DOL handbook clarifies paid time rules for Target employees

The Department of Labor's Field Operations Handbook sets out which activities employers must count as hours worked under the Fair Labor Standards Act, and that guidance has direct implications for Target frontline staffing and timekeeping practices. The handbook addresses categories such as rest periods, waiting time, sleeping time, donning and doffing, travel time, and portal-to-portal issues, and it is commonly relied on in wage-and-hour investigations and litigation.

Short rest breaks of about 5 minutes to 20 minutes are customarily paid and must be counted as hours worked, while longer breaks may be noncompensable if employees are free to use them for personal purposes. The handbook also clarifies that preparatory and finishing activities performed for the employer can be compensable work time when those activities are integral and indispensable to the employee's principal work and the employee has little choice about performing them. This can include tasks that Target employees report doing before clocking in or after clocking out, such as pre-shift prep, mandatory security screenings, or required walkthroughs for shrink prevention.

The DOL also acknowledges a de minimis doctrine under which very short increments of time may be disregarded. Courts weigh factors such as the administrative difficulty of recording small increments, the total amount of additional time involved, and the regularity of the time increments when deciding whether they are compensable. That calculus is central to disputes over repeated unpaid minutes at the start or end of shifts that may add up across pay periods.

For Target workers, the practical stakes are straightforward: policies that require employees to perform unpaid preparatory tasks, to delay clocking in, or to complete mandatory checks before or after shifts can create unpaid work that may meet the DOL's standards for compensable time. For managers and corporate compliance teams, the handbook signals a need to review clock-in rules, break policies, security screening procedures, and timekeeping systems to avoid exposure in audits or lawsuits.

Beyond potential back pay, these issues affect workplace dynamics. Employees who regularly perform unpaid pre-shift tasks may experience lower morale and higher turnover, while inconsistent enforcement of clocking rules can create mistrust between hourly workers and supervisors. Employers that proactively train supervisors on what counts as compensable work and adjust scheduling or pay practices can reduce risk and improve retention.

Workers should document the time spent on pre- and post-shift duties and raise concerns through their usual internal channels or the Wage and Hour Division if necessary. For employers, the handbook is a clear prompt to align store and distribution-center practices with federal wage standards or face potential legal and financial consequences.