Workers are the eyes and ears of workplaces. When they can report hazards without fear they not only avert danger for themselves but entire workplaces -- and in a time of COVID, families and communities as well. Too often employers use the threat of deportation to silence employees. OSHA must do everything in its power to protect workers who speak up - with strong whistleblower protections (including responding to the... more »

# Civil Right Activity Heat Mapping Project (CRAHM)

# Organizational Change and Decision-Making Presentation

Overview of the Planned Change

Overview of the Planned Change & Potential barriers

Many of today's leading organizations utilize mapping and mapping related tools, to depict the geographic location of their service areas or to make similar references to their individual organizations areas of concentration.... more »

Supporting and adding to CAST LA's comments:

Susan Harwood Grants could integrate labor trafficking awareness

Worker safety training grants aimed to raise worker awareness of health and safety issues could integrate basic awareness training about workplace rights beyond OSH issues, as well as indicators of labor trafficking, and what to do when labor trafficking is suspected. This training should also include de-biasing... more »

Prioritize farmworkers, factory workers, and domestic and home healthcare workers, who are all essential workers who are suffering from the coronavirus at increased rates, for COVID protections (including PPE and improved living conditions and preventative health care), treatment, and vaccination. Improved living conditions and preventative health care should be required of all employers who provide housing for workers.... more »

DOL should increase inspections by WHD and OSHA teams and train all inspectors on identification of possible signs of labor trafficking. All potential trafficking should be shared with appropriate law enforcement partners for investigation and possible prosecution. DOL should coordinate with DHS to provide Continued Presence for all immigrant workers at these workplaces that are identified as potential labor trafficking,... more »

December 14, 2020

Submitted via IDEAS page

Mark Mittelhauser

Associate Deputy Undersecretary for International Affairs

U.S. Department of Labor

RE: U.S. Department of Labor's Efforts to End Labor Trafficking National Online Dialogue

Dear Associate Deputy Undersecretary Mittelhauser:

This comment is being submitted by Centro de los Derechos del Migrante, Inc. (CDM), a binational non-profit with operations in the... more »

Victims of forced labor lack control over the safety of their working conditions, including potential exposure to COVID-19. These workers are less likely to be provided adequate sanitary measures, personal protective equipment (PPE), social distancing and other workplace safety measures or access to testing and medical care. At the same time, DOL/OSHA is extremely underfunded, is yet to issue enforceable workplace safety... more »

Limited protections provided by nonimmigrant work or guestworker visas increase the vulnerabilities of foreign workers to forced labor. The COVID-19 pandemic has only increased these vulnerabilities by making it more difficult for workers to leave abusive employers. All workers in the United States should be able to work for employers that implement worker-centered protections, including COVID-19 protections, be able... more »

Especially during the COVID-19 pandemic, OSHA must continue to protect workers by investigating complaints and carrying out worksite inspections to ensure migrant workers are working in safe environments. OSHA should issue an Emergency Temporary Standard providing regulations to protect workers against coronavirus exposure in the workplace and including specific, enforceable requirements. Temporary visa workers should... more »

Worker safety training grants aimed to raise worker awareness of health and safety issues could integrate basic awareness training about workplace rights beyond OSH issues, as well as indicators of labor trafficking, and what to do when labor trafficking is suspected. It would be important to avoid creating significant additional burden on grantees, and this would ideally be paired with additional discretionary funding... more »

The Advocates for Human Rights recommends that OSHA have a process for assisting if no wage and hour claim is open but where immigration concerns necessitate access to CP and certification. Generally, The Advocates has been pleased with DOL's ability to respond to these issues through a wage/hour investigation that triggers immigration protections; however, where no wage and hour issues appear but trafficking concerns... more »

In our experience, DOL should work to protect J-1 visa holders from trafficking and exploitation. This should be done through cooperation with DOS on pre-departure training, consistent and timely investigations and screening of all host programs, reliable reporting resources for complaints, and more. In our experience, the J-1 program can be valuable; however, it involves significant opportunity for exploitation where... more »

The Advocates for Human Rights recommends DOL set-up and follow procedures for collaboration with ERO/ICE, which focus on the rights of victims and ensuring witness protections. In our experience, DOL ability to investigate has been impinged by ICE/ERO actions that apprehend victims, re-traumatizing them and making investigations/support more challenging due to possible deportation. DOL should work with ICE officials... more »

The Advocates for Human Rights strongly encourages DOL to ensure any protocols guarantee the involvement of social service providers and advocates early and throughout the investigation. The individuals help aid the investigation by providing needed services to make victims safe and comfortable. They also have training and skills in trauma-informed interviewing techniques and understand nuances facing special populations.... more »

1. Create a federal oversight mechanism for health and safety over agricultural labor to enact the same role as OSHA does in construction labor. This should include constant review of and a reporting mechanism for agricultural child laborers with a resource and referral system in place to respond to abuse, exploitation, and trafficking.

2. Develop a training and support network for those with nonimmigrant status or those... more »