The National Pork Producers Council (NPPC) along with the American Sheep Industry Association and the National Turkey Federation has jointly submitted comments on the U.S. Department of Labor’s (DOL) proposed on-farm child labor regulations.The groups charged the proposed rules show that DOL has a “shallow understanding of modern livestock and poultry farm practices and production.”For example, many youth use livestock as part of 4-H, FFA and other leadership programs. But under the rules, youth under age 18 would be prohibited from being near certain animals without adult supervision.The rules would also prohibit youth from “operating or assisting to operate” farm machinery over 20 PTO horsepower.Also, tasks involving work at elevations above 6 ft. and near manure storage areas would be prohibited.One “misguided” proposal would allow youth to only work on family farms owned and operated by their own parents, without establishing a clear definition of a family farm.Also, not allowing youth to participate in “practices that inflict pain upon the animal” is an unreasonable proposal. “This would limit youths from simply being in the same enclosure as a veterinarian vaccinating an animal or participating in an activity such as hoof trimming, tail docking or castration,” the organizations commented.In their comments, the organizations strongly urged DOL to make considerable changes before the rule is finalized to avoid “what seems to be an all-out ban on youth involvement in nearly all activities that occur on farms and ranches,” the groups explained.