 (C138).

Who's affected#

• Young people who are 17 and currently working, or seeking work, in federally regulated workplaces. The government survey cited 1,369 employees under 18 in federal jurisdiction out of 895,100 total federally regulated employees.
• Employers and businesses in federally regulated sectors such as banks, airlines, airports, railways, ports and shipping, trucking and bus operations, telecommunications and broadcasting, and federal Crown corporations — and First Nations Band Councils.
• Small businesses estimated to be affected: about 8,729 small businesses and roughly 69 employees in those small businesses over the regulatory period (government estimate).

Why it matters#

• The main goal is to reduce young people’s exposure to dangerous work. Federal records showed 67 hazardous occurrences involving employees under 18 between 2010–2011 and 2019–2020, with 65 resulting in disabling injuries (no fatalities in that period).
• The government estimated the present‑value cost of the proposal at $27,730,631 over 2023–2032, broken down as: employers’ wage effects $5,435,996, forgone earnings to affected employees $22,294,635, and record‑keeping $1,974.
• The cost‑benefit breakeven analysis showed the proposal would need to prevent about 11 moderate injuries per year (or about 5 serious injuries per year) for quantified benefits to match costs.
• The change would bring federal rules into line with Canada’s commitment under the ILO Minimum Age Convention, 1973 (C138) and with recommendations from a past federal labour‑standards review.
• This is a proposed regulation (Part I). Interested people had 30 days from publication to comment.