Office and clerical employees, such as bookkeepers, stenographers,
typists, and others who perform general office work of a firm engaged in
operating fishing boats are not for that reason within the section
13(a)(5) exemption. Under the principles stated in Sec. 784.106, their
general office activities are not a part of any of the named operations
even when they are selling, taking, and putting up orders, on recording
sales, taking cash or making telephone connections for customer or
dealer calls. Employment in the specific activities enumerated in the
preceding sentence would ordinarily, however, be exempt under section
13(b)(4) since such activities constitute ``marketing'' or
``distributing'' within the meaning of that exemption (see
Sec. 784.153). In certain circumstances, office or clerical employees
may come within the section 13(a)(5) exemption. If, for example, it is
necessary to the conduct of the fishing operations that such employees
accompany a fishing expedition to the fishing grounds to perform certain
work required there in connection with the catch, their employment under
such circumstances may, as a practical matter, be directly and
necessarily a part of the operations for which exemption was intended,
in which event the exemption would apply to them.
