PETITION TO THE U.S. DEPARTMENT OF LABOR AND EMPLOYMENT STANDARDS
ADMINISTRATION WAGE HOUR DIVISION REGARDING THE UNACCEPTABILITY OF THE
PRESENT ARCHAEOLOGICAL TECHNICIAN I (29023) JOB DESCRIPTION AND WAGE RATE
We, the undersigned, wish to express to the U.S. Department of Labor and the
Employment Standards Administration Wage Hour Division our opposition to
their recent decision regarding the job description and wage rate for the
Archeological Technician I (29023) position.
I. Problems with the Archeological Technician I Job Classification
The Department of Labor (DoL) has recently adopted job classifications and
wage rates for archaeological technicians, recognizing three operative
levels in the practice of archaeological field excavation. It is our
position that Archeological Technician I (29023), which characterizes the
tasks performed at this level of work as "unskilled or semi-skilled," does
not actually exist in the day-to-day practice of contract archaeology, and
in fact invites misuse and outright abuse by Cultural Resource Management
(CRM) firms and other providers of archaeological services, including
government agencies such as the U.S. Forest Service and the Army Corps of
Engineers. These firms and organizations have a vested interest in
maintaining low wages for archaeological technicians, as evidenced by their
lobbying efforts during the DoL's initial consideration of the
archaeological technician question, and the Archeological Technician I
(29023) job classification, despite its questionable veracity, will allow
unscrupulous employers to misrepresent degreed fieldworkers' positions and
deny them the wages and benefits due any other recognized skilled laborers.
We also assert that this deskilling of archaeological fieldwork will have a
negative impact on the quality of excavation and interpretation of
archaeological resources.
II. "Unskilled Labor," Oversight Requirements, and the Archaeological Record
Taking issue first with the classification of archaeological field crew as
performing "unskilled and semi-skilled" tasks -- Cultural Resource
Management (CRM) firms and State Historic Preservation Offices (SHPOs) have
established nearly universal requirements for minimum education and
experience for archaeological fieldworkers at all levels. Typically, crew
members are expected to have at least a BA in Anthropology and to have
completed at least one archaeological field school in order to be considered
as a potential crew member on a CRM archaeological project. These standards
were established by the field at large. Archaeological sites are unique and
extremely complex, and it is widely accepted that the information potential
of these sites is too precious to risk loss by allowing untrained hands to
accomplish excavations and accurately record the systematic process of
removal and destruction. The adoption of the Archeological Technician I
description could serve as a precedent for the removal of existing standards
for prerequisite training and experience of archaeological technicians,
allowing archaeological service providers to hire truly unskilled,
inexperienced, non-degreed laborers to do the delicate work of recovering
archaeological data. Given existing educational requirements and the basis
which underlies them, describing the demands faced by a typical CRM field
technician in the course of his/her job as "unskilled" or "semi-skilled" is
entirely untenable. Archaeological fieldwork, if it is to have any
validity, must be accomplished by highly trained, degreed archaeologists.
CRM archaeology projects, especially large-scale pipeline and road projects,
commonly place individual field crew members or small teams of field crew
far beyond the immediate supervision of field directors and other management
personnel. The Archeological Technician I (29023) job description clearly
states that such workers must be "under direct supervision of archeological
crew chiefs..." Technicians who are operating independently of a director,
as is the case on the majority of CRM archaeology projects, can not be
considered as level I technicians, yet the American Cultural Resource
Association (ACRA) has posted information stating that the Archeological
Technician I position should be considered to represent all "crew member"
(non-supervisory field personnel) tasks. This suggests that these firms do
not fully understand, or simply do not plan to observe, the specific
supervisory/oversight requirements for the level 1 technician position, and
it is precisely this potential for misuse which is the greatest threat posed
by the Archaeological Technician 1 job description. And once again, the
question arises whether degreed, skilled field archaeologists (as all CRM
crew members must be according to established hiring practices) should be
classified as operating at an "unskilled and semi-skilled" level regardless
of oversight.
III. A Call to Abandon the Archeological Technician I Classification
We believe that the risk of abuse, coupled with the structural realities of
day-to-day CRM fieldwork requiring skilled autonomous labor, and the fact
that none of the field personnel working on such projects can truly be
described as unskilled, establishes without question the inappropriateness
of the level 1 technician position. As concerned professionals, we are also
committed to maintaining the highest level of quality in the practice of our
craft and we consider the establishment of the Archeological Technician I
standard as a clear and present threat to the informed recovery of our
fragile and ephemeral history. Individually, we have all pursued extensive
education in order to participate in archaeological field projects, and we
contend that such education is a necessary prerequisite to the responsible
excavation of archaeological resources. If the Archeological Technician I
description opens the door to the widespread use of inexperienced, untrained
technicians on archaeological sites, our knowledge of the buried past will
suffer.
Facing the threat of abuse of Archeological Technician I oversight
requirements by employers, we support the intention of the United
Archaeological Field Technicians Union (Local 141 of the Operating Engineers
AFL-CIO) to pursue such cases whenever possible. However, we would prefer
to have the existing Archeological Technician I job description removed from
the Service Contract Act Directory of Occupations, rather than be subjected
to the personal hardship and litigation which is otherwise inevitable. In
sum, the Archeological Technician I job description is a fictitious creature
which does not apply to CRM archaeology, yet it allows for egregious abuse
and underpayment of the majority of skilled, degreed archaeological
fieldworkers, and the degradation of our profession as a whole.
NAME:
STREET ADDRESS:
CITY, STATE, ZIP:
PHONE NUMBER:
E-MAIL ADDRESS:
COMMENTS:
****************************************************************************
*****
PLEASE COMPLETE THIS FORM AND RETURN (WITH COPY OF PETITION AND SIGNATURE IN
REPLY) TO:
[log in to unmask]
THIS PETITION MAY ALSO BE PRINTED OUT, SIGNED, AND RETURNED VIA U.S. POST TO:
THOMAS C. PATTERSON
2300 WALNUT ST., APT# 701
PHILA., PA 19103
****************************************************************************
******
PLEASE POST TO OTHER APPROPRIATE LISTSERVS AND CIRCULATE IN HARDCOPY
|