Approaches to Reducing the Use of Forced or Child Labor: Summary of a Workshop on Assessing Practice (2009)

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2 SCOPE OF THE WORKSHOP Introductory Remarks Susan Berkowitz, chair of the planning committee, opened the workshop with several focusing comments. After first welcoming the speakers and guests, Dr. Berkowitz elaborated on the purpose of the workshop, which was to discuss a set of criteria for identifying good practices to reduce the use of child or forced labor. She reminded the audience that the criteria to be presented are a starting point for discussion and by no means final. Dr. Berkowitz noted that the workshop was set up to look at the criteria by “critically assessing them, thinking about where there may be gaps, where we may want to reorganize them.” She indicated that the goal of the workshop is “to have tested these criteria against the experience of people who are here either as presenters or in the audience who have deep knowledge of this area because what we would like to emerge from [the workshop] is to flesh out these criteria, to test them against your collective experience, to revise them, and to have them emerge strengthened so that we can go forth with some sense of a set of criteria that can be used across different domains.” Dr. Berkowitz’s noted the importance of focusing on good rather than best practices. She argued that the draft criteria were geared more to finding good practices. A limitation in the criteria, in her opinion, was that we were not “quite there in terms of the ability to define a set of practices that would necessarily work across contexts, recognizing that this is an area where context is very important.” Dr. Berkowitz continued by noting that context matters. She stated it was essential to think about the importance of context in which business practices operate and to use some flexibility in the application of criteria, arguing that “we always need to be sensitive to the particular context in which any of these criteria would be utilized to identify, help ameliorate, modify, or respond to either child or forced labor. That is why the language is not one of best practices but of good practices or effective practices.” Dr. Berkowitz concluded her welcoming remarks by inviting participation from everyone regardless of whether they were a presenter or attending the workshop as an interested audience member. She downplayed the distinction between these two groups, in particular to facilitate a stronger set of criteria that has a certain buy-in, in essence, from the community. She noted that “obviously in the context of the current economic crises, there is all the more reason to be concerned about these kinds of questions [of child and forced labor].” 9 

10 REDUCING THE USE OF FORCED OF CHILD LABOR FIGURE 2-1 Organization of the Bureau of International Labor Affairs at the U.S. Department of Labor. Source: Rachel Rigby, U.S. Department of Labor, Workshop Presentation, May 11, 2009. Sponsor Perspectives Ms. Rachel Rigby and Dr. Charita Castro of the Office of Child Labor, Forced Labor, and Human Trafficking (OCFT), Bureau of International Labor Affairs (ILAB), U.S. Department of Labor presented the perspectives of the sponsors at the workshop. Ms. Rigby presented the organization and mission of ILAB as well as the policy or legislative context for this endeavor. As shown in Figure 2-1, ILAB is composed of an Office of the Deputy Under Secretary comprising senior officials and three operating offices: the Office of Trade and Labor Affairs; the Office of International Relations; and the Office of Child Labor, Forced Labor, and Human Trafficking. The mission of OCFT is to support the labor and foreign policy objectives of the President and the Secretary of Labor, meet congressional mandates, and perform public outreach by promoting the elimination of the worst forms of child labor and increasing knowledge and information on child labor, forced labor, and human trafficking.1 The Office’s portfolio consists of three areas: (1) technical assistance, the grant funding that the Office provides to support international projects designed to eliminate child labor, forced labor, and human trafficking; (2) research and policy; and (3) awareness-raising, helping to educate people in the United States 1 More information about the Office can be found at: http://www.dol.gov/ilab/programs/ocft/. 

