The safety of farm children and youth: understanding reactions to proposed DOL regulatory changes

Abstract

In September 2011, the U.S. Department of Labor (DOL) published its intention to revise child labor regulations for agriculture (RIN: 1235-AA06). The DOL invited public participation through submission of written comments to the Federal Register. Over 10,000 comments were received. Commenting on rulemaking is a key form of public participation, giving interested and affected parties a window of opportunity for voice in the regulation process. This paper is a content analysis of the comments received by the DOL. NVivo software was used to code and classify a random sample of 1000 comments, distinguishing (1) stakeholder groups; (2) key concerns/themes addressed; and (3) degree of support for the proposed changes. The results of the analysis showed a lack of support for the proposal, which corresponds with the DOL's decision to withdraw the proposal in April 2012. A bottom-up participatory approach is a suggested next step to increase buy-in for future children's agricultural safety policy.