Dear Friends of the Triangle Breastfeeding Alliance:
As you know, the Department of Labor (DOL) has posted a Request for Information (RFI) seeking public comments to inform implementation of the Reasonable Break Time for Nursing Mothers law. The DOL’s next step will be to issue a document of guidance for employers in complying with the law, so this opportunity to comment is your chance to say what you think will be important to that process.
USBC’s Nursing Breaks Law Task Force encourages all breastfeeding coalitions to respond to this RFI to share your wisdom and experience. The deadline for comments is Tuesday, February 22, 2011.
USBC has collaborated with national work-family organizations to prepare the attached background document as a template. It contains 12 sections that we hope will help to organize your ideas and your response (see table of contents within the document). You are welcome to use the text of these points as written, amend them in any way you see fit, or to write your own entirely. We do, however, encourage EVERYONE to thank the Department of Labor for drafting preliminary interpretations that set up a culture of trust in each woman’s individual experience and flexibility to meet each woman’s individual needs.
In the RFI, the DOL has asked ten specific questions and two general questions. In addition to responding to these, the background document includes additional points that we found to be important to mention, or to repeat from comments we sent to DOL last spring. Your organization may choose to address any or all of these points. We do encourage you to include real-life stories and examples of creative solutions wherever you can. Finally, remember to say a little about your organization and its particular expertise in work and breastfeeding issues.
*Note: Our partners are still discussing a couple of issues with FLSA experts. These conversations may result in changes or additions to USBC’s own comments, which will be heavily based on this document. We did not want to delay sending this document to you any longer, but if the additional information received is significant we will send an update as soon as we get it.
Here are the quick links you will need for your response:
Direct link to RFI: http://webapps.dol.gov/FederalRegister/HtmlDisplay.aspx?DocId=24540&Month=12&Year=2010
Direct link to submission web page: http://www.regulations.gov/#!submitComment;D=WHD-2010-0003-0001
The USBC web page encouraging submissions of specific problems and solutions about DOL”s “space” questions is also still active at the link below. Thank you for your ongoing support to contact mothers, advocates, and breastfeeding friendly businesses—please do continue to refer them to this page to respond through February 22:
Thank you on behalf of USBC’s Nursing Breaks Law Task Force for all that you do to support women, children, and families!
Best regards,
Megan E. Renner
Executive Director
United States Breastfeeding Committee (USBC)
2025 M Street, NW, Suite 800
Washington, DC 20036
Phone: (202) 367-1132
Fax: (202) 367-2132
The mission of the United States Breastfeeding Committee is to improve the Nation’s health by working collaboratively to protect, promote and support breastfeeding. Donate today!
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