Employment Law Questions? Ask an Employment Lawyer.
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Employers are required to make good faith efforts to ensure that workers take their rest breaks "insofar as practicable" in the middle of each work period. What is "practicable" depends on the circumstances, and would ultimately be up to a jury to decide in consideration of all the unique facts.
So the answer ultimately comes down to how confidently you can argue that it would be "impractical" to let your employee take their rest breaks in the middle of their shifts. If you would be comfortable taking that position at a labor board hearing, given the unique circumstances of the employment, then you would not be making an unsound decision by structuring rest breaks as you propose. But that is really as definitive an answer as can be given, since the "practicality" of allowing rest breaks in the middle of work periods is inherently subjective and depends on the unique employment.
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