Plain-language reference for the wave-one proposal. Sources are tagged at the end of each point. This is background for discussion, not a substitute for legal review of the actual placement agreement.
California has no special "unpaid intern" status that automatically exempts a for-profit host from wage laws. The default: if the student does work that benefits the company, they are an employee and must be paid at least minimum wage, plus overtime and meal/rest breaks as applicable. Source: nolo.com
An unpaid placement is lawful only if the student is the primary beneficiary — educational training, tied to school, limited duration, does not displace paid workers, no job entitlement, and everyone understands it is unpaid. School credit and a structured learning plan help; using the student as free labor does not. Source: nolo.com
If the facts look like a job, calling it an "internship" or routing it through the school does not erase wage or child-labor rules.
Paid work almost always needs a school-issued Permit to Employ and Work (CDE B1-4), after the student, parent, and employer complete B1-1. The employer keeps the permit on site. Hour limits and prohibited duties still apply. Source: cde.ca.gov
For a school-supported unpaid internship or volunteer placement — not a job the student arranged alone — CDE instead uses Form B1-6 (Request for Volunteer/Unpaid Trainee Authorization). Per CDE's FAQ, if the minor is truly an unpaid trainee for academic purposes and not an employee under the FLSA trainee test, a work permit is not required — but B1-6 is used so the parent, the school, and the worksite supervisor all know about the placement. Source: cde.ca.gov
There is no single statewide rule that every private-company mentor of a school intern must complete the same annual training a school employee completes. School staff are mandated reporters; a random workplace supervisor is not automatically in that school category. Here's what can apply to the host:
If the business has 5 or more employees and employs minors, certain HR staff and supervisors who oversee those minors are mandated reporters of sexual abuse at work, and the employer must train them (the CDSS/OCAP online module is acceptable) and get a signed acknowledgment. This targets minor employees, not automatically every unpaid school trainee — but if the student is treated as an employee, it is in play. Source: bhfs.com
Employers with 5 or more people must train employees (1 hour) and supervisors (2 hours) every two years. Unpaid interns and volunteers count toward the headcount, but the Civil Rights Department's employer FAQ says the employer is not required to train unpaid interns/volunteers — best practice only. FEHA does protect unpaid interns from harassment and discrimination. Source: calcivilrights.ca.gov
School employees — and in many cases certain school volunteers/contractors who supervise pupils — must complete mandated-reporter training. That duty sits on the school, not automatically on the host's staff. Source: cde.ca.gov
Many schools will not place a minor unless the worksite agrees to a safety orientation, a named mentor, and — in some programs — fingerprinting/TB and the district's own child-protection training. That is program policy, not a universal Labor Code mandate.
So: the host is not usually required to take the "teacher mandated-reporter class" just because a school asked them to host. They may have reporting/training duties if they employ minors, they must keep the workplace free of harassment, and the school can impose extra conditions as the price of placement.
Responsibilities split. Typical pattern:
The school's involvement does not transfer the company's premises-liability or harassment duties to the district. It often does shift unpaid-student workers' comp to the school under 51769 when the program fits those Education Code categories.