Comment by Dec. 1 on Impacts of “Child Labor” (Part I)

Today and tomorrow I’ll be in Kansas City, meeting with farm broadcasters at their annual convention.   I plan to visit with them about the unintended consequences some proposed rule changes could have on the agricultural community in general and on the seed industry in particular.

One topic of discussion will be probable impacts of tightened rules regarding Child Labor.  The U.S. Department of Labor in September proposed changes that could prohibit children from working on a farm or ranch that is not directly owned by their parents.  Under the proposed rules, farm workers under the age of 16 would be prohibited from working in cultivation and harvesting crops. They also would be prohibited from working at country grain elevators, feedlots and other agribusinesses.

Ironically, the same “family farmers” that regulators are trying to exempt from the proposed rule changes will likely be impacted the most.  Ownership arrangements of farming operations have changed over time as farms and ranches pass from one generation to the next.  It’s common for siblings to jointly own and operate farms.  It’s also common for extended families and neighbors to form legal partnerships.  The proposed new child labor rules, however, could fundamentally alter these dynamics.

Regulators must closely examine how production agriculture operates today.  They need to gain a better understanding of how business is conducted in rural America before these changes are implemented.  But, they can’t do it without your help!

More than ever, the agricultural community needs to unite and be heard.  Submit your comments before December 1, 2011 to the Department of Labor.  To submit written comments, reference RIN 1235-AA06 in your letter and mail it to:

The Wage and Hour Division
U.S. Department of Labor, Room S-3502
200 Constitution Ave., N.W.
Washington, D.C. 20210

Click below for additional background information and how proposed rule changes will impact agriculture.