Purdue University Safety Specialist Releases Official Comments Sent to Labor

Purdue University Safety Specialist Releases Official Comments Sent to Labor

Letter outlines why proposed rule should not be implemented as currently written.

Indiana farm families and Indiana youth in agriculture have an ally in Bill Field, long-time farm safety specialist at Purdue University. While Field teaches farm safety and has been the symbol of farm safety promotion in Indiana for more than three decades, he and others find great exceptions with the U.S. Department of Labor proposal as written. The proposal would severely limit what anyone under 18 can do on farms and in agribusiness.

Field recently released a copy of the official comments he filed with the Department of Labor during the comment period. Here are excerpts from the letter.

"The proposed rulemaking changes… hold the potential for not only positive but also significant negative effects, perhaps unintended by its framers, to youth less than 16 years old who seek employment or are currently employed in agriculture. In addition, the proposed regulations fail to address adequately the significant costs associated with implementation and enforcement of the new rules, and the collateral effects on already limited employment opportunities for rural youth. Consequently, we don't believe that the proposed rules should be adopted in their present form.

"…The authors (of the rule change) provide no documentable evidence that the broadly expanded prohibitions for youth seeking employment in agriculture will result in a measurable reduction in the number of farm-related fatalities to currently non-exempt youth in agriculture. There are no credible studies that report injuries and fatalities to currently non-exempt youth. To combine all fatality and injury data for youth ages 1-16 that have occurred on farms as justification for the proposed changes that target a relatively small element of the youth in agriculture not only ignores many factors that need to be accounted for, it reflects poor science.

"A review of available data clearly reveals that the incidents involving non-exempt youth comprise a relatively small proportion of the total documented cases. In other words, the proposed changes (to the rule) will have little impact on the overall problem of childhood and youth-related injuries and fatalities.

"In addition, the limited benefits resulting from the rule changes would not meet the most liberal cost/benefit standard during a time when there are much more pressing needs concerning the health and safety of children and youth."

Since this issue is so timely, look for more comments from the Purdue University farm safety specialist's official response in another Web item.

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