SCOPE OF THE WORKSHOP 11 and abroad on international child labor, forced labor, and human trafficking issues. The Office was founded in 1993 at the request of Congress to research and report on international child labor issues. At that time the Office was focused on child labor and was primarily focused on research. In 1995 the Office began receiving funds for its first technical cooperation projects. Those grants went to the International Labor Organization’s International Program on the Elimination of Child Labor.2 In 2001 Congress appropriated additional funds that were used in the Office’s Child Labor Education Initiative3 to provide grants to organizations that remove or prevent children from the worst forms of child labor through educational programs on the theory that education is the best path toward the reduction and elimination of child labor. The Office has continued to receive increasing funding for its education initiative since 2001. In 2005 the office received a new mandate under the Trafficking Victims Protection Reauthorization Act (TVPRA) to monitor and report on forced labor and child labor. Ms. Rigby noted that the Office had already been monitoring and reporting on child labor as well as forced labor as it pertained to children all along; the TVPRA broadened the Office’s mandate to include the issue of forced labor among adults. Ms. Rigby then presented a selection of research initiatives currently being funded4: • The current project, through the National Academies, for the development of criteria for the standard set of practices under the TVPRA; • ILO-IPEC for research that includes national child labor surveys, child labor data collection, methodological developments, baseline surveys, impact assessment, and thematic research;5 • Understanding Children’s Work Project, a partnership between the World Bank, the ILO, and UNICEF, that conducts work on impact evaluation, indicator development and country-level research;6 • Macro International, which conducts research in India, Pakistan and Nepal on children working in the carpet industry—a three year research project;7 • Verité, which is undertaking research on forced labor in eight countries in the production of specific goods; and • Tulane University, which oversees public and private initiatives to eliminate the worst forms of child labor in the cocoa sector in Côte d’Ivoire and Ghana.8 2 According to Ms. Rigby, ILO-IPEC continues to be a major partner for her office. 3 More information on the Initiative can be found at: http://www.dol.gov/ilab/programs/iclp/education/main.htm (accessed September 28, 2009). Goals of the program are: (1) Raise awareness of the importance of education for all children and mobilize a wide array of actors to improve and expand education infrastructures; (2) Develop formal and transitional education systems that encourage working children and those at risk of working to attend school; (3) Strengthen national institutions and policies on education and child labor; and (4) Ensure the long-term sustainability of these efforts. 4 ILO-IPEC funding is tens of millions per year. See “U.S. Department of Labor awards more than $58 million to eliminate exploitive child labor around the world.” Reuters, October 1, 2008, and OCFT Project Status at http://www.dol.gov/ilab/programs/ocft/project-africa.htm (accessed September 28, 2009) and http://www.dol.gov/ilab/programs/ocft/project-asia.htm (accessed September 28, 2009). 5 For a discussion of ILAB funding to ILO-IPEC from 1995 to 2006, see: http://www.dol.gov/ILAB/programs/iclp/iloipec/main.htm (accessed September 28, 2009). 6 For more information on the program, see: http://www.ucw-project.org/ (accessed September 28, 2009). 7 In March 2009 Macro International joined with ICF International and is now called ICF Macro. 8 See the project’s Web site at http://www.childlabor-payson.org/ (accessed September 28, 2009). 

12 REDUCING THE USE OF FORCED OF CHILD LABOR Ms. Rigby then discussed the Office’s legislative mandates on child labor, forced labor, and human trafficking, which form an important policy context for this project, noting that the Office has several current initiatives that are specifically mandated by U.S. law. Executive Order 13126 of 1999, Prohibition of Acquisition of Products Produced by Forced or Indentured Child Labor.9 The intention of this E.O. was to prevent federal agencies from purchasing products made with forced or indentured child labor; Ms. Rigby emphasized that the focus was on forced or indentured child labor and does not include adults. The Office developed and published a list of products in 2001 that it felt met this definition and produced procedural guidelines to guide our work on that list.10 At the same time, the General Services Administration published a federal acquisition regulation final rule as part of the overall U.S. government procurement regulations that require federal contractors that supply products on the Office’s list to certify that they have made a good faith effort to ensure that these products were not made with forced or indentured child labor.11 Ms. Rigby noted that the Office’s list can be updated in response to public submissions or as a result of DOL’s own independent research. The Trade and Development Act of 2000. The Trade Act of 1974 established the U.S. generalized system of preferences (GSP), a trade preference program primarily aimed at developing countries.12 Subsequent amendments to the Trade Act required annual reports to Congress on the status of internationally recognized worker rights, including country efforts to uphold their commitments to combat the worst forms of child labor. The 2000 Trade and Development Act was passed, which called on DOL to report annually to Congress with specific information on beneficiary countries and how they were upholding their commitment to combat the worst forms of child labor. The report covers countries receiving GSP benefits and benefits under other trade preference programs: the African Growth and Opportunity Act (AGOA), the Andean Trade Preference Act (ATPA), and the Caribbean Basin Trade Partnership Act (CBTPA).13 The report covers about 140 countries, and varies each year depending on what 9 For the text of the Executive Order see: http://frwebgate.access.gpo.gov/cgi- bin/getdoc.cgi?dbname=1999_register&docid=99-15491-filed.pdf (accessed September 28, 2009). 