Comment on FR Doc # 2012-31269

In determining guidelines for eligibility for part time or adjunct instructors in institutions of higher education, it is critical to contextualize those hours in terms of a full time instructor's responsibilities. A full time instructor's teaching load is only part of the job tasks that result in a full time position. In addition to the teaching load, that full time instructor is also expected to dedicate a certain number of hours per week to both research and service. Therefore, if an instructor were teaching the equivalent of what is a full time teaching load at an institution, that still would not be equivalent to a full time job. In some institutions, an instructor may have service and research responsibilities but that is extremely rare. I agree that office hours, course preparation time and other teaching related duties should be counted; however, this must be placed in context of what comprises a full time faculty position.