Stubbers, Shirley

Document ID: WHD-2011-0001-1176
Document Type: Public Submission
Agency: Wage And Hour Division
Received Date: November 03 2011, at 12:00 AM Eastern Daylight Time
Date Posted: November 4 2011, at 12:00 AM Eastern Standard Time
Comment Start Date: October 31 2011, at 12:00 AM Eastern Standard Time
Comment Due Date: November 4 2011, at 11:59 PM Eastern Standard Time
Tracking Number: 80f66166
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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. The work ethic, family unity, and good citizenship that is created by children with their families whether, Mom & Dad, Aunt & Uncle, Grandpa & Grandma, or close family friends is unmatched. 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!!!!!!!!!!!!!!! Sincerely, Shirley Stubbers

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