## Facts

- Production workers at meat and poultry processing plants were required to wear protective gear for their jobs.
- Employees sought wages under the Fair Labor Standards Act (FLSA), as affected by the Portal-to-Portal Act, for time spent:
  - Donning and doffing required protective gear.
  - Walking between changing areas and production areas.
  - Waiting associated with donning and doffing.
- In the IBP litigation, lower courts held the donning/doffing and related walking time compensable.
- In the Barber Foods litigation, lower courts treated related walking and waiting as noncompensable preliminary or postliminary activities.
- The Supreme Court consolidated the cases to determine when these activities fall within compensable work time.

## Issues

1. Whether donning and doffing required protective gear constitute “principal activities” that start and end the compensable workday under the FLSA.
2. Whether time spent walking between changing areas and production areas after donning and before doffing required gear is compensable.
3. Whether pre-shift waiting to begin donning required gear is compensable.
4. Whether post-shift waiting to doff required gear is compensable.

## Decision

- The Court held that donning and doffing required protective gear that is integral and indispensable to the job are “principal activities.”
- The Court held that walking time occurring after the first principal activity and before the last principal activity is compensable as part of the continuous workday.
- The Court held that pre-shift waiting to don the first piece of required gear is noncompensable as a preliminary activity.
- The Court held that post-shift waiting to doff gear that is integral and indispensable is compensable because it occurs within the continuous workday.
- The Court’s rulings resolved the consolidated cases by applying the same continuous-workday framework to both employers’ practices.

## Legal Principles

- “Principal activities” include tasks that are an integral and indispensable part of employees’ productive work.
- When an employee performs the first principal activity, the compensable “workday” begins; it ends only after completion of the last principal activity (the continuous workday rule).
- The Portal-to-Portal Act’s exclusion for “walking, riding, or traveling” applies to travel before the first principal activity and after the last principal activity, not to travel occurring within the continuous workday.
- Waiting time is compensable if it occurs within the continuous workday; waiting to begin the first principal activity is preliminary and excluded.

## Conclusion

The Court concluded that required donning and doffing of integral protective gear are principal activities that start and end the workday, making related walking time and post-shift waiting to doff compensable, while pre-shift waiting to begin donning remains noncompensable under the Portal-to-Portal Act.


IBP, Inc. v. Alvarez, 546 U.S. 21 (2005)