10 Details on the 2001 list are found at: http://frwebgate.access.gpo.gov/cgi- bin/getdoc.cgi?dbname=2001_register&docid=01-953-filed.pdf (accessed September 28, 2009). For the text of the Procedural Guidelines, please see: http://frwebgate.access.gpo.gov/cgi- bin/getdoc.cgi?dbname=2001_register&docid=01-952-filed.pdf (accessed September 28, 2009). 11 For the text of the Final Rule see: http://frwebgate.access.gpo.gov/cgi- bin/getdoc.cgi?dbname=2001_register&docid=01-1503-filed.pdf (accessed September 28, 2009). 12 For text of the Act, see Title 19, Chapter 12, available at: http://www4.law.cornell.edu/uscode/19/ch12.html (accessed September 28, 2009). 13 For an example, see: The Department of Labor's 2007 Findings on the Worst Forms of Child Labor available at: http://www.dol.gov/ilab/programs/ocft/PDF/2007OCFTreport.pdf (accessed September 28, 2009). Links to all reports are available at: http://www.dol.gov/ilab/media/reports/iclp/main.htm (accessed September 28, 2009). 

SCOPE OF THE WORKSHOP 13 countries are actually receiving those benefits at any given time. It includes various sections for each country. There is data on working children and the nature of child labor in the country, information on minimum age of work laws and legislation that pertains to the worst forms of child labor in the country such as Penal Codes, information on child labor law enforcement, and overview of government policies and program to combat child labor. The TVPRA of 2005.14 The TVPRA of 2005, Section 105, contained five new mandates for the DOL. Part A calls for the DOL to monitor the use of forced labor and child labor in violation of international standards. As Ms. Rigby stated, the Office has been monitoring the use of child labor since its founding in 1993; the change was the additional focus on monitoring forced labor of adults. An outcome of this mandate was that the Office’s research portfolio expanded. Part B requires DOL to provide information regarding trafficking in persons for the purpose of forced labor to the U.S. State Department’s Office to Monitor and Combat Trafficking in Persons (G/TIP). This, Ms. Rigby noted, was not a new mandate, and in fact the two offices had been working closely and sharing information since the G/TIP was founded in 2001. G/TIP publishes an annual report Trafficking in Persons,15 which contains information supplied by DOL, and DOL cites these reports in its annual reports. Part C requires ILAB to develop and make available to the public a list of goods from countries that ILAB has reason to believe are produced by forced labor or child labor in violation of international standards. Ms. Rigby noted that this area of the mandate had perhaps received the most attention thus far. She noted that ILAB was in the process of producing this list (due in early 2010). ILAB started by setting out procedural guidelines that were published in draft form in October 2007. Public input was then solicited and considered in the final guidelines published in December 2007.16 The guidelines lay out the process by which ILAB will make decisions about which goods should go on that list, the criteria that inform those decisions as well as procedural issues on the development of the list, what will happen after the list is published, and how can it be modified. Ms. Rigby highlighted a key element of these procedural guidelines, which was to point out that they contain the definitions that ILAB uses for forced labor and child labor in the development of this list, as well as other key terms such as what constitutes a “good.”17 Ms. Rigby noted that the definitions are based on both international standards and U.S. law.18 The definition of child labor used is based on ILO Conventions 138 and 182. Convention 138 stipulates that the minimum age for work should be no less than 15 or 14 in certain less developed country contexts and Convention 182 lays out the internationally recognized worst forms of child labor that no child under age 18 should be involved in, including work that could be harmful to the health, safety, or morals of children. For forced labor, guidance is taken from ILO Convention 29. After the procedural guidelines were published, the public was asked to share with ILAB any information on forced labor or child labor and the production of goods globally. The request was framed broadly to allow for a wide scope of comments. The request is essentially open- 14 Reauthorized in 2008. 15 For an example see 2008 Trafficking in Persons Report available at: http://www.state.gov/g/tip/rls/tiprpt/2008/ (accessed September 28, 2009). 16 To read the draft procedural guidelines, see: http://edocket.access.gpo.gov/2007/pdf/E7-19310.pdf (accessed September 28, 2009). To see the final guidelines, see: http://edocket.access.gpo.gov/2007/pdf/E7-25036.pdf (accessed September 28, 2009). 17 The definitions are presented in the first chapter of this report. 18 For a further discussion of the definitions, in particular as they relate to ILO Conventions, see Appendix E. 

