One morning in 2019, an auditor arrived at a meatpacking plant in rural Minnesota. He was there on behalf of the national drugstore chain Walgreens to ensure that the factory, which made the company's house brand of beef jerky, was safe and free of labor abuses.
He ran through a checklist of hundreds of possible problems, like locked emergency exits, sexual harassment and child labor. By the afternoon, he had concluded that the factory had no major violations. It could keep making jerky, and Walgreens customers could shop with a clear conscience.
When night fell, another 150 workers showed up at the plant. Among them were migrant children who had come to the United States by themselves looking for work. Children as young as 15 were operating heavy machinery capable of amputating fingers and crushing bones.
Migrant children would work at the Monogram Meat Snacks plant in Chandler, Minnesota, for almost four more years, until the Department of Labor visited this spring and found such severe child labor violations that it temporarily banned the shipment of any more jerky.
In the past two decades, private audits have become the solution to a host of public relations headaches for corporations. When scandal erupts over labor practices, or shareholders worry about legal risks, or advocacy groups demand a boycott, companies point to these inspections as evidence that they have eliminated abuses in their supply chains. Known as social compliance audits, they have grown into an $80 billion global industry, with firms performing hundreds of thousands of inspections each year.
But a New York Times review of confidential audits conducted by several large firms shows that they have consistently missed child labor.
Children were overlooked by auditors who were moving quickly, leaving early or simply not sent to the part of the supply chain where minors were working, the Times found in audits performed at 20 production facilities used by some of the nation's most recognizable brands.
Auditors did not catch instances in which children were working on Skittles and Starburst candies, Hefty brand party cups, the pork in McDonald's sandwiches, Gerber baby snacks, Oreos, Cheez-Its or the milk that comes with Happy Meals.
In a series of articles this year, the Times has revealed that migrant children, who have been coming to America in record numbers, are working dangerous jobs in every state, in violation of labor laws. Children often use forged documents that slip by auditors who check paperwork but do not speak with most workers face-to-face. Corporations suggest that supply chains are reviewed from start to finish, but sub-suppliers such as industrial farms remain almost entirely unscrutinized.
The expansion of social compliance audits comes as the Labor Department has shrunk, with staffing levels now so low that it would take more than 100 years for inspectors to visit every workplace in the department's jurisdiction once. For many factories, a private inspection is the only one they will ever get.
Auditors for several firms said they are encouraged to deliver findings in the mildest way possible as they navigate pressure from three different sources: the independent auditing firms that pay their salaries; corporations, such as Walgreens, that require inspections at their suppliers; and the suppliers themselves, which usually must arrange and pay for the audits.
The auditor who looked at the Minnesota jerky factory for Walgreens was Joshua Callington. He has conducted more than 1,000 audits in the past decade.
"If audits are done correctly, the world could be a better place," he said. "Bettering the lives of workers is what these audits are supposed to be about."
But more and more, he said, each audit had begun to feel like a struggle between wanting the truth and trying to avoid conflict.
He had not seen any child labor in the Minnesota factory. To keep to his work schedule, he had to leave for his next audit at 4 p.m., long before the late shift arrived. Spotting problems had also led to tension between Callington and his employer, UL Solutions, which began as a safety testing business and expanded more than two decades ago into social compliance audits. The company took in $2.5 billion in revenue last year and is on the cusp of an initial public offering.
What Callington saw as a commitment to his job, his firm seemed to see as overzealousness.
"The assessment is not meant to be a policing effort," the UL Solutions employee handbook says.
After Callington failed three Walgreens suppliers in 2017 and 2018 for abusive working conditions, the chain complained about his communication style and asked for him to be taken off its account. UL put him on a remediation plan for about a year. (Walgreens declined to comment on the incident, but said it only rarely asks for auditors to be removed. In response to questions about the Monogram factory, the company said it had cut ties with the supplier. Monogram said it is now using stronger age-verification procedures.)
This spring, Callington flagged labor issues involving adult migrant workers at a warehouse that supplies Costco's potatoes. The plant's management complained that he was demanding and argumentative, and his supervisor barred him from returning. Callington believed that the supplier objected to his finding 21 violations when the previous audit had found none. UL Solutions, which still employs Callington, declined to comment on either incident.
The supervisor said Callington would have to complete a series of customer service trainings, and concluded with an inspirational quote that he attributed to the poet Maya Angelou.
"'People will forget what you said. They will forget what you did. But they will never forget how you made them feel,'" he wrote in an email. "Keep this in mind as you are interacting with our clients during your audits."
Night shifts, daytime audits
In dozens of interviews, auditors said that sometimes their firms provide little more than a veneer of compliance for global corporations, which overstate how rigorously they review sprawling supply chains.
