RE: Comments on RIN 1235-AA06 (Child Labor Regulations, Orders and Statements of Interpretation; Child Labor Violations – Civil Money Penalties)
Dear Mr. Kerschner:
I began working on my Grandparents farm when I was 14. I came back every summer to work harvest for them and my uncle until I was 17. Then after finishing high school and getting my EMT- basic I moved from Albuquerque, NM to Halsey, OR at the age of 19 to live and work on the farm while attending Linn Benton community college. I am now a child care teacher, who still works every summer, during harvest, on a farm.
I understand that the proposed changes to the child labor regulations would not allow children under 16 to work on a farm that is not a sole proprietorship of their parents. Had this been enacted when I was a teenage I would have missed many experiences that have been invaluable to me in every job I’ve had since then. I feel I have a better work ethic, a snap to it attitude, and an awareness of my surroundings that are all directly part of learning to “work” on the farm.
Over the years my family has employed many teens on their farm. Including my sister, cousins, second cousins, and neighborhood kids. The parents love that their kids can have a summer job that teaches responsibility, hard work, and respect for the land. Many of those teens have used the money earned working on the farm to pay for college. Most coming back summer after summer.
Those kids take a farm safety course before work on the farm begins, and also go through a fire safety day on the farm taught by my uncle. I have had a lot of jobs where a fire extinguisher has been present, but the farm is the only place where they’ve taught me to use one, and allowed me to practice using it under supervised conditions. We all used a variety of equipment, drove vehicles, climbed ladders, used CB radios to stay in contact, and ended the summer safe and sound. In fact I believe that I am a better driver for having learned to drive on the farm in a slow moving tractor.
Please don’t change the child labor law regulations to prevent 14 and 15 year olds from being fully employed on the farm. The ag community at large would miss including them as workers, but more importantly these kids would miss out on experiences that will last them a lifetime.