Department of Labor Clarifies Meal Period Requirements and Travel Time Considerations

The U.S. Department of Labor issued recent guidance on Fair Labor Standards Act compliance regarding meal break policies and tip pool arrangements. The DOL determined that a 60-minute lunch break remains compensable as a bona fide meal period even if employees spend up to 14 minutes traveling to a designated break area, provided sufficient time remains for eating; however, breaks significantly reduced by travel time may become compensable work time. Employers should carefully evaluate whether travel requirements to break areas adequately preserve meaningful meal periods for workers.

The Department of Labor's guidance addresses a practical challenge in many workplaces: when facility layouts require employees to travel substantial distances to reach designated break areas, the question arises whether the journey itself cuts into time that should be spent eating. In the detention facility case examined, workers needed up to 14 minutes simply to reach their break location, leaving roughly 46 to 54 minutes for an actual meal from a scheduled 60-minute period. The DOL determined this arrangement remained compliant since adequate eating time remained.

However, the agency signaled that circumstances could differ significantly. The DOL pointed to a Fifth Circuit case where only 18 minutes of actual break time remained after travel from a stated 30-minute period—a reduction deemed substantial enough to warrant legal reconsideration of whether compensation was owed. This standard suggests employers must perform individualized assessments of their facility layouts and break area accessibility to ensure compliance.