14 REDUCING THE USE OF FORCED OF CHILD LABOR ended. ILAB also held a public hearing in April 2008. Six witnesses testified, about 100 individuals attended, and the event was broadcast on C-SPAN.19 ILAB intends to publish that list by January 15, 2010. Part D of the TVPRA called on DOL to work with persons who are involved in the production of listed goods described in subparagraph C, to create a standard set of practices that will reduce the likelihood that such persons will produce goods using the labor described in that paragraph (i.e., forced labor and child labor). As Ms. Rigby noted, this is the part of the mandate that gave rise to this workshop. Part E calls on the DOL to consult with other departments and agencies of the U.S. government to reduce forced and child labor internationally and ensure that products made by forced labor and child labor in violation of international standards are not imported into the United States. As Ms. Rigby noted, the DOL does not have enforcement capacity; rather DOL shares information with other departments and agencies of the U.S. government who do have mandates that relate to the importation of goods. The DOL shares information about the research that it has gathered, which these other entities can use to make decisions about trade policy or importation, for example. The Food Conservation and Energy Act of 2008. Known as the Farm Bill, this legislation mandated that the U.S. Department of Agriculture establish a consultative group to eliminate the use of child labor and forced labor in imported agricultural products. The DOL has a specifically mandated role in the legislation that is part of that group. The group is composed of 13 members, one of which will be the DOL’s Deputy Under Secretary for International Affairs and 12 other members drawn from governmental, nongovernmental, and private sectors. 20 The Farm Bill requires that the group develop recommendations relating to guidelines to reduce the likelihood that agricultural products or commodities imported into the United States are produced with the use of forced labor and child labor.21 The Bill also makes specific reference to the TVPRA, and Ms. Rigby highlighted the close tie between the list that DOL is producing under the TVPRA, which may or may not contain agricultural goods, and the guidelines that will be produced by this group to reduce the likelihood that agricultural goods will be produced using forced labor and child labor. 19 For a record of the hearing, please see: http://www.dol.gov/ilab/programs/ocft/pdf/20080423g.pdf (accessed September 28, 2009). 20 Further details provided by DOL can be found at: http://www.dol.gov/ILAB/programs/ocft/fcea.htm (accessed September 28, 2009). 21 According to the Federal Register Notice (January 21, 2009, 74, No. 12, Page 3546-3547): “The Consultative Group will develop recommendations relating to a standard set of practices for independent, third-party monitoring and verification for the production, processing, and distribution of agricultural products or commodities to reduce the likelihood that agricultural products or commodities imported into the United States are produced with the use of forced labor or child labor. Recommendations developed by the Consultative Group will be submitted to the Secretary of Agriculture by June 18, 2010. Thereafter, the Consultative Group will continue to advise the Secretary as necessary.” 

SCOPE OF THE WORKSHOP 15 Dr. Charita Castro provided further perspectives from the sponsor on the purpose of the workshop, stating that the impetus for it lay in the TVPRA of 2005,22 which called on DOL to work with producers to create a standard set of practices to reduce the likelihood that goods will be produced using forced labor or child labor globally.23 She stated that this workshop was a good venue to bring together experts working in the field and that those presenters represent a broad range of experts from the field of child labor, forced labor, corporate social responsibility, and best practices theory. Dr. Castro said that OCFT has been funding projects since 1995, including projects on forced child labor in over 75 countries.24 These funds have helped the Office gain a great deal of knowledge and expertise among their grantees, particularly implementing agencies such as the ILO (including the International Programme on the Elimination of Child Labour (ILO-IPEC)), and other grantees, some of whom were at the workshop. She noted that these organizations have worked on various interventions and approaches to address child labor and forced labor, working on direct interventions to withdraw and prevent individuals from this exploitation. They have also worked closely with governments and the private sector. Thus, she concluded, that in examining good practices, DOL already had a strong knowledge base to start from. However, she noted that there are also practices by the private sector, public-private partnerships, and other stakeholders that DOL may not be aware of or that have not been shared with the broader public. Given the mandate of the TVPRA and DOL’s state of knowledge, Dr. Castro posed the question: how can the DOL best identify practices that have been most effective so that these can be disseminated and replicated? The DOL approached the National Research Council to help OCFT create a framework that could be used to evaluate practices and identify the most effective ones or the ones that are emerging in the fields that can be considered good practices. Dr. Castro noted that the framework was