Working Hours and Leave 178. Regarding the 2018 new regulations of the Labor Standards Act, related to Article 34, “intervals between work rotations or shifts,” and Article 36, “one regular leave day in each seven days of work,” both the labor and management sides expressed their different opinions during the amendment of the law. It has become a major case of disputed legislation. The Ministry of Labor (MOL) did not reserve sufficient time to allow all central authorities to review and evaluate the implications carefully. It has not carefully studied the criteria by which exemptions may be allowed to industries, nor has it provided a clear standard to integrate the opinions and methods considered by all departments. As a result, more than 60 industries raced to claim they would be given exemptions, as seen in the “pre-announcement” draft to all“the authorities governing the central business objectives”. Furthermore, for parts of the labormanagement negotiation meetings, the central authorities, including the Ministry of Economic Affairs (MOEA), the Ministry of Health and Welfare (MOHW), and the Ministry of Transportation and Communication (MOTC) “clearly failed to provide sufficient preparation time for the labor representatives to attend the meeting,” “there were doubts about the industry represented by the workers attending the meeting,” in addition to there being an “uneven number of attendees from the labor and management sides, etc., and the meeting time was too short to allow both sides to express opinions sufficiently.” There were also issues of “dissenting opinions of the attending labor side that were not sufficiently evaluated,” and “examination standard for the necessity of exemptions to the application of the new law was chaotic and unclear.” All of the above indicates that for the amendment of the new regulations of Article 34 and Article 36 of the Labor Standards Act, the procedural aspects and the substantial aspects in formulating these amendments have not been considered thoroughly and adequately. 179. With regard to the four special types of industries to which the exemption to “one regular leave day in each seven days of work,” is applicable as specified by the MOL, some of the criteria for application are too vague. In addition, for the industries to which the exemption is applicable as approved by the MOL, the MOL has not performed an “overwork risk assessment” and proved a “rigorous and clear necessity under the examination standard;” whether the labor representatives attending the labor-management negotiation meeting convened by central government were actually representative of the workers, leading further to the major doubts of “why the exemption cannot be applied to industries with the same conditions,” and “whether the relaxed exemptions should also apply to the upstream, downstream and surrounding industries.” 79