DHS Rule Negatively Impacts All Workers

These comments were sent to the Department of Homeland Security on April 25th, 2008
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Coloradans for Immigrant Rights, a project of the Colorado office of the American Friends Service Committee, submits these comments in opposition to the supplemental proposed rule that reissues the rule on Safe Harbor Procedures for Employers Who Receive a No-Match Letter.

The mission of Coloradans For Immigrant Rights (CFIR) is to create a welcoming climate for all members of our community, to advocate for humane immigration policies and to eliminate unjust immigration practices. We build broad support for immigrant justice by educating and organizing citizens in support of immigrant rights. Many CFIR members have the privilege of citizenship; therefore, we believe it is our responsibility to take guidance from immigrant based groups, and to reach out to other citizens with a pro-immigrant message. We believe diverse pro-immigrant voices grow and strengthen the movement for immigrant justice.

Because of the SSA no-match letters, our staff and members have already received calls reporting increased fear and confusion as employees and employers struggle to understand the policy. Additionally, due to the current anti-immigrant climate, many citizens of Latino descent in Colorado have reported racial profiling across a number of areas. Reissuing this rule can only make it worse.

Relying on a flawed database to solve our nation’s immigration issues is a mistake. Rather the DHS should pursue worksite policies which would enable employers to help their workers adjust their immigration status. It would not only be a more productive and humane, it would recognize the enormous contributions immigrant workers make daily to our nation’s economy.

Coloradans for Immigrant Rights, joins the national American Friends Service Committee office in strongly opposing the Department of Homeland Security’s reissuance, without any substantive change, of the Safe Harbor Procedures for Employers Who Receive a No-Match Letter. The rule does not address the issues raised by the court. It has resulted in the firing of lawfully authorized workers. The proposed changes are not substantive, thus the rule will continue to undermine labor rights thereby causing a detrimental impact on all workers. Additionally, the rule will further overburden the Social Security Administration. Finally, the rule will be costly to workers and to our nation’s economy. At a time of crisis in our nation’s economy, we should be creating policies that strengthen our workforce and communities and that recognize the contributions that all workers make regardless of their status.