Labor Relations Board,
I write to you as a graduate employee at a public university. My role as a worker, as university officials themselves have been willing to recognize, is obvious.
I teach classes, I grade papers, I perform research, etc. Moreover, graduate students do not perform this labor in the context of a single short training semester but for the majority of their time in graduate school. Many graduate students teach their own classes from start to finish with minimal oversight. That is, from syllabus design to implementation.
Speaking as a graduate student, I have a number of concerns about this proposed rule change, that I hope you will consider before adopting.
First, why must the idea that graduate workers are students entail they are not workers. Doctors are required to take continuing ed courses, and no one would consider them students and not workers. Graduate students can be both.
Even if one thinks graduate students are PRIMARILY students, that still does not entail they not workers at all. On what basis should people who labor for the university not be considered employees at all?
Second, if graduate students are not employees, then why are they paying taxes on their income? It should all be exempt from taxes the way scholarships are.
Third, if graduate students are not employees, then why do they spend the majority of their time in graduate school also having teaching/research duties etc. Surely, the time commitment would far smaller and less common — maybe one semester — if this labor is so tertiary to graduate students. Speaking from my personal case, 20 hours a week for 5 out of 6 years of grad school, is an awful lot of work to not count as an employee.
Fourth, independent of teaching and other duties, why does the research labor itself, e.g. writing a dissertation or publishing papers, not count as employee labor. Identical labor clearly counts as employee labor in the case of university professors.
Fifth, given that many graduate students are not paying tuition, that is, not bringing tuition to the university, then presumably universities primarily value graduate students for their labor. And if graduate students are primarily valued for their labor, then how could they not be considered employees?
Sixth, many graduate students perform labor that is of no pedagogical/personal use to them. I have had to teach classes outside of the area I study. Other graduate students I know have done labor like work at library check-out desks. On what basis are these individuals considered as students and not employees?
Thank you for taking the time to address my concerns.