IBP, Inc. v. Alvarez
Headline: Court rules workers must be paid for walking after putting on required protective gear during the workday, but not for waiting before donning, changing pay obligations for meatpacking and poultry plants.
Holding: The Court held that when protective gear is integral and indispensable, walking after donning during the continuous workday and waiting to doff are compensable, but time spent waiting to don before the workday begins is not compensable.
- Requires pay for walking after donning required protective gear during the workday.
- Allows pay for time waiting to remove protective gear at shift end.
- Does not require pay for waiting before donning when waiting occurs before workday begins.
Summary
Background
Workers at a large meatpacking plant and a poultry plant sued their employers seeking pay for time spent putting on and taking off required protective gear, walking between locker rooms and production lines, and waiting to get equipment. The companies argued that a 1947 amendment to the pay law excludes such walking and some waiting time from pay. Lower courts split: one court said walking after dressing was payable, another said walking and waiting were not.
Reasoning
The Court looked at earlier decisions and the 1947 law that carved out certain travel and “preliminary or postliminary” activities from pay. It reaffirmed the idea that activities that are “integral and indispensable” to the job count as the job itself. The Court held that once a worker has begun the first required, integral task (like donning unique protective gear), the short walk that follows is part of the continuous workday and must be paid. Waiting to remove gear at the end of the day is also covered. But time spent waiting to don gear before the first principal activity begins remains a preliminary activity and is excluded.
Real world impact
The ruling means some short walking and end-of-shift waiting times at plants must be counted as work; employers must review pay practices for workers who don specialized gear. The Court affirmed one appeals court, reversed the other in part, and sent the cases back for further fact-finding under the rule the Court announced.
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