Wednesday, December 14, 2011

More Child Labor Law Sarcasm

Apologies for my sarcasm (shown in red) in advance.
Agricultural Secretary Tom Vilsack recently said there has been some concern and confusion in rural America over the Department of Labor’s (DOL) proposed regulations on child labor. You have to love that statement.  Really I don’t think there has been any confusion.  Rural America just doesn’t like it and the only people it really affects is well Rural America.  No need to apologize Mr. Vilsack, just make it go away.
He went on to say, statistics show that while only 4 percent of working youth are in the agriculture sector, 40 percent of fatalities of working kids are associated with machines, equipment, or facilities related to agriculture.  That’s way too high.  We don’t want to blur the line between teaching kids about a good day’s hard work, and putting them in situations more safely handled by adults. Statistics are so interesting so is that 4% of all youth working where specifically?Don't insult our intelligence with numbers that are so vague.  Why are only looking at youth being killed while working what about the alternative to working?  I am confused are you saying that we have more youth being killed in farm accidents then lets say drug overdoses and car accidents involving drugs and alcohol?  I love statistics. I would like the statistics on the amount of revenue and economic stimulus that is derived from youth working in agriculture. I also want to know where you plan to make up for that when it comes out of the budget.  
Do not put your faith in what statistics say until you have carefully considered what they do not say.  ~William W. Watt
He uses statistics as a drunken man uses lampposts - for support rather than for illumination.  ~Andrew Lang
Say you were standing with one foot in the oven and one foot in an ice bucket.  According to the percentage people, you should be perfectly comfortable.  ~Bobby Bragan, 1963 
Mr. Vilsack goes on to make this point. First, it is important to know that DOL is not proposing any changes to how a son or daughter can help on their family farm.  There is nothing in the proposed rule that affects the ability of parents and families to assign chores and tasks to their children. (Unless that chore or task has to be done on a tractor or with another piece of equipment of course)  Further, the proposed rule respects the various ways that farms are structured in rural America, including partnerships and LLC’s.   DOL is looking at possible approaches to simply protect the safety of children hired to work on a farm. With everything going on in the country in agriculture and outside of agriculture our elected officials have decided this is a very important matter.  I just get so confused at what becomes a priority. 
Mr. Vilsack also makes this point. DOL announced their proposal on September 2 to start a conversation (where was this conversation and who did it involve?)  about how to keeps kids out of harm’s way and solicited comments from the agricultural community to ensure everyone had an opportunity to provide input.   USDA worked with DOL to extend the comment period through December 1, to give the farming community additional time to prepare and submit comments to help avoid unintended consequences that impact farmers and ranchers.  Wouldn’t it be nice if instead of extending a comment period they actually went to a family farm where youth were working and asked them for comments since most of them were in the field still harvesting their crops?
We want to ensure that children of farm families maintain their ability to help with the family farm, while working to prevent unnecessary child injuries or deaths.
In the months ahead, we will continue to work with DOL on how to find a common-sense approach to strengthening our agricultural economy and keeping our farm kids safe. We’ll make you a deal; you worry about the economy and we will worry about our kids.

I have attached Department of Labor’s proposed changes and updates.

Welcome to the Department of Labor’s Wage and Hour Division (WHD) Website on the proposed changes to the child labor in agriculture regulations.
On September 2, 2011, the Department published a Notice of Proposed Rulemaking (NPRM) to revise the child labor regulations to strengthen the safety requirements for young workers employed in agriculture. The current child labor agricultural hazardous occupations orders have not been updated since they were promulgated in 1970. The department is proposing a dramatic updating of these regulations based on the enforcement experience of the Wage and Hour Division (WHD), recommendations made by the National Institute for Occupational Safety and Health, and a commitment to bring parity between the rules for agricultural employment and the more stringent rules 

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