Auditors typically start their inspections in the morning and stay for about seven hours, even at 3,000-person factories that operate around the clock. In practice, this means that late afternoon and night shifts, where child labor violations most often occur, are almost never seen.
This year, the Department of Labor imposed a $1.5 million fine against Packers Sanitation Services, which provides cleaning crews to slaughterhouses. Investigators found that the company was employing more than 100 children, including 13-year-olds, to clean back saws and head splitters overnight.
These plants had been supplying McDonald's and Costco for years, and the corporations required regular audits. Some of those auditors noted that there was a large night shift run by the sanitation company, but said they had not been able to observe any of the workers. One auditor who was checking a Nebraska plant for Costco's Kirkland brand beef spoke with 20 out of 3,500 workers — as is standard in much of the industry — and left at noon, an inspection showed. In another audit at the same plant, the inspector left at 1:30 p.m.
Costco and McDonald's said in statements that they were strengthening their auditing standards. Packers said it had improved age verification of its workers.
Even if auditors had stayed later at the plants, they might not have been able to talk privately with the migrant child workers, who largely speak Spanish or Indigenous languages of Central America. Auditing firms rarely provide interpreters.
"You're supposed to ask another worker to translate. But you're trying to unearth something that people aren't trying to yell from the rooftops," said Juanita Sanchez-Sevilla, a Spanish speaker who has been conducting audits since the 1990s, including for the leading firms Intertek and Bureau Veritas. "If you look at the upper echelons of the industry, they're all white."
In the absence of in-person interviews, auditors rely on paperwork. But children use forged documents. This summer, for instance, a 16-year-old from Guatemala was killed while cleaning a Mississippi slaughterhouse that supplies Chick-fil-A. His documents said he was in his 30s. In a statement, Chick-fil-A said it was reviewing how it investigates violations at plants.
Research has shown that outside audits are less conclusive than companies suggest. A 2021 analysis of 40,000 audits by a Cornell professor found that nearly half had relied on forged or dubious documents. An earlier study that explored the industry's financial conflicts of interest found that auditors report fewer violations when factories are paying the bill.
In a statement, UL Solutions said that audits provide a snapshot for companies, which are ultimately responsible for enforcing their standards. An audit, the statement said, "cannot and does not guarantee that an audited facility is in full compliance with requirements against which it was audited, and does not confirm or certify compliance with laws."
In the absence of thorough inspections, child workers can stay hidden for years.
In 2020, an auditor visited a snack food factory in Geneva, Illinois, to do an inspection required by the baby food giant Gerber. As it always had, Gerber's report came back clear of child labor. The factory was also being regularly audited for the makers of Starburst and Skittles candies, Oreos and Cheez-Its. The companies behind those products said in statements that they had not seen indications of child labor in any inspections.
However, some migrant children were working on these products at the time. Among them was Efren Baldemar, who described getting the job with false identification at 14 years old. He was working from 10 p.m. to 6:30 a.m. to help support his family in Guatemala, renting space in a house of strangers.
In the mornings, he went from the factory to ninth grade and often fell asleep at his desk. The pace on the assembly lines was grueling. "If you didn't keep up, the product would back up, and the machines would smoke," he said.
The manufacturer, Hearthside Food Solutions, has been under federal and state investigations since the Times revealed child labor at other facilities in February. In a statement last week, the company said it "has never knowingly employed underage labor in our facilities." It said it could not find a record of Efren working at its plant.
Plant inspections are typically scheduled weeks in advance, and auditors say they risk upsetting factories by arriving even a few minutes early.
"If you tell them when you're showing up, they can game it," said Doug Cahn, who created the audit system for Reebok International and now advises other corporations. "They know auditors don't come back to see if the lights are on at the meatpacking plant at 3 a.m."
In some cases, the Times review of audits showed, auditors certified plants as free of child labor but acknowledged in their reports that they didn't really know if that was true.
An auditor representing Walgreens reported that there was no way to verify the ages of workers at a Chicago-area factory distributing disposable plates and cups. At the time, the factory was also supplying products for Sysco, Hefty and Walmart's Great Value brand, according to the audit. The plant was using a staffing agency that refused to share paperwork, the auditor noted.
Hefty and Walgreens said that they have stopped using the supplier. Sysco said it did not generally audit U.S. suppliers, while Walmart declined to comment.
The staffing agency is now under a state investigation for possible child labor violations.
Nagging questions
In his career, Callington had never found a case of migrant child labor, which would trigger an automatic failing grade. But now looking back, he suspected he had often audited plants where children were working.
Earlier this year, Callington asked managers at UL Solutions if Costco or other corporations might be willing to start requiring unannounced nighttime inspections. He pointed out news coverage that mentioned child labor raids at slaughterhouses.
