The NCC has co-signed comments to the Notice of Proposed Rulemaking (NPRM) to revise child labor regulations in agricultural and non-agricultural occupations, including regulations for determining and assessing civil penalties in child labor enforcement proceedings.

An NPRM is a procedure used by government departments and agencies to gather comments on a topic before drafting a proposed rule. 

A Further Notice of Proposed Rulemaking is sometimes announced when additional comments are desired, before an actual proposed rule is submitted to the public for comment. The public has another opportunity to engage when a formal rule is announced.

The proposal would implement recommendations made by the National Institute for Occupational Safety and Health as well as changes identified through the Department of Labor’s (DOL) enforcement actions.

In comments to the DOL, 72 agricultural organizations joined together to criticize the proposal as one which “would significantly curtail the employment opportunities available to youth working in U.S. agriculture…” The full comments are at www.cotton.org/issues/2011/upload/11childlaborcomments1201.pdf.

The comments address misrepresentations in a Human Rights Watch report issued last year that DOL quoted in a press statement; raise concerns about DOL’s interpretation of the exemptions for children working for their parents and as student learners; oppose new and additional restrictions on tractor and other power driven machinery use by minors; oppose the overly broad expansion of the Hazardous Occupation Orders (HO) relating to livestock, timber, construction, elevated surfaces, storage bins and silos; and discourage the DOL from issuing a new agriculture HO that would limit exposure of young farm workers to extreme temperatures.

It is unknown when DOL will complete an evaluation of the submitted comments and a final regulation will be proposed, but the NCC remains engaged and is monitoring the process.

The NCC also joined 38 other organizations in a letter to DOL, which asked for another extension in the comment period in order to further analyze the proposal and respond. The letter is available at www.cotton.org/issues/2011/dollet11.cfm.