On Sept. 2, 2011, the U.S. Department of Labor (DOL) issued a Notice of Proposed Rulemaking (NPRM) on Child Labor Regulations.

A NPRM is the first step an agency makes before actually issuing a proposed rule.

Commenting on a NPRM is the first opportunity the public has to influence a rule’s content. The public has a second opportunity to affect the rule when it is published in a proposed or draft form. Public input at both junctures is crucial.

In the NPRM, the DOL proposed to revise child labor regulations, which set forth the criteria for the employment of minors under 16 years of age in agricultural occupations and under 18 years of age in non-agricultural occupations.

The NPRM proposes to implement specific recommendations made by the National Institute for Occupational Safety and Health, increase parity between the agricultural and non-agricultural child labor provisions, and also target other areas for change.

Several agricultural organizations have identified many areas of concern raised by the proposed rule. Concerns range from the implications of multiple family members working for a family farm organized as a LLC, additional restrictions placed on young people working with and around agricultural equipment, to the future of agricultural education opportunities for youths and teens.

The NCC is working with these organizations in requesting an extension in the comment period to provide time for a thorough analysis of the rule’s potential impacts. The comment period is now through Nov. 1, 2011.