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For example, DOL has cited growers for describing wages offered as "minimum wage" rather than specifically stating "$7.40 per hour." DOL is also requiring detailed explanations of productivity standards and growers' compliance review and enforcement methods. In addition, DOL has cited growers who failed to disclose bonus structure details if growers traditionally paid bonuses, explaining that if growers historically paid bonuses, growers would likely pay bonuses in the current year and therefore should disclose bonus details as terms and conditions of employment under MSAWPA disclosure requirements. Agricultural employers should carefully review their employment practices and assure MSAWPA disclosures accurately reflect the terms and conditions of employment.

As a result of DOL's recent interpretation and enforcement, Varnum has revised our template disclosure documents to prompt employers to include more specificity on these issues. Our template documents may be downloaded at Template Documents. Please be advised that these forms are not intended to be used "as is" and must be customized for your operation. Please contact Kimberly Clarke at This email address is being protected from spambots. You need JavaScript enabled to view it. if you would like assistance customizing your disclosures.

(Source: Varnum, LLP: Varnum is a regional business law firm with more than 150 lawyers, serving clients in a full range of practice areas.)

DOL Requires Agricultural Employers to be Specific -- Template Documents

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