Your Comments on Child Labor on Farms Needed

Organizations representing production agriculture, including the American Sheep Industry Association, this week requested a 90-day extension to comment on the Department of Labor's (DOL) proposed rule on child labor on farms. Currently, the comment period closes on Nov. 1.

For many, farming and ranching is a family tradition, involving two, three or more generations. But proposed DOL requirements for farm and ranch employers and restrictions on what youth can do on the farm would put that tradition at risk. There is concern that the proposed rule would increase legal liabilities to farm families, as well as force farmers to change the way they plant, harvest, handle livestock and do work on the farm every day. The regulations would also limit training for future farmers and affect some youth's ability to earn money in the summer. The lessons learned on the family farm instill respect for the land and animals, persistence, discipline and hard work.

The DOL rule could impact agricultural operation by:

• Restricting the "Parental Exemption" rule so that farms operated by partnerships and corporations may not benefit. As a result, the rule does not take into account the ownership patterns and operations of family farms because many family farms involve different members and generations of the same family working on the farm. DOL wants to limit the "family farm" exemption solely to the children of the owner or operator of a farm. Other family youth-nieces, nephews or grandchildren-would be restricted in what jobs they could do on the family farm by this rule.
• Calling into question longstanding practices in agriculture, including livestock welfare, planting, operating a tractor, harvesting fruits and vegetables and working near grain bins and elevators, silos and livestock barns.
• Affecting standard education and training for future farmers by reducing on-farm learning opportunities. A student-learner on a farm must satisfactorily complete at least 90 hours of systematic school instruction in agricultural education at or above the eighth grade level before working on the farm.
• Setting a maximum height restriction of 6 feet, thereby limiting young hired workers from working in areas such as barn lofts.
• Prohibiting young hired workers from engaging and assisting in many animal husbandry practices, such as herding animals on horseback.

Currently, the deadline to submit comments is Nov. 1. All farmers and ranchers who might be impacted by this DOL regulation are asked to submit comments at www.regulations.gov/#!submitComment;D=WHD-2011-0001-0001.