The comment period on proposed changes to the Agricultural Hazardous Occupations Order closed Dec. 1. On that date, a letter was submitted to the U.S. Department of Labor by four men who have been working on a USDA program to enhance the safety training of youth wanting to work in agriculture.
Purdue University's Bill Field says they spent weeks on the letter, which outlines their opposition to the changes, because they were never consulted about the proposals.
"In my mind these are bureaucrats that are not elected by the public that are implementing rural changes on the way we live at the community level," Field said. "And that without really giving a fair shake to the public response that has been very strong concerning some aspects of these proposed rule changes."
Field and his group are not at all opposed to adjustments to some of the rules. In fact, technology and practices that have changed dramatically in the 48 years since the rules were implemented beg for an update. But Field says the ramifications of many items being proposed threaten the accessibility to work experiences for young people.
"It almost excludes for non-farm kids the opportunity to work in some operations," Field said. "Some of the very narrow interpretations, for example it prohibits the use of almost any power tool, and that could include a battery operated screw gun for putting up fences."
Field says DOL wants to implement changes by the first of the year, and he is deeply troubled by the speed of the process and the process itself.
"A democratic society offers us the opportunity to have public input," Field said. "There is no way they will be able to work through 3,900 or 4,000 responses and give them consideration before implementation."
Legislators across the country have been contacted about the rules, and Field says that may be the best recourse now for those hoping to put the skids on implementation. So his advice is to contact your Congressmen and Senators.
Field is a Professor of Agricultural and Biological Engineering at Purdue. Those who worked with him preparing the presentation and signing it are Dr. Shannon Snyder, Student and Agricultural Instructor at Purdue, Roger C. Tormoehlen, Professor at Purdue and Dr. Brian French, Associate Professor at Washington State University.