Hackett, Kevin

Document ID: WHD-2011-0001-0012
Document Type: Public Submission
Agency: Wage And Hour Division
Received Date: September 07 2011, at 12:00 AM Eastern Daylight Time
Date Posted: September 13 2011, at 12:00 AM Eastern Standard Time
Comment Start Date: September 2 2011, at 12:00 AM Eastern Standard Time
Comment Due Date: December 1 2011, at 11:59 PM Eastern Standard Time
Tracking Number: 80f135a2
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I am a nationally certified trainer for the National Safe Tractor & Machinery Operation Program. I have been the coordinator for the Youth Farm Safety Program in Oklahoma with the Oklahoma Cooperative Extension Service (OCES) for 15 years. For 15 years prior to that I trained and certified Youth (14 years old and older) through the program. I retired a year ago from OCES and have continued to support the youth safety effort. I have been involved in developing "Train the Trainer" guides for the Hazardous Occupation Safety Training in Agricultural Program and and providing trainings for trainers in a 4 state area to provide the related certification training programs. I strongly support you allowing Cooperative Extension staff continuing to be allowed to do related farm safety program for youth and familes that fall into that exemption as they need to continue to have access to related subject matter organized training programs. Youth or Family targeted program are still greatly needed as they heavily utilized the previous programs held. I feel like the Student/Trainee program through Vocational AG/Career Tech needs more defined training requirements beyond what has been mentioned. I feel the program needs the prerequisite of a minimum of 8 hours of tractor safety training along with the 90 hour of general agricultural requirement listed (which I feel should contain 8 hours of general farm safety). I also feel the respective implement safety training program should have further direction that the curriculum should be drawn from a curriculm that covers topics such as those covered in the Minimum Core Content Areas as listed by the National Safe Tractor and Machinery Operation Program. Current examples include the program by the same name that was the result of USDA Agreement #2001-41521-01263 and the GearingUp for Safety Program (Purdue University). An updated version of the HOBAR manual that has been used for a number of year would be a good base also.

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