Thomas Dowd, Administrator
Office of Policy Development and Research
Employment and Training Administration
U.S. Department of Labor
200 Constitution Ave. N.W.
Washington, D.C. 20210
Thank you for the opportunity to comment on the U.S. Department of Labor’s
proposed revision of the 2008 H2A regulations. Georgia Fruit and Vegetable
Growers Association commented extensively when the present regulations were
proposed and were pleased with the final rule approved in January, 2009. We
hope our comments concerning the effects of these proposed revisions on
Georgia growers will be given equal consideration.
The Georgia Fruit and Vegetable Growers Association represents more than 400
members who are growers, packers, shippers and industry suppliers in Georgia,
South Carolina, Alabama and Florida. Fresh market growers are also employers
who depend on large numbers of temporary, seasonal workers to produce their
crops. Most of our larger growers have used the H2A program for almost a
decade to ensure their agricultural workforce is legal. These growers are the
Department’s more knowledgeable stakeholders.
Before we detail the changes to the regulation that we consider most detrimental
to the continued operation of H2A-staffed farms, we want to comment on the
justification offered by USDOL for the proposed revisions. The regulations have
been in effect for less than a year, but USDOL is proposing a major and …