The last time the U.S. Department of Labor made substantial changes to child labor laws relating to youth in agriculture, according to Bill Field, Purdue University farm safety specialist, Lyndon Johnson was president, the John Deere 4020 was still a pup, and yours truly was learning how to drive a newly-purchased Allis-Chalmers D-17, at age 13- an age considered old for learning to drive a tractor in those days. You could still make a living off a 40-cow dairy and 300 acres with family living. Man hadn't even been to the moon yet, and personal computers were more than two decades away.
All this points to the fact that rules affecting agriculture and labor need to be revised. Terms need to be clarified. Many facets of modern agriculture didn't even exist in 1966, including Roundup Ready soybeans, low-rate chemicals, GMO traits, and much more.
Bill Field and cohorts who recently sent a letter asking that the Department of Labor not institute the child labor in agricultural rule changes as proposed acknowledge that the rule dos need to be updated and clarified. It's just that some of the current proposed clarification goes beyond common sense.
"Examples include the proposed revisions to prohibit use of electronic communication devices, specifically cellular telephones, while operating ag tractors and machinery as well as clarification of the definition of agricultural confined spaces," Field wrote in comments sent to the Labor Department about the proposed rule.
"There's also a need to update the language used to describe prohibited practices and include new technology such as skid-steer loaders, all-terrain vehicles and silage baggers," Field says.
"Upon comparison of the current rule with the revisions proposed, it's evident that the federal law will be a continued viable source of reasonable guidance for youth, their parents and their employers in agriculture.
"The proposed changes, in their current form, would also add stress to an over-stretched compliance and enforcement arm of DOL. It's believed that there are other areas of occupational safety and health that would yield a higher return of investment regarding the loss of life and frequency of injury."Don't look for a final ruling on this proposal from the Department of Labor anytime soon. A mass amount of comment information was collected during the comment period and must be reviewed before final decisions on the rule are made.