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Montana Stockgrowers Call for H-2A Rule Changes
February 2, 2026
The Montana Stockgrowers Association (MSGA) has submitted a formal request for rulemaking to the U.S. Department of Labor (DOL) urging the agency to amend and clarify its regulations governing the H-2A Temporary Agricultural Worker Program to expressly recognize livestock auction markets and rancher/farmer feeder feedlots as falling within the definition of “agriculture.” The petition was developed in response to feedback gathered during MSGA’s Producer Profitability Initiative listening sessions and the Montana Agriculture Labor Summit.
The request asks the Department to update its regulations to reflect the integral role livestock auction markets and rancher/farmer feeder feedlots play in seasonal agricultural production and the broader livestock supply chain. Auction markets are a critical component of the livestock industry, providing essential services such as animal handling, sorting, weighing, marketing, and transportation coordination for producers across Montana and the nation. Rancher/farmer operated feedlots constitute production agriculture by performing essential, value-added activities within the livestock production cycle, including feeding and daily husbandry of animals prior to finishing or sale. These activities are necessary to transform livestock from one production stage to the next and are performed on ranches and farms, thereby falling squarely within the scope of agricultural labor and services relevant to the H-2A Temporary Agricultural Worker Program.
“Livestock auction markets and rancher/farmer feedlots are unquestionably part of production agriculture,” said Lesley Robinson, MSGA President. “Yet under current H-2A regulations, these businesses face uncertainty about their eligibility to participate in the program, even though they perform agricultural work essential to livestock production. Clarifying this definition would provide much-needed regulatory certainty and help address chronic workforce shortages.”
The H-2A program allows agricultural employers to hire temporary foreign workers when domestic labor is unavailable. While the program has long been used by livestock producers, ambiguity in the Department of Labor’s regulatory definition of “agriculture” has left livestock auction markets and feedlots in a gray area, despite their close connection to ranching and farming operations.
In its request, MSGA emphasized that auction market employees routinely perform duties historically and customarily associated with production agriculture, and that excluding these operations from H-2A eligibility undermines the efficiency and resilience of the livestock industry. Clarifying that rancher/farmer feeder feedlots qualify as agricultural employers for purposes of the H-2A program would support the program’s statutory purpose, reflect the economic realities of modern livestock production and marketing, and help ensure the continued functioning of a critical segment of the agricultural economy.
“Montana’s livestock producers depend on well-functioning auction markets and feedlots,” Robinson added. “Ensuring these operations can access a stable workforce is critical not only for animal welfare and producer livelihoods, but also for the strength of rural economies.”
MSGA urged the Department of Labor to initiate rulemaking to amend its H-2A regulations, so they clearly and expressly include livestock auction markets and rancher/farmer feedlots within the definition of agriculture, aligning federal policy with industry realities.
To learn more about the Producer Profitability Initiative, visit www.mtbeef.org.
