Rocky Mountain Farmers Union posted a comment with the Department of Labor urging that proposed new federal regulations on child labor avoid unintended hardships to family farms and ranches. “We are concerned that the regulations do not clearly exempt family operations that have incorporated,” said Kent Peppler, a Mead, Colorado, farmer and President of RMFU. “We support regulations to improve the safety of young farm workers, but the regulations shouldn’t place unnecessary burdens on farm and ranch families whose children participate in the family work.”
As a grassroots organization working to protect family farmers, ranchers and their rural communities, RMFU advocates for safe agricultural workplaces and supports programs that encourage young people to get experience and training that will lead them to a fulfilling life in agriculture. “We value the health and safety of all farm workers, whether family or hired help,” the comment asserted, “and we support the student-learner programs of rural schools, which offer hands-on training in a safe environment.”
Family-oriented agriculture is the most environmentally, economically and socially responsible model for agricultural production. Families have an inherent concern that their natural resources are sustainable, that their livestock are handled with humane husbandry, and that workers, who include spouses, children, and the extended family, have a safe workplace. The agricultural family has a vested financial and emotional interest in keeping the workplace safe. The proposed rules lack clarity regarding their impact on farms owned by a closely-held family corporation or partnerships consisting of family members. “This could be another case of creating rules that do nothing to curb industrial abuses while creating hardship for conscientious families in agriculture.”
RMFU expressed support for prohibitions on young workers using electronic devices, including communications devices, while operating a tractor. “The risks of ‘distracted driving’ are a mounting problem in the digital age,” Peppler said. However, the comment urged further consideration of the proposed rule requiring a valid state driver’s license to operate a tractor on public roads. Most states have already established their regulations with reference to operating licensed vehicles on public roads. RMFU supports requiring appropriate markings on slow moving equipment to improve operation safety. But national regulations overriding local statutes will degrade the student-learner’s involvement in operation of the farm or ranch. “Operator training is the key to farm safety,” Peppler said.
The proposed rules eliminate many the student-learner and certification exemptions from Hazardous Occupations (HO) rules. This modification will have a direct impact on training the next generation of farmers and ranchers and recruiting young adults into agriculture-related businesses. RMFU urged the Department to provide justification for specific changes within a task area covered by the rule.
“The new regulations would prohibit young family members from learning key skills for raising livestock,” Peppler said. “Young people should have appropriate training, safety conditions, and supervision on the job, but we cannot support prohibiting student-learners from participating in basic animal husbandry.”
RMFU’s comments supported new prohibitions that correct omissions in existing statutes, such as prohibiting hired farm workers under the age of 16 working in silos or grain storage bins, in manure pits, or handling pesticides. “Farm safety is important to RMFU, as important as the health and safety of our own children. The future of American agriculture requires an experienced and trained new generation. We commend the Department’s efforts to make workplaces safer for young workers. However, these regulations go too far in their zeal to protect our young people from their own families. Nobody wants their children working in unsafe conditions. But the Department of Labor must not allow new regulations to have unintended consequences like adverse effects on family farmers and ranchers and on learning and certification programs.”