“Gray Area” vs. “Grey Matter”
Over the course of a week, our family has posted a series of blog articles related to the Department of Labor’s proposed changes the types of work youth can do on a farm. Our intent is to increase awareness of this issue and to create dialogue.
The Lathams are sharing their thoughts and concerns over how our particular operation could be impacted in hopes that other families will do the same. We don’t have law degrees nor are we interested in advising people on how to conduct their own business. We understand that each family farming operation has its own unique set of circumstances, and that’s why we’re encouraging farmers to take a closer look at RIN 1235-AA06 to see how their individual operations might be impacted.
While some rule proponents have pointed out there is an exemption for “parents,” this is a grey area. Even youth who work for their parents might not be exempt if their farm is part of a limited liability company (LLC) or trust that includes more than one owner who isn’t a parent. As written, the proposed rules extend the parental exemption to others acting on behalf of a parent but it does not specify “legal guardian.”
We believe the proposed laws include all sorts of gray areas and would like to see common sense (a.k.a. the use of “grey matter”) prevail. Take a closer look and see what questions you have about the proposed regulations; then be sure to ask for answers from the Department of Labor (DOL). When contacting the DOL, be specific about your questions. Also be specific about when commenting on how your operation would be impacted by the proposed rule changes.
Let’s keep this issue “top of mind” within the agricultural community, so that it doesn’t get brushed under the proverbial rug when the nation’s attention turns to hosting holiday gatherings at the week’s end. The U.S. Department of Labor needs to hear potential impacts their proposed regulations could have on real-life farm families.
Consider making “child labor” a topic of conversation at your family’s dinner table this Thanksgiving. After all, the comments are due by Dec. 1. Click here to submit your comments online. 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
Other related blog posts:
- Comment by Dec. 1 on how proposed changes to “child labor” regulations would impact your farm: http://bit.ly/ueDC92
- Farm cores help build character & work ethic. If you agree, please contact the Department of Labor by Dec 1: http://bit.ly/uCEp0X
- FFA & 4-H projects could be affected by proposed “child labor” rules: http://bit.ly/uCEp0X (http://bit.ly/w4pBxk)
- Child labor? Oh, please! Every day is “bring your child to work day” on the farm.” http://bit.ly/rWd2My
- Teen Farm Labor is Vital in Rural Areas: http://bit.ly/t5j65s