Nancy Alcantara, Shannon Rebolledo, Justin Uphold and the Packers Sanitation Investigation Leads Team

In February 2023, Labor Department investigators discovered extensive child labor violations that involved 102 children, ages 13 to 17. These children were illegally performing sanitation work at processing facilities, cleaning bone saws, skull splitters and other dangerous machinery during overnight shifts at 13 meat slaughterhouse plants in eight states. 

The shocking findings from this wide-ranging investigation, led by Nancy Alcantara, Shannon Rebolledo and Justin Uphold, resulted in a nationwide injunction, a consent decree and one of the largest civil monetary penalties in the agency’s history—$1.5 million against Packers Sanitation Services, a leading food sanitation service provider. 

“Children are not supposed to be working at a meat processing facility or for a company cleaning bone saws and other dangerous machinery or using industrial chemicals,” said Michael Lazzeri, the Labor Department’s Midwest regional administrator.  

Investigation led to a new enforcement approach  

“This investigation prompted sweeping changes in how the Department of Labor conducts child labor enforcement, and the launch of a national initiative to identify and address exploitative child labor,” Lazzeri said.  

Patricia Davidson, a Labor Department deputy administrator, said that “since the Packers Sanitation Services investigation, we have found a number of companies that have illegally employed children to do dangerous work in manufacturing jobs and overnight shifts.” 

During fiscal 2023, the department concluded 955 investigations that found child labor violations, holding more employers accountable than in any year over the past 15 years. Investigators found almost 5,800 children employed in violation of the law, an 88% increase since 2019.  

Since the cleaning company investigation, the department has continued to find minors employed in dangerous situations, including at a Wisconsin sawmill that illegally employed nine children to operate hazardous machinery. One child died from work-related injuries as a result.  

The Fair Labor Standards Act of 1938 prohibits minors from working in hazardous occupations. In the Packers Sanitation Services case, the investigators found the cleaning company serviced plants owned by some of the country’s largest meat producers, and they uncovered instances of children suffering injuries.  

Nicole Van De Bogart, a Labor Department Midwest deputy regional administrator, said Alcantara and Rebolledo obtained credible information that children were working the overnight shift in a Grand Island, Nebraska, slaughterhouse and coming to school exhausted from working overnight. In some cases, they had chemical burns from using caustic cleaning materials. 

A broad investigative strategy 

Alcantara, Rebolledo and Uphold developed a broad investigative strategy to obtain nationwide compliance and address the employment of minors at other meat-processing plants that used the same sanitation company.  

Alcantara and Rebolledo coordinated the effort, while Uphold was in charge of executing the search warrants and visiting the Packers Sanitation Services corporate office to analyze and organize the voluminous data from the company and 55 meatpacking facilities. 

Using company records, on-site inspections, various investigative techniques, and contacts in the communities, the trio determined that child labor violations were not only occurring at the Nebraska plant, but at facilities served by the sanitation company in Arkansas, Colorado, Indiana, Kansas, Minnesota Tennessee and Texas. The use of administrative search warrants enabled the team to gain accurate information, identify the exploited minors and halt the widespread illegal conduct. 

Uphold said this case is “one of the proudest accomplishments of my life,” adding that the team not only helped vulnerable children working in horrible conditions, but also “established a new approach to child labor enforcement and spurred new leads and new relationships.” 

Rebolledo said she “will never forget the faces of these kids whose lives and safety were in danger working under such horrendous conditions.”  

Alcantara said it was “traumatic walking through these slaughterhouses with animal parts on the floor and blood flowing, and just horrific to know 13-year-olds were working there overnight.  

“We understood this investigation would be challenging, but we could not stop. We had to work together, get the resources and develop a strategy to include as many plants as possible to have a nationwide impact.”