meant to be a tool to evaluate company efforts, but also noted its potential for use in assessing efforts by governments, public-private partnerships, and others to combat child labor and forced labor in global supply chains.25 Dr. Castro hoped that that over the next two days DOL would get effective feedback as well as a thoughtful discussion about what would be useful criteria. Dr. Castro stressed that this was only one step in a longer process, with multiple opportunities for stakeholder involvement. She noted that once the workshop summary was received from the National Academies, DOL would provide additional opportunities for input from the business community, NGO counterparts, and the broader public. DOL will review the material that emerges from the workshop and then solicit additional feedback on the framework and further examples of practices that go beyond this meeting. Discussion At this point, the floor was opened to comments and questions from the audience. One participant asked for clarification of the starting point for the workshop and whether there was a 22 The TVPRA is discussed in more detail in Chapter 1. 23 Dr. Castro noted in her presentation that the DOL follows international standards and in particular ILO conventions in defining “child labor” and “forced labor.” The actual definitions were not presented in the speech, but can be found in the boxes in the first chapter. 24 See for instance U.S. Department of Labor, Faces of Change: Highlights of U.S. Department of Labor Efforts to Combat International Child Labor, Second Edition. Washington, D.C.: USDOL, 2008. 25 Dr. Castro noted that for purposes of the workshop, that DOL was not distinguishing between goods that are imported into the United States or goods used for domestic consumption. Both types were considered. 

16 REDUCING THE USE OF FORCED OF CHILD LABOR set of assumptions guiding the endeavor. Ms. Rigby noted in response that there are many stakeholders engaged in combating forced and child labor and that through this workshop DOL sought to narrow their focus to private-sector practices. She noted that ILAB was already familiar with many NGO activities, so the workshop was meant to complement what they already knew by focusing on the private sector and public-private partnerships more directly. Dr. Castro added that the focus was on the production of goods, not service industries. A participant noted that one piece of legislation that seemed to be missing from the discussion provided by Ms. Rigby was the Smoot-Hawley Tariff Act. The questioner suggested that the TVPRA, in 105(b)(e), pretty much replicates what was in the early tariff requirements about the exclusion of any good produced with forced labor and then later into child labor, but it also included labor and products produced in prisons. The questioner asked whether the TVPRA took account of the potential use of forced labor in the flow of products from prison-based systems. Ms. Rigby responded that the reason the Smoot-Hawley Act was not covered in her presentation was that it is a law enforced only by the Department of Homeland Security (DHS) Immigration and Customs Enforcement (ICE). According to the Act, ICE is responsible for prohibiting the importation of goods made by prison labor or forced labor under penal sanctions, and that includes of children.26 Ms. Rigby pointed out that a key definitional issue was whether prison labor is forced labor. Based on the ILO Convention 29 definition of forced labor, some prison labor is included, but only under what is defined by the ILO. Not all prison labor is forced labor. A third question focused on Executive Order 13126. The audience member noted that under the executive order contractors are supposed to provide a good-faith examination of their supply chains to determine whether there is forced labor or child labor.27 The question for DOL 26 One participant then added, “The original act says all goods, wares, articles and merchandise mined, produced, or manufactured wholly, or in part, in any foreign country by convict labor and or forced labor and/or indentured labor under penal sanctions. That was the 1930 law and then it was later amended to include child labor.” The full text is: “All goods, wares, articles, and merchandise mined, produced, or manufactured wholly or in part in any foreign country by convict labor or/and forced labor or/and indentured labor under penal sanctions shall not be entitled to entry at any of the ports of the United States, and the importation thereof is hereby prohibited, and the Secretary of the Treasury is authorized and directed to prescribe such regulations as may be necessary for the enforcement of this provision. The provisions of this section relating to goods, wares, articles, and merchandise mined, produced, or manufactured by forced labor or/and indentured labor, shall take effect on January 1, 1932; but in no case shall such provisions be applicable to goods, wares, articles, or merchandise so mined, produced, or manufactured which are not mined, produced, or manufactured in such quantities in the United States as to meet the consumptive demands of the United States. “Forced labor,” as herein used, shall mean all work or service which is exacted from any person under the menace of any penalty for its nonperformance and for which the worker does not offer himself voluntarily. For purposes of this section, the term “forced labor or/and indentured labor” includes forced or indentured child labor.” 27 According to the language of the Executive Order, “Each solicitation of offers for a contract for the procurement of a product included on the list published under section 2 of this order shall include the following provisions: (1) A provision that requires the contractor to certify to the contracting officer that the contractor or, in the case of an incorporated contractor, a responsible official of the contractor has made a good faith effort to determine whether forced or indentured child labor was used to mine, produce, or manufacture any product furnished under the contract 

