Steiner v. Mitchell

Background

A battery manufacturer in Tennessee and its production workers disputed whether time spent changing into work clothes and showering should be paid. The workers handled toxic materials — including lead compounds and sulfuric acid — that contaminated clothes, skin, and the plant atmosphere. State law and the employer’s insurance required locker and shower facilities. The employer provided work clothes and showers without charging employees, but did not record or pay the roughly thirty minutes a day employees spent changing and showering. The Secretary of Labor sued under the Fair Labor Standards Act to stop the employer from violating overtime and record-keeping rules, and lower courts ruled for the Secretary.

Reasoning

The central question was whether those changing and showering activities were part of the employees’ "principal" work or merely preliminary or postliminary tasks excluded by the Portal-to-Portal Act. The Court examined the Act’s language and legislative history and concluded that activities that are "integral and indispensable" to the principal production work are compensable. The Court found changing clothes and showering in this plant clearly indispensable because of the hazardous materials and the need to protect health and production. The Court therefore affirmed the lower courts’ rulings that the time must be counted as work time under the Act.

Real world impact

The decision means employers in similar hazardous industries must count and pay time for required changing and showering when those steps are essential to production or safety. The judgment was limited to future relief, so it did not award back pay for past work. The ruling rests on facts showing clear health and contamination risks making the activities integral to the job.