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NAMI Submits Comments Regarding DOL's Proposed Amendments to Overtime and Salary Level Provisions

Wednesday, September 9, 2015

(North American Meat Institute)

The Meat Institute submitted comments to the Department of Labor (DOL) opposing amendments to existing overtime provisions and proposed changes to salary levels that exempt individuals from overtime requirements. NAMI stated the proposal would adversely affect many meat and poultry industry employees and put companies at a competitive disadvantage, calling DOL's methodology to raise salary thresholds "untested and complicated." The comments assert the proposal likely would significantly decrease the number of exempt employees in many meat and poultry processing companies and would jeopardize incentive compensation opportunities, benefits, flexibility and professional status for many salaried employees. Hourly workers also would face limited opportunities for career advancement, according to the comments. NAMI said the proposed additional labor costs and regulatory requirements could hinder the ability of the American meat and poultry industry to compete globally.

NAMI also took issue with the proposed automatic annual salary increases, stressing such changes would adversely affect employees and increase costs. Specifically, the comments state the automatic annual change would complicate the planning and implementation of yearly salary increases, and would drive some salaried workers to hourly status. Furthermore, the comments challenge proposed changes to the duties test, contending that artificial caps or limits to the time exempt managers or supervisors can spend on non-exempt work would hinder a facility's operations by causing efficiency losses, increasing administrative burdens and labor costs, undermining customer service and yielding greater wage-and-hour litigation.

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