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Sen. Lydia Brasch

Sen. Lydia Brasch

District 16

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Lincoln, Nebraska – December 1, 2011 – Senator Lydia Brasch, District 16, signed on to a letter to the U.S. Department of Labor expressing great disappointment with the department’s proposed changes to the Child Labor Regulations that will prohibit the employment of young workers in agriculture.  The letter is signed by other state senators and many Nebraska ag groups.  Posted below, the letter urges the proposed regulations to be withdrawn by the department to allow an opportunity for discussion with agriculture producers who are directly involved and affected by any proposed changes.

Emphasizing the importance of engaging our youth in agriculture, Senator Brasch said, “Safety of our youth assisting in farm and ranch operations is critical; however, the Department of Labor must enact reasonable regulations.  Our youth need opportunities to work in agriculture and continue the legacy of this invaluable profession.”


Secretary Hilda L. Solis
United States Department of Labor
Wage and Hour Division

200 Constitution Ave., NW
Washington, DC 20210

RE: RIN 1235-AA06


Dear Secretary Solis,

Early and extensive training of younger generations is vital to the future of the agriculture industry.  On behalf of agriculture producers in the state of Nebraska we write today to inform you of our disappointment in the most recent proposed Child Labor Regulations, Orders and Statements of Interpretation; Child Labor Violations—Civil Money Penalties as published at 76 F.R. 54836-54885.

The proposed regulations demonstrate a complete lack of understanding of agriculture and the people whose livelihood stems from the industry.  Rather than working together to achieve pragmatic safety solutions, the U.S. Department of Labor has proposed a set of regulations that will effectively prohibit all young workers from being employed in agriculture.  We would encourage you to withdraw the proposed regulations and bring together a group of interested stakeholders, including agricultural producers, to discuss such an important issue—safety. 

Involving agricultural producers in this dialogue is imperative to shed light on how illogical the proposed regulations are and to coordinate a safety effort that emphasizes the improvements that have already taken place within the agriculture industry.  A few instances showing the necessity of involving agricultural producers are:

·   Farm and ranch operations often organize as business entities to take advantage of tax and liability benefits.  These entities are created by family members or neighbors. The safety precautions justifying a parental exemption still exist when a child is employed by such an entity.  The parental exemption is completely eroded if it does not allow children to still be employed by these types of operations under the exemption.

·  Dramatic improvements in the area of rollover guards and operator presence technology make power driven equipment much safer than in decades past and have been adopted on most new equipment coming off production lines.  Completely banning children from operating all power driven equipment is unreasonable when these types of protections exist.

·  The extensive education and vast adoption of low stress handling techniques for livestock, like those advocated through the Beef Quality Assurance program, Pork Quality Assurance program (PQA+), United Egg Producers Certified Animal Welfare Program or Animal Care – Best Management Practices for Production & Slaughter program have increased the safe handling of livestock.  Prohibiting children from herding livestock, interacting with them in pens and administering care is unfounded when these types of techniques are in place.

These are just a few examples indicating the safety improvements in agriculture that have been entirely disregarded in the proposed regulations and point out why it is essential that they be withdrawn and further discussion opportunities be established where agricultural producers are involved.



Farm Credit Services of America

Nebraska Agricultural Educators Association

Nebraska Cattlemen, Inc.

Nebraska Corn Growers Association

Nebraska Farm Bureau

Nebraska Grain Sorghum Producers

Nebraska Poultry Industries

Nebraska Pork Producers

Nebraska State Dairy Association

Nebraska State Grange

Nebraska Soybean Association

Lydia Brasch, Nebraska State Senator, District 16

Tom Carlson, Nebraska State Senator, District 38

Deb Fischer, Nebraska State Senator, District 43

Norm Wallman, Nebraska State Senator, District 30

Doug Bergman
Arapahoe, Nebraska

John M. Childears, ARA
President, Broker
Agri Affiliates, Inc.
North Platte, Nebraska

Glen Amateis, Clay Leithead & Naomi Loomis
Double A Feed, Inc.
Bridgeport, Nebraska

Jim Fehringer
Fehringer & Mielak, LLP
Columbus, Nebraska

Larry Wilcox
Sr. Vice President
Minden Exchange Bank & Trust Co.
Minden, Nebraska

Ryan Reiber
Panhandle Rural Electric Membership Association
Alliance, Nebraska

Janice Harrop & Jeremey Shiers
Security State Bank
Ansley, Nebraska

Russ Ropte
Shonsey & Associates
Grand Island, Nebraska




Sen. Lydia Brasch

District 16
Room #1022
P.O. Box 94604
Lincoln, NE 68509
Phone: (402) 471-2728
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