Static educational checklist — not a calculator. No punch-clock inputs, no minutes-to-pay engine, no live OT math. Spot common donning / doffing and preliminary / postliminary red flags under the Portal-to-Portal Act and FLSA hours-worked rules. Distinct from compensatory-time, sleep-time, spread-of-hours, training-time, continuous-workday, on-call/waiting, travel-time, meal/rest, tip-credit, recordkeeping, child-labor, final-paycheck, and OT pay-stub pages.
Federal baseline
The Portal-to-Portal Act (29 U.S.C. § 254) generally excludes walking, riding, or traveling to/from the place of principal activity, and activities that are preliminary or postliminary to principal activities, from compensable hours — unless a contract, custom, or practice makes them payable. Activities that are integral and indispensable to a principal activity (classic example: required protective gear that is part of the job’s productive work) remain hours worked. Once the continuous workday starts with the first principal activity, mid-shift walking/waiting between principal activities is usually compensable. Section 203(o) can exclude clothes-changing and washing time under a bona fide CBA in certain industries. This page does not time punches or compute pay for a specific shift.
Checklist — donning / doffing red flags
Required PPE treated as “just getting ready.” Flag policies that zero out time spent putting on or taking off employer-required protective equipment (gloves, specialized suits, respirators, sanitary gear) that is integral to the productive work. Donning/doffing that is integral and indispensable is generally hours worked — not unpaid prep.
“Clothes” label stretched to kill PPE time. Flag handbooks that call mandatory protective gear ordinary “clothes” so the time never hits the clock. Courts distinguish ordinary clothes from specialized protective equipment; mislabeling PPE as street clothes is a common Portal-to-Portal trap.
§ 203(o) CBA exclusion applied without a qualifying agreement. Flag employers that cite the clothes-changing / washing exclusion of § 203(o) where there is no bona fide collective bargaining agreement that excludes that time, or that stretch § 203(o) beyond clothes/washing into gear the statute does not cover.
Walking / waiting after the first principal activity unpaid. Flag clocks that start only at the production line and ignore walking, waiting, or security screening that occurs after employees have already donned required gear or begun another principal activity. Under the continuous-workday doctrine, time between the first and last principal activities is generally compensable.
Pre-shift donning + post-shift doffing both zeroed. Flag schedules that require gear on before the official start and gear off after the official end, yet pay only the face-time between bells. If both ends are integral principal activities, unpaid bookends are a classic hours-worked miss.
Security screening / bag check treated as always non-compensable. Flag blanket “screening is never paid” rules without asking whether screening occurs before the first principal activity or after the continuous workday has already begun, and without checking contract/custom/practice that may make the time payable under § 254(b).
De minimis used as a blanket wipe-out. Flag payrolls that discard several minutes of required donning/doffing every shift as “too small to count” without a genuine de minimis analysis (practical administrative difficulty, aggregate size, regularity). Regular multi-minute unpaid rituals are often not de minimis.
No records of gear-up / gear-down time. Flag timekeeping that captures only production punches and never records required changing or PPE time, leaving no trail for hours-worked disputes.
Confusion with meal / rest / on-call doctrines. Flag policies that treat unpaid meal periods, rest breaks, or on-call waiting as if they answered the donning/doffing question. Those are related hours-worked doctrines — not substitutes for Portal-to-Portal analysis.
State / local overlays ignored. Flag federal-only reliance where a state (e.g., California hours-worked rules on required changing/PPE, industry wage orders, or local ordinances) treats more pre-/post-shift time as compensable than the Portal-to-Portal floor. Always check the stricter overlay.