Wage and Hour Division
U.S. Department of Labor
Room S-3502
200 Constitution Avenue, NW
Washington, DC 20510
RIN 1235-AA06
To Whom It May Concern:
I am concerned about the Department of Labor child labor rule, “Child Labor Regulations, Orders and Statements of Interpretation” (RIN 1235-AA06). This rule will have a dramatic change on current agricultural practices by limiting young family workers from learning how to manage a farm. The activities on a modern farm range from planting, harvesting, collecting fruits and vegetables, caring for animals, and operating tractors and other equipment, among other actions.
Also, ownership of the family farm partnership is unique. In many instances ownership of the family farm has changed as land has passed from one generation to another with multiple family members owning, operating and being employed by the farm. The rule would undermine the traditional extended family farm by limiting the ability of grandchildren, nieces and nephews to learn the family business.
Agriculture operations offer a safe work environment for all workers, especially youth. Farms offer a unique opportunity to train, educate and provide resources for young workers and their families in rural communities. Currently, there are protections for workers on farms and this rule is confusing, duplicative and unnecessary.
Lustig, Doug
This is comment on Notice
Child Labor Violations-Civil Money Penalties
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