Jeff,
I read the document in its entirety.
1. The training, even though it includes actual operation of the facilities of the
employer, is similar to what would be given in a vocational school or academic
educational instruction;
2. The training is for the benefit of the trainees;
3. The trainees do not displace regular employees, but work under their close
observation;
4. The employer that provides the training derives no immediate advantage from the
activities of the trainees, and on occasion the employer�s operations may actually
be impeded;
5. The trainees are not necessarily entitled to a job at the conclusion of the training
period; and
6. The employer and the trainees understand that the trainees are not entitled to
wages for the time spent in training.
I do not see how any of those criteria could not be easily met. I have worked in unpaid internships before in the companion animal veterinary field. A simple form with a signature verifying that I understand what I am getting into suffices.
The six criteria emphasize exactly what I am looking for. As I eluded too earlier, it doesn't make sense to pay someone that you are "training" and will not be making a career out of it at your facility. This training almost always comes at the expense of the business owner, with the trainee coming away with some technical skills and knowledge.
An employer / employee relationship does not exist.
You do not hire a trainee, nor do you promise to do so in the future, which is what makes it legal. A more common term would be "job shadowing", which is very popular in hospitals, veterinary clinics, etc.
Unpaid internships are offered out of the "goodness" of a business owner's heart, not so that they can benefit from slave labor.
I may have used the phrase "working for free" a little too liberally. It should have read, "will learn for free and hopefully not screw up your operation".
