der the Fair Labor Standards Act, because omitting all but the heads of households on their payroll lists may reduce the number of "man days" of labor in a calendar quarter to below the 500-man-day threshold that triggers coverage by the act (29 U.S.C. §213(a)). Although there are no reliable data on how many children of migrant farmworkers actually work in the fields, farmworker advocates and enforcement officials report that the single greatest problem facing children working in agriculture is children working under their parents' payroll numbers (U.S. General Accounting Office, 1998).

As for other industrial sectors, there are no reliable annual U.S. statistics regarding fatal and nonfatal occupational injuries and disease in agriculture because there is no national surveillance system for agricultural workers. In addition to the general limitations of the data that are available (see Chapters 2 and 3) for both adult and young agricultural workers, in agriculture there are the added difficulties of differentiating bystanders from workers; inconsistencies in the definitions of work, farm, and child; and the lack of a universal classification scheme for coding agricultural injuries.

The estimates that have been made are based on adaptations of sources such as the National Electronic Injury Surveillance System (NEISS) of the Consumer Product Safety Commission and state fatality reports. A recent report suggests that an average of 104 individuals younger than 19 die in farm-related incidents every year, which is an annual rate of 8.0 deaths per 100,000 population (Rivara, 1997). Because the source of these estimates does not permit distinguishing deaths unrelated to work from those deaths associated with active labor on farms, the true rate of agricultural work-related childhood fatalities is unknown. There is evidence, however, that most of these fatalities are work-related because children 10 and older—who are more likely than younger children to be working—had substantially higher fatality rates than those in younger age groups. Furthermore, males, who are traditionally assigned more hazardous jobs on farms, had fatality rates that were 2.4 times greater rate than those of females, with the highest fatality rates occurring in the adolescent years.

Further evidence of the importance of agriculture's role in work-