This is difficult to answer. We aren’t lawyers and don’t exactly understand how the law works here. If you practice law and specialize in labor, students in the ANCT program (past and present) would love to talk to you.

If the zoo were considered a zoo, it might be violating labor laws. But, is it considered a college? Is it both? Are students classified as unpaid interns?

From the student perspective, the zoo plays both sides separately. When they want to limit the freedom of speech and student self-expression, it’s a “zoo” and students must “maintain professionalism”. But when it comes to days off, scheduled breaks, a lunch break, and other workers’ rights, it’s a “college” and the zoo doesn’t have to abide by labor laws.

We argue that whether or not the program is legally required to follow labor laws, it should. Students should get two breaks and a lunch when required to be at the zoo all day. They technically have a lunch break in their schedules, but often have to care for animals in place of taking that lunch. There are no breaks. Students have been scolded by staff for “standing around” to catch a breath between intensive tasks.

The U.S. Department of Labor has a test for what crosses the line from unpaid intern to employee. Number six doesn’t pass muster for ANCT students. “The extent to which the intern’s work complements, rather than displaces, the work of paid employees while providing significant educational benefits to the intern.”

Students are responsible for feeding, enriching, training, records, and cleaning. If they were to not show up for work at 8 a.m tomorrow, the zoo would likely shut down for the day. With a handful of staff, it would be difficult to get all of the animals fed by the required time. It would be extremely unlikely that they’d also be able to clean enclosures and provide each animal with necessary enrichment. Animal welfare would suffer. I hope they wouldn’t forget to submit their records.