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carlucciletter

carlucciletter

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Published by nreisman

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Published by: nreisman on Feb 09, 2011
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02/09/2011

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 2/7/2011Commissioner Colleen C. Gardner  NYS Department of Labor W. Averell Harriman State office CampusBuilding 12Albany, NY 12240Dear Commissioner Gardner:I am writing you concerning the proposed addition of Part 186 to Title 12 of the NewYork Codes, Rules and Regulations (NYCRR) relating to Child Performers (State Register I.D.#LAB-45-10-00020-P). I support the Department of Labor¶s (DOL) mission to establishregulations concerning the safety and employment of child performers. However, I share theconcerns of parents of child performers, production companies and Broadway theatrical groupsthat the proposed rules are too onerous and too dangerous to the future of a healthy film,television and theatrical industry in New York.The film, production and theater industries are responsible for thousands of jobs in NewYork State. If we were to impede these businesses with undue or overly burdensome regulationsthey may seek to do business in another state or country. This would cause serious negativeeconomic consequences for New York and damage its reputation for being a premiere film andtelevision production mecca.The safety and well-being of childhood performers should be given notable consideration by all who are involved in the film, television, production and theater business. The Departmentof Labor should involve all of these parties in drafting rules that will affect the industry. TheDepartment¶s outreach to affected parties appears to be questionable. At this time I wouldrecommend the DOL engage in negotiated rule making (
Negotiated rulemaking
is a process inAmerican administrative law, used by state and federal agencies, in which representatives from agovernment agency and affected interest groups negotiate the terms of a proposed administrativerule) with industry representatives to make sure the regulation adopted into law will best serveall parties involved.After a review of the proposed child performer regulation, it appears the costs of implementing the rule will be overly burdensome to the parents, production companies andtheaters without producing the benefits that DOL wishes to achieve. For example, costsassociated with providing two physical and mental health evaluations by a physician per year 

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