Pennsylvania's New Volunteer Safety Requirement Is Anything but Minor — the Keystone State Is the First to Formally Close a Gap in the Regulatory Framework

As of May 1st, 2026, any haunted attraction in Pennsylvania that wants to use minors in performance roles must have a state-approved safety plan on file with the Department of Labor and Industry before it can even apply for a "Minor in Performance" permit. The requirement didn't come from a spontaneous policy initiative. It came from an investigation, a scandal, and years of regulatory silence.

Pennsylvania appears to be the first state to take this step, and it may not be the last.

The Investigation

The chain of events begins with a Facebook group — "Untold Stories of Field of Screams" — that went viral in early 2024. Field of Screams is one of Pennsylvania's largest and most prominent haunted attractions. The group attracted attention from Spotlight PA, an investigative news outlet founded in 2019 by a consortium of newspapers, whose investigations have repeatedly led to legislative and regulatory change in the state.

Spotlight PA interviewed over 18 current and former volunteers who had worked at Field of Screams between 2006 and 2024. Their findings described a pattern of sexual harassment and exploitation of teenage volunteers by adult staff. A second major Spotlight PA article, published in October 2025, revealed something harder to explain away: an adult volunteer had been allowed to continue working alongside minors for three years after the company learned of his 2023 conviction for exposing himself to children.

As of this writing, there are no criminal charges. Law enforcement has cited statute of limitations and evidentiary challenges. The regulatory response, however, moved forward.

Why Haunted Attractions Fell Through the Cracks

One of the more important things about this new regulation is the problem it identifies: haunted attractions occupy a **regulatory gray zone** that most entertainment industries don't.

Pennsylvania's Child Labor Act has a "minor in performance" permit system, but haunted attractions historically operated under the federal Fair Labor Standards Act's Section 13(a)(3) **seasonal amusement exemption** — which exempts seasonal and recreational establishments from minimum wage, overtime, and most labor law protections. Because volunteers at Field of Screams weren't technically employees, they didn't trigger standard employer-employee protections at all. And because haunted attractions are seasonal, they fell under the exemption regardless.

Meanwhile, the state's minor performance permit system was designed primarily with theatrical, film, and television performers in mind — paid child actors in formal productions. (My own child was one of these, in California, and the state's version of these laws requires protections like a studio teacher whose job isn't really to teach but rather to observe what's going on and watch out for the child's safety.) The point is that the system was built with a particular kind of child performer in mind. Haunted attraction volunteers aren't actors in the traditional sense. They aren't being paid, aren't in a union, and aren't working on a regulated set. They existed in the gap between entertainment labor law and recreational amusement law, and nobody had closed it.

The new Pennsylvania regulations effectively say: if you're using minors in a performance role at a haunted attraction, you must now meet the same kind of safety-plan threshold the state applies to other minor performers. The haunted attraction specificity is intentional — it's a direct response to the Field of Screams scandal, not a broad policy overhaul.

How Other States Compare

California's version of these laws may have caught some of these issues, but even there it's unclear whether the protections explicitly cover unpaid haunted attraction volunteers versus paid entertainment workers. Indiana, interestingly, takes something like the opposite approach — it explicitly exempts minor haunted attraction performers from most child labor protections, treating them as actors while requiring parental accompaniment for those under 16. Most other states have no haunted attraction-specific minor protections at all, beyond general child labor law, which typically doesn't apply to unpaid volunteers at seasonal recreational businesses.

What This Means for Your State and Your Business

It seems moderately likely that over the next few years, this will spread to other states. The path Pennsylvania took — regulatory action by the Department of Labor, rather than legislation — is worth noting. Legislation often encounters a fight; regulatory action through an existing agency framework is faster and harder to stall.

The Haunted Attraction Association and its legal advisory board are now actively engaged on the issue. If they develop a voluntary national standard for minor volunteer safety that operators can adapt proactively, it may actually preempt state-by-state legislation by demonstrating self-regulation. That is historically how industries avoid mandatory frameworks: by building credible ones of their own first.

If you operate in Pennsylvania, compliance is not optional as of May 1st. If you operate elsewhere and use minors in performance roles — paid or volunteer — now is a reasonable time to review your practices and document them, before a regulator does it for you.

As always, consult with an attorney licensed in your state before making changes to your legal documents or practices.

The Broader Picture: Which Industries Are Next?

The combination at the heart of this issue — the Seasonal Recreational Exemption, plus volunteer labor, plus minor participants — is not specific to haunted attractions. Several adjacent industries follow the same profile and are worth watching.

Corn mazes, hay rides, and fall agritourism often use teenage volunteers in low-supervision, after-dark settings with little regulatory oversight, and are frequently more rural and less visible than major haunted attractions. Renaissance faires and outdoor festival entertainment use both paid and unpaid minor performers in settings where the festival structure often involves touring adult entertainers in proximity to teenage local volunteers, with no formal labor oversight.

Youth sports programs have seen far more public attention on this problem because of certain notorious cases, and many states now require background checks for coaches and volunteers — but requirements vary and enforcement is inconsistent. Summer camps and outdoor adventure programs share the same volunteer/seasonal/recreational exemption profile, and while most states require background checks for camp counselors, the requirements vary significantly. Immersive theater productions — which increasingly blur the line with haunted attractions — use adult actors in close, sometimes physical proximity to audience members, and often employ teenage cast members in non-union productions with no formal labor protections. Horror-themed escape rooms that use live actors are in some respects similar to haunted houses, and would logically be among the next categories a regulator would examine after establishing this framework.

The legal principle Pennsylvania has now established — that the combination of minors in performance roles, dark or disorienting environments, mixed adult/minor cast, and seasonal operation requires a formal safety plan — is transferable to all of these industries.

The Safety Plan Requirements

These requirements are in effect as of May 1st, 2026. The safety plan must be on file with the Department of Labor and Industry before an attraction can even apply for the individual "Minor in Performance" permits that authorize each minor to work.

The safety plan must include:

1. A comprehensive background check on every adult staff member — employees and volunteers alike — who will interact with minors. The checks must specifically cover any convictions involving minor victims and any misdemeanor or felony sex offenses. The state is allowing attractions to choose how to run the checks.
2. A written description of a training program on preventing sexual abuse and harassment in the workplace.
3. General workplace safety training covering hazards specific to the venue and how to handle misbehavior.
4. A formal identification of risks and hazards at the venue.
5. A written reporting mechanism and enforcement protocol.

Beyond the safety plan, attractions must still apply for an individual permit for every single minor they intend to use — the state has to sign off on each one. Pennsylvania's Child Labor Act also caps how long minor performers can work depending on age; generally, up to six hours per day for seventeen-year-olds. The safety plans are valid for one year and must be resubmitted annually, submitted at least 20 days before applying for permits.

One important limitation: Pennsylvania state law still does not require routine inspections of haunted houses. The Department of Labor may conduct unannounced site visits, but there is no mandated inspection schedule, and no requirement that the state audit whether the required training is actually being conducted. The plan requirement is real. The enforcement mechanism, for now, is not.

This post is general legal information, not legal advice. Regulatory requirements vary by state and are subject to change. Consult a licensed attorney in your state before relying on any of the above for your business.