SCOPE OF THE WORKSHOP 17 was whether “it has supplied what it believes for the past 10 years to have been a definition of good faith efforts. What has been done? What is the standard or definition of those good faith efforts relating to monitoring and certification?” Ms. Rigby clarified that there are two parts to the Executive Order. One part places primary responsibility on DOL for the “research and production of a list of the goods that DOL believes are habitually made with those forms of labor.” She noted that when contractors undertake that good-faith effort, they provide the certifications to a different agency. A fourth question dealt with the roles of the DOL in relation to the State Department and DHS. The questioner was concerned that the agencies might be operating in silos and were not cooperating as much as they could. Dr. Castro responded that the DOL had a number of ways to gather information, including independent contractors collecting data, including primary data from other countries; research activities of the program managers at the OCFT (as well as hearing from grantees); and information provided by the State Department, DOL’s “eyes and ears on the ground.” She noted that DOL has a variety of ways to gather information on the ground even though the DOL does not have field offices. Dr. Castro also noted that DOL worked collaboratively with ICE. A fifth question related to part D of the TVPRA, calling for DOL to work with producers of goods on the list developed to create a set of standards to reduce the likelihood that such persons will produce goods using child labor or forced labor. The questioner asked how DOL intended to interpret that, specifically whether the focus would be on those persons who are engaged in the use of child labor in the production of those goods or those who are not but who might be interested in setting standards for an industry or a sector so as to discourage others from doing so? Dr. Castro responded that they try to engage multiple stakeholders, but “as far as specifics, we are still in discussions about this at DOL.” Following up on that question, a participant noted that the draft criteria provided to workshop participants ahead of time (and discussed in Chapter 5) did not seem to address incentives (including negative incentives) to encourage compliance, nor did it touch upon remediation so that the system or process would not just be regulatory but also encourage and perhaps even help with the changes. The participant wondered if those topics were on the table, to which Dr. Castro responded that they were. One audience member added that it might also be helpful to consider the impact on the wider population and the wider economy, or the wider society of operations that intervene in forced or child labor. One example would be the use of an economic boycott against a country where “we hammer down on the government which then leads to economic deprivation of significant parts of the population.” The discussion concluded with comments regarding labor practices in the United States. One participant asked: “Considering that we have extensive privately owned prisons in the United States and quite a number of them produce under contract to the U.S. government, I am wondering how that is going to fit into these standards or the criteria.” Another audience member noted “the fact that the TVPRA talks about imported agricultural products but of course we have very significant problems with forced labor in domestic agriculture products.” We have to talk about wages and hours. We also have to talk about labor inspection and we have to hope and that, on the basis of those efforts, the contractor is unaware of any such use of child labor; and (2) A provision that obligates the contractor to cooperate fully in providing reasonable access to the contractor's records, documents, persons, or premises if reasonably requested by authorized officials of the contracting agency, the Department of the Treasury, or the Department of Justice, for the purpose of determining whether forced or indentured child labor was used to mine, produce, or manufacture any product furnished under the contract.” 

18 REDUCING THE USE OF FORCED OF CHILD LABOR for an increase in labor inspectors in the United States that might even someday match, say, the number in Ghana per capita.” The first audience member concluded by noting that when individuals work on these issues overseas, they are challenged by individuals in foreign countries who point out flaws they see in the United States. The commenters thought that DOL should take this into account. In the exchange that followed Ms. Rigby reiterated that DOL was following international labor standards, regardless of U.S. practice or practice of any individual country. Dr. Castro noted that DOL receives similar questions when its staff travel overseas. She noted that for purposes of this project, the focus is on the international context, though that is not to say the domestic situation is not important.