Ruben Lugo

WORK HISTORY

EDUCATION

ABOUT RUBEN LUGO

My 30 years of experience working for the U.S. Department of Labor, Wage and Hour Division, has enabled me to become a technical and investigative expert on Federal agricultural labor laws, especially the H-2A program. I truly understand the regulatory pitfalls of using the H-2A program. I was responsible for providing technical guidance, managing agricultural investigations, tracking compliance levels of farm labor contractors, supporting negotiations, settlements and litigation efforts, organizing regional outreach efforts, and providing internal agricultural enforcement training to Wage and Hour investigators in the western region and throughout the nation.It takes time, resources, and money to establish systems and protocols to be in compliance with federal labor regulations. Yet it is more costly to be in non-compliance than the cost and effort to be in compliance. DOL data reflects a non-compliance rate of over 80 percent on all their H-2A and agricultural investigations, even for some companies with internal compliance departments. In the last few years, DOL Wage and Hour has settled investigations with several million dollars due in back wages and civil money penalties, with some leading to from the debarment the H-2A program, revocation of a farm labor contractor certificate, and press that resulted in bad publicity for the company, or brand. An additional cost that should be considered when not investing in compliance, is the potential cost of legal representation during an investigation, and even more so for litigation defense. Investing in compliance not only minimizes liability but it also reassures the upper tiers of your supply chain and consumers that your produce was grown and harvested in compliance with all labor regulations. After conducting and reviewing hundreds of agricultural investigations, I have developed a broad understanding of common errors made by agricultural companies that resulted in costly violations. Many of these errors could have been prevented if proactive steps had been taken such as compliance training and monitoring. During my time conducting outreach to employers, I have learned and developed a sensitivity to the challenges faced by agricultural employers with complying with labor regulations. I am now available to evaluate, assess, guide, train, and develop systems for farm labor contractors, associations, growers, packers, shippers, and food manufacturers so a positive impact can be made on sustainable compliance of their organization\'s brand and supply chain.