Comment on DOS-2011-0134-0001

Dynamic Global Exchange, Inc. is designated by the U.S. Department of State to sponsor participants in the Summer Work and Travel J-1 Cultural Exchange program (also in the Intern and the Training programs). We completely agree there is a need to standardize the job offer with full details - via the DS 7007. Our concern is focused on the DS proposal, as stated on the form DS 7007, to require a hosting company to provide a SWT participant with a minimum of 32 hours/week of scheduled work. Due to the seasonality of jobs, with students often arriving and departing when tourist traffic is low, requiring each employer to provide a minimum of 32 hours EACH week for program duration is an overly strict requirement. As we understand the regulations, allowing SWT participants to take an additional job was primarily to allow participants to take extra hours with another employer when the primary employer could not provide ample hours. We have met some hosting companies and sponsors of the Intern and of the Training program who have interpreted the 32-hour weekly minimum on those programs to be "an average over the program duration." That is, a participant may work 50+ hours in high season and well less than 30 hours in off-season. Therefore, if a 32 hour minimum IS instituted in the SWT program, THIS also must be clarified (WEEKLY requirement OR AVERAGE over the program duration). Also, please clarify if sponsors will be required to execute a DS 7007 for additional employers a participant may work with.