"I have audited these locations and was never able to detect these issues given that we are only present for the first shift," he wrote.
A manager said she would raise the question with higher-ups. He never heard anything more about it.
Callington sometimes squeezes in five audits a week, staying on the road for six-week stretches. He flies between coasts so regularly that he has stopped thinking of himself as having a home-base time zone, and during long drives occasionally turns to his phone to ask, "Hey, Siri, where am I?"
This fall, he found himself in Oregon looking over the supply chain for the store-brand milk sold at Costco.
A company called Darigold, which processes milk for an association of 300 Northwest dairy farms, was paying for Callington to review its Portland plant. A manager toured him around the gleaming factory, which was suffused with the sweet smell of milk.
He looked over the spinning bottling machines, but he did not ask about the dairies that supplied the milk. He had once tried to look at a sub-supplier for Costco when he wandered into a hen house at a different facility that was packing eggs. The factory complained that he had gone beyond the scope of his audit, he said.
By late afternoon, he was thanking the Portland team for their hospitality and leaving to prepare for his next inspection. He had given the milk plant a perfect score on Costco's child labor standards: free of illegal child labor (requirement No. 140), free of children working excessive hours (No. 144) and free of instances of child labor in the past (No. 142).
But a few hours away, 17-year-old Miguel Sanchez was in the middle of his shift at a Darigold milk supplier, where he had been working 12-hour days for nearly two years.
'No option except to keep going'
Miguel came to Washington's Yakima Valley from Mexico to live with an older brother, and he immediately began working at an industrial dairy with fake identification that said he was an adult. It was a violation of child labor laws for him to work instead of going to school, but he had to contribute to the rent and felt pressure to support his parents back home.
"I was tired a lot when I started because you have to work really fast, but my family was proud of me," he said.
In May, Miguel was trying to corral several dozen cows in a milking pen when a co-worker accidentally shut the gate and trapped him inside. Two cows, each weighing about half a ton, pushed him up against the metal bars.
Miguel felt the air leave his lungs and his spine start to buckle. He tried to shout, but his co-worker did not hear him over the thrum of machinery, and he began to pass out. A supervisor took him to the hospital.
Six months later, pain still radiated from his back into his legs as he ran up and down the floor of a warehouse hooking and unhooking cows from milking machines. He regularly downed an over-the-counter drug called Backaid to get through the workday, but it seemed to do less and less. Even standing had become excruciating.
"It feels like electric shocks all through my body," he said last month. "But I have no option except to keep going. I have to make money."
It is unclear if the milk Miguel collected ended up in the facility that Callington audited. Darigold's milk is processed in 11 plants around the Northwest. Workers said they often saw minors in the dairies, and the Times spoke with a half-dozen children who came to the United States alone and worked full time for Darigold suppliers in Washington, Idaho and Oregon.
In separate statements, Costco and Darigold said they had not been aware of any child labor issues and would investigate.
Years before Callington audited the Portland factory, Costco was warned about working conditions on Darigold supplier dairies. One adult worker in the Yakima Valley drowned in a manure lagoon. Another had her face crushed by a cow. A third lost both her legs in a feed grinding machine.
In 2018, Costco began meeting with farmworker advocates as well as representatives from Darigold and UL Solutions to draw up a framework for auditing industrial dairies. But a year later, the initiative fell apart, with Costco telling the others that the extra monitoring was not feasible. In its statement to the Times, Costco said it remains interested in "collaborative partnerships" to improve conditions on dairy farms.
A major producer, Darigold also supplies McDonald's and Nestlé and processes Safeway's house brand Lucerne. None of those corporations inspect the dairies where the milk originates. McDonald's, Nestlé and Safeway said in statements that they expect suppliers to comply with their responsible sourcing standards.
Miguel tries to keep his mind blank during the workday, but he worries that he will get hurt again. When he returned home after another shift last month, he nodded at his brother and lay down on an air mattress on the floor. The sole table in the apartment was covered with boxes of Backaid and receipts for wire transfers the brothers had sent home.
"Maybe they'll let me take some sick days next week," Miguel said.
"I hope so," his brother said. "I don't know if you're going to be able to keep going."
Also scattered on the table were letters from the state explaining how Miguel could put in a workers' compensation claim and collect benefits. Neither brother could read, though, and in any case, the letters were written in English. The last one said that the deadline to apply had passed.
Miguel said that when he got hurt, his supervisor told him not to give his real age at the hospital. In the milking warehouse, though, most everyone knew he was a minor.
There was no need to hide on the night shift. No one was coming to look for him.
Marcela Valdes contributed reporting.
