Project 2025's DOL agenda: Gut enforcement, endanger teens, and let employers rewrite the rules

Project 2025's proposals on the Department of Labor read like a playbook for rolling back worker protections piece by piece. Take the PRO Good Guidance rule: rescinded by Biden in July 2021 after Trump's October 2020 final rule limited how DOL can use guidance documents in enforcement. Project 2025 wants to reinstate it, which would let agencies hide their interpretation of rules and make it harder for workers to know their rights or hold employers accountable. This isn't about 'transparency'—it's about giving employers cover to violate wage and hour laws, safety standards, and anti-retaliation protections without clear consequences, because enforcement agents would lose the ability to rely on plain-language guidance. Congress should instead enshrine the Biden rescission and require all DOL guidance to be publicly accessible, explainable in plain language, and usable in enforcement.

On child labor, Project 2025 proposes letting teenagers work in currently prohibited hazardous occupations with parental consent and training. This ignores NIOSH data showing that 18 workers under 18 died from work-related injuries in 2020 alone, and thousands more are hurt every year in jobs that are already legal. The current DOL hazardous occupation orders (HOOs) list 17 specific jobs—from meatpacking to roofing to operating power-driven machinery—that are banned for most workers under 18 because they are simply too dangerous. Rolling back those protections would expose young workers, often from low-income families or working in family businesses, to preventable injury or death. The safer alternative: enforce the existing HOOs, expand safety training for young workers in permitted jobs, and raise the minimum age for hazardous work to 18 without exception, as the International Labour Organization recommends.

On apprenticeships, Project 2025 wants to revive the Industry-Recognized Apprenticeship Program (IRAP)—created by Trump in 2020, rescinded by Biden in December 2021—which let trade associations and other private entities oversee apprenticeships outside the Registered Apprenticeship Program (RAP) that has strong labor standards. IRAP had weaker quality and safety requirements, and its rescission was welcome. What workers need instead is expanding RAP through sectoral partnerships with unions, community colleges, and employers that guarantee portable credentials, living wages, and safety protections—not a return to deregulated, employer-controlled 'apprenticeship' that devalues training and exploits workers.

Finally, the small-business exemption proposals would raise the NLRB's jurisdictional threshold (currently based on a $500,000 annual revenue standard from 1935, already outdated but this would cut millions of workers out of NLRB protection entirely) and exempt first-time, non-willful OSHA violators from fines. That last one is a gift to dangerous employers: without the deterrent of a fine, why would any business invest in safety? The consequence is more preventable injuries and deaths, especially in construction and manufacturing. Congress should instead strengthen NLRB jurisdiction to cover all workers regardless of employer size, and OSHA fines should be mandatory for any violation that exposes workers to serious harm, with no carveout for first-timers.