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1. The "General Circulation" Sunday Requirement
USADWEB receives many media search requests to find the appropriate publication for Sunday advertisements, for both professional and non-professional positions. The Federal Register, in Vol. 69, No 247, lists the requirement as "a newspaper of general circulation in the area of intended employment most appropriate to the occupation and the workers likely to apply for the job opportunity."
The register's requirement raises the following questions:
1. What does "general" mean? Does it mean greatest circulation?
2. Do we need to know circulation numbers? Does it mean circulation by home delivery or does it suffice to have the paper for sale on newspaper stands?
3. Does the newspaper need to have the greatest circulation in the zip code of the job location, or have a more widespread circulation in the metropolitan statistical area?
One thing we know for sure: The word "general" is not the same as the word "greatest." The Federal Register clearly states a requirement for "greatest circulation" when there is no Sunday paper of general circulation, which forces an employer to advertise in a non-Sunday rural newspaper.
Another thing we know from experience is that many of our clients opt to take a more conservative stance by choosing the greatest circulated Sunday paper. In many cases, the greatest circulated paper may cover a larger geographical area, which shows the employer’s willingness to attract as many US workers as possible.
On occasion, we see smaller circulated papers with a higher circulation in a particular zip code than the generally circulated paper for the entire metropolitan statistical area, even though the latter paper may have the greater circulation overall.
Additionally, we have adopted the position that the sale of papers on a news rack alone does not make the paper fit the general circulation requirement. In some cases, it may make the paper a viable option for the ethnic/local paper option for professional recruitment.
Although there are not necessarily clear-cut answers to the above questions, USADWEB keeps your interests in mind when performing a media search. We give you suggestions based on our experience and, as always, will provide you with the knowledge obtained in our research so that you can make an educated decision. Ultimately, we will defer to your preference.
2. Radio Friendly Scripts VS Newspaper Ready Texts
When placing a radio advertisement, many times the written ad text must be reformatted to make it more "radio friendly." The ad texts that are used for print advertisements often have abbreviations or syntax that make them difficult to understand when they are read aloud.
USADWEB works closely with the radio station to format the script so that it is broadcast in the appropriate language terms to read on the air, without changing or omitting any essential information. This includes writing out any abbreviations. For instance, "exp" becomes "experience" and "Bach" becomes "Bachelor’s Degree." It can also mean varying the word order or supplying "filler" words to flesh out full sentences.
For example, this newspaper ad text:
Ad Specialists (Baltimore, MD): USADWEB f/t mult. pos. Duties incl: execution of mrktng & advertising programs, external comm's, product catalogs, client/cust. svc, etc. Apply: www.usadweb.com or fax resumes 410-580-5417. EOE
might be re-worded for radio as:
USADWEB has multiple full-time positions for Ad Specialists in Baltimore, Maryland. Duties include the execution of marketing and advertising programs, external communications, product catalogs, client/customer service, etcetera. Apply online at www.usadweb.com or fax resumes to 410-580-5417. Equal Opportunity Employer
Most radio ads generally fit in either a 30-second or 60-second spot. Please keep in mind that job codes tend to lengthen the reading time, as each letter must be spoken out. Occasionally, stations may attempt to fill in time gaps by repeating information. We will submit the revised copy to you for approval whenever major changes are made or if we have questions about abbreviations or pronunciation. Of course, you can always submit your own radio-friendly text separately from the newspaper text, if you prefer.
If you would like more information about formatting newspaper texts so that they are radio friendly, please contact your ad representative!
3. BALCA Case Emphasizes Importance of Timely Filing
A recent case decided by the Board of Alien Labor Certification Appeals (BALCA) emphasizes the importance of timely filing for alien labor certifications. In the case of Art O Frame, the Certifying Officer (CO) denied certification because the job order was posted with the State Workforce Agency (SWA) more than 180 days before the application was filed, violating 20 C.F.R. § 656.17(e).
The employer argued that the recruitment process was delayed due to mistakes made by their attorney and the advertising agency that they used in placing the newspaper ads, which required the ads to be re-run. The employer further contended that they attempted to file the application online and were unable to register with the Department of Labor (DOL). They requested that in light of these circumstances, their failure to submit the application within the 180 days be forgiven.
BALCA upheld the denial and refuted the arguments raised by the employer. In addressing the first claim, that the attorney and the ad agency were to blame for the delay, BALCA stated that "delay caused by the errors of an agent do not excuse a substantive defect in the timing of the application."
Furthermore, even though the employer claimed they were unable to file online, this appeared to be due to the employer's failure to provide a Federal Employer Identification Number (FEIN) to the DOL. The employer also did not attempt to mail the application when the online registration failed until they were well past the filing deadline.
At USADWEB, we understand the sensitive timing of your cases, and we work with you to minimize the length of your recruitment campaign. The timely provision of essential information, such as a valid FEIN or Unemployment Insurance Number (UIN) for a SWA job order, and verifying that your ad information is accurate before it runs, can help to expedite your recruitment and minimize delays. Our commitment to your recruitment allows you a sufficient window of time for you to meet your 180-day filing deadline.
Clients' Comments Corner
"A colleague of mine asked me how I go about posting SWA job orders in various states and how do I manage to keep track of my recruitment and tear sheets. I told him I don't ever worry about any of that because I use USADWEB. The specialists at USADWEB are very responsive and well informed. When I don't know the local media market, they make suggestions. I never have to worry that my ads aren't being placed in appropriate media, and I never worry about tearsheets or other placement confirmations. Most importantly, I never have to post job orders or try to teach a client how to place job order."
(Law Firm, Cambridge, MA)
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About
USADWEB
USADWEB,
LLC. is an innovative advertising agency that understands the immigration needs of companies placing recruitment advertising for labor certification cases in PERM, supervised recruitment, and H2B processes. For more
than half a decade, we have helped law offices
and companies all over the United States meet the Department of
Labor's recruiting requirements. Take advantage of our expertise and
relationships with publications throughout the country. Our
knowledgeable staff has experience placing all forms of recruitment:
newspapers, periodicals, journals, internet job search postings,
campus recruitment, radio ads, and more. Contact a representative
for more information on placing your ads today!
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