One-Hour Situations
(looping, promotional publicity, personal appearances, wardrobe, make-up, hairdressing) [8CCR11762]
- if a minor age 16 and under is NOT called to the set but is called for a period up to one (1) hour into wardrobe, make-up, hairdressing, promotional publicity, personal appearances, or for looping, when such minor’s school is not in session, a studio teacher need not be present
- If a minor attended school that day, ANY amount of time spent in looping or publicity must be covered by a studio teacher
- minor must be accompanied by a parent or guardian
State of California
Department of Industrial Relations
Division of Labor Standards Enforcement
525 Golden Gate Avenue
San Francisco, CA 94102
June 1,1999
Re: Interpretation of Title 8, California Code of Regulations 11762
The Labor Commissioner, Marcy Saunders, has asked me to respond to your May 4, 1999 letter, requesting interpretation for the above referenced regulation.
Title 8, CCR 11762 states:
No minor under the age of sixteen (16) may be sent to wardrobe, make-up, hairdressing or employed in any manner unless under the general supervision of a studio teacher. If any such minor is not called to the set but is called for a period up to one (1) hour into wardrobe, make-up, hairdressing, promotional publicity, personal appearances or for audio recording, when such minor’s school is not in session, a studio teacher need not be present but the minor must be accompanied by a parent or guardian.
Your letter states the “law has not been enforced as written.” We regret to hear this as the regulation is very clear on it’s face. As the enforcement agency regulating the conduct of studio teachers, the State Labor Commissioner wishes to confirm that if a child under the age of sixteen attends school and on that same day is subsequently sent to wardrobe, hairdressing, promotional publicity, personal appearances, or audio recording, a studio teacher must be present to supervise that child. The only time a studio teacher is not required under this regulation is when the student conducts these activities on a scheduled holiday or weekend. Should a production company or employer not abide by this regulation, please inform the Labor Commissioner so we may promptly investigate the alleged violation.
I hope I have adequately answered this issue. Should you have any further questions, concerns, or require additional interpretation, do not hesitate to contact the undersigned directly. Thank you for your ongoing interest in California labor law.
Yours truly,
David Gurley
Attorney for the Labor Commissioner