At the same time. the Department has failed to concentrate. as Congress intended. on the activities of crew leaders. The result has been widespread harassment of farmers. packers. processors. and their employees. yet little discernible effort to seek out and correct actual abuses by crew leaders. The vague language of the act has allowed the Department to interpret: "Migrant worker" to include local workers. "Agricultural employment" to include nonagricultural employment. and Narrow. loopholeclosing qualifications so as to render an exclusion virtually meaningless. The convoluted format of the act begins by broadly describing activities in which many who obviously are not crew leaders frequently engage. then narrowing the scope by a series of exclusions until supposedly only crew leaders remain. In theory. such a drafting scheme can be made to work. but here the combined effect of the format. vague definitions. and vague qualifications within exclusions have provided the legalistic rationale for a complete subversion of Congress clear intent that farmers. packers. and processors be protected. rather than regulated as farm labor contractors.