NAWG joined a coalition of 60 agriculture organizations writing the Department of Labor last week requesting an extension of the comment period for a proposal that would greatly restrict children’s activities on the farm.



Among other things, the proposal would prohibit minors under the age of 16 from most farm work, with an exemption for work on a farm operation owned by a minor’s parents. 

This narrow exemption is perhaps the most complicating aspect of the regulations as written for modern farm operations, the majority of which are family-run, but incorporate extended family like grandparents, aunts, uncles, cousins, nieces and nephews. 



The proposal, which the coalition called “extraordinarily” broad, also incorporates agricultural education activities, including those run through schools and organizations like FFA, and long-standing practices involving livestock, fruit production and grain handling that would require complete structural changes to modify.



The coalition told the Labor Department that the proposal’s terms could have broad impact on appropriate work opportunities for young people in rural America as well as the economies of rural communities, many of which already face a dearth of any qualified and willing workers. 



“Should the proposed rule be promulgated in its current form, it would entail sweeping changes in current private and commercial agricultural practices, coupled with an increase in legal liability to farm and ranch families,” the groups wrote. “Its potential negative impact on educating and training a future generation of farmers is real.”



The groups writing Sept. 18 also said an extension in the comment period is needed because it has fallen in the busy harvest season, making it challenging for those who would be most affected by the new regulations — farm families — to thoroughly consider its implications and produce appropriate comments. 



The proposal was issued in September after a year and a half of internal consideration. The coalition asked for at least a 60-day extension of the deadline for final comments, until Jan. 1, 2012.

It is unclear if that extension will be granted before the original commenting due date of Nov. 1. 



The Labor Department proposal in full is at http://webapps.dol.gov/federalregister/HtmlDisplay.aspx?DocId=25286&AgencyId=14.



The full letter is available at www.wheatworld.org/othercorrespondence.