In the oldie-but-goldie decision of Steiner v. Mitchell, 350 U.S. 247 (1956), the Supreme Court held that time workers spend on activities performed before or after regular working hours is compensable under the Fair Labor Standards Act, if the activities are “integral and indispensable parts of the principal activity” of the worker’s employment. This holding, and the reasoning behind it, is an important principle of “donning and doffing,” equipment preparation, security screening, and similar cases, where workers seek compensation for time spent performing work-related activities off the clock or outside of regular work hours.
Steiner operated a car-battery manufacturing plant. The plant’s production employees worked with some toxic chemicals. These included lead and sulphuric acid. In the manufacturing process, some of the materials gave off dangerous fumes. Some were inevitably spilled or dropped, becoming a part of the dust in the air. In general, the chemicals permeated the entire plant and everything and everyone in it. Id. at 249-50.
In an effort to make the plant safer and thereby increase the efficiency of its operation, Steiner equipped it with shower facilities and a locker room with separate lockers for work and street clothing. Also, Steiner furnished work clothes for the employees to wear. The cost of providing their own work clothing would be prohibitive for the employees, since the acid caused such rapid deterioration that the clothes sometimes lasted only a few days. The employees regularly changed into work clothes before the beginning of the productive work period, and showered and changed back at the end of that period. In addition, the company required the employees to take afternoon baths to minimize the amount of lead oxide absorbed into their blood. These measures were thought to protect the company and the employees. Id. at 250-52.
Steiner did not pay the employees for the time they spent in these activities, which together amounted to about 30 minutes per day. Steiner conceded that the employees’ clothes-changing and showering activities were indispensable to and integrally related to the performance of their productive work. Steiner, however, contended that these activities fell outside the concept of a “‘principal activity’ and that, being performed off the production line and before or after regular shift hours, the time employees spent doing them was not compensable time under the Fair Labor Standards Act. Id. at 250-52.
The Court’s Decision
The question for the Court was whether the time employees spent changing clothes and showering was compensable under the FLSA in light of the Portal-to-Portal Act, which provided that time spent on activities “preliminary to or postliminary to” an employee’s “principle activities” was not compensable under the FLSA.
The Court decided that this time was compensable. As the backdrop to this conclusion, the Court explained Congress passed the Portal–to–Portal Act in response to the “unexpected liabilities” created by a broad judicial interpretation (as in Anderson v. Mt. Clemens Pottery Co., 328 U.S. 680 (1946)) of compensable time under the FLSA. See 29 U.S.C. § 251(a). Section § 4(a)(2) of the Portal–to–Portal Act therefore exempted employers from FLSA liability for claims based on “activities which are preliminary to or postliminary to” the principal activities that an employee is employed to perform. 29 U.S.C. § 254(a)(2). 350 U.S. at 253-54.
The Court then determined that for Steiner’s battery-plant employees, changing clothes and showering were parts of their “principal,” rather than their “preliminary” or “postliminary,” activities, within the meaning of § 4(a)(2). Therefore, time employees spent in these activities was required to be counted in measuring their compensable working time under the FLSA.
First, after reviewing the Portal-to-Portal Act’s legislative history, the Court determined Congress intended that activities employees performed either before or after the regular work shift, on or off the production line, would be compensable under the FLSA if those activities are “an integral part of and indispensable to their principal activities,” and are not specifically excluded by § 4(a)(1) of the Portal-to-Portal Act. 350 U.S. at 254-56. That section, § 4(a)(1), generally excludes time spent traveling to and from the workplace. 29 U.S.C. § 254(a)(1).
Second, the Court determined the “integral and indispensable” rule was supported by other provisions of and amendments to the Portal-to-Portal Act. 350 U.S. at 254-56.
Finally, the Court concluded that with respect to Steiner’s battery plant employees, changing clothes and showering were integral and indispensable parts of the principal activity of their employment. Therefore, the time the employees spent on these activities was compensable working time under the FLSA.
In sum, Steiner stands for the proposition that time workers spend on activities performed before or after regular working hours, on or off the production floor, is compensable under the FLSA, if the activities are integral and indispensable parts of the principal activity of the worker’s employment. The reasoning behind this holding is an important principle of FLSA cases involving donning and doffing, equipment preparation, security screening, and similar claims where workers seek compensation for time spent performing work-related activities off the clock or outside of regular work hours.
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