Nebraska Grain and Feed Association
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Your Input Is Important, So Please Respond!

On September 2, the U.S. Department of Labor (DOL) proposed substantial revisions to the department’s child labor regulations to ban youth under certain ages from engaging in specific types of work at off-farm agricultural business, as well as on farms not owned or operated by their parents.  Among other things, the U.S. Labor Department is proposing to establish a new hazardous occupation order that would prevent youth less than 18 years of age from being employed in the storing, marketing and transportation of farm product raw materials. Prohibited places and types of employment would include grain elevators, grain bins, silos, feedlots, stockyards, livestock exchanges and livestock auctions.  The proposed rule also would prohibit youth younger than 18 from agricultural work involving animals, and in storage bins, pesticide-handling, timber operations and manure pits.

For the grain handling industry, it appears that the proposals are far too broad and could have a negative economic impact on both member companies and rural communities.  Therefore, NGFA believes that teens under 18 (mostly around 16 and 17) should still be allowed to work at grain handling facilities to help sweep driveways during harvest, clean water tanks in empty pens, and perform other miscellaneous jobs that do not present dangers associated with engulfment, augers, and coming into contact with livestock.   NGFA will submit individual comments supporting this position as well as signing onto joint comments, highlighting these points, that we plan to develop with Farm Bureau.


NGFA is currently drafting comments to submit to DOL and will send out a template, by early next week, for members to use for developing comments.  In the letter, we would like to highlight the direct and secondary costs to the grain storage industry to replace the seasonal teen workers that will no longer be able to work grain handling or feed facilities, if the rule goes into effect.

To assist us in working towards an agreeable resolution of this issue with DOL, we would appreciate if members could respond the following series of questions.  If the requested information is not readily available, we would appreciate if you could please provide a reasonable estimate.  NGFA is also working with the Small Business Administration on developing comments. The more economic data, anecdotes and examples that we can use in our comments, the stronger our argument will be.  Please feel free to provide me with any other information that you believe is relevant to this issue.  


  1. How many teens under 18 work at grain handling/feed facilities? Is it a key part of facility staff during harvest?
  2. What percentage of local workforce is comprised of 16-18 year olds?
  3. What is local/state teen unemployment rate? Any other opportunities for teens if they can’t work at grain handling facility during harvest?
  4. If teens under 18 were not allowed to work at a facility, what would be the direct cost to the company? What would be indirect costs to community?
  5. Would there be any other opportunities for teen workers, who are interested in agriculture/agronomy, to get firsthand experience in the industry if they are not allowed to work at grain handling/feed facilities?
  6. Would it be difficult for companies to find replacements for the teens if they are not allowed to work?


Feel free to contact Pat if you have any questions or need additional information.



calendar of events

August 4, 2017

NeGFA Summer Meeting & Golf Outing

York Country Club

York, NE





contact us

Nebraska Grain and Feed Association
4600 Valley Road, Suite 416
Lincoln, NE 68510-4844
Phone: 402-476-6174
Fax: 402-476-3401