Association Opposes Cal/OSHA Indoor Heat Stress Regulation

The Association joined several other agricultural organizations in submitting written comments opposing CalOSHA’s proposed “Heat Illness Prevention in Indoor Places of Employment” standard.  Last year, the legislature in its infinite wisdom decided it was necessary for California to not only be the only state with an outdoor heat illness regulation, they passed legislation to mandate the Cal/OSHA adopt an “indoor heat illness” regulation.  Accordingly, Cal/OSHA has now drafted and released a proposed standard entitled Heat Illness Prevention in Indoor Places of Employment.  If enacted, the proposed standard would require employers to conduct the following:

  • Establish, implement and maintain an effective heat illness prevention plan for “indoor heat illness”
  • Measure the wet bulb globe temperature (WBGT)
  • Identify each individual employee’s work activity levels and clothing adjustment factors
  • Conduct heat stress hazard assessment of all facilities
  • Provide access to potable drinking water
  • Provide for preventative cool-down rest periods of no less than 5 minutes
  • Establish effective first-aid and emergency response procedures for responding to possible heat illness
  • Provide engineering controls to reduce employee exposures to reduce heat stress including but not limited to: isolation of hot processes or work areas, shielding of radiant heat sources, insulating hot objects, and local exhaust ventilation
  • Provide administrative controls including but not limit to: reduced activity levels, work-rest schedules and cooled rest areas
  • Remind employees throughout the work shift to drink plenty of water
  • Conduct pre-shift meetings to review high heat procedures
  • Make personal protective equipment, such as water-cooled garments, air-cooled garments, ice-packet vests, wetted over-garments and heat-reflective clothing available to employees exposed to high heat sources
  • Keep records of heat stress hazard assessments and trainings

The Association has reviewed the proposed standard and attended the recent workshop held in Oakland on the proposed standard.  Based upon that review we have serious concerns with the proposed regulations and the impact they could have on agricultural operations, including tree nut farms, hullers and processors.  We feel strongly that the proposed standard is not warranted or justified in the agricultural industry, is overly cumbersome and too complicated and costly to implement.