The Association led a coalition joined by 12 other agricultural organizations from California opposing and submitting comments to Federal OSHA on the Notice of Proposed Rulemaking (NPRM) for the Worker Walkaround Representative Designation Process. This proposal would allow union representatives to accompany OSHA inspectors on a “walkaround inspection” of non-unionized property. OSHA suggests these union representatives must be allowed access to the farm or ranch when they are reasonably necessary to aid in the inspection process. The same access would be available for any other employee’s designee such as trial lawyers or other activists. The coalition expressed serious concerns on allowing people with no expertise or knowledge of safety or industrial hygiene to participate in such an inspection. Current regulations allow for outside representation but specify that the representative must have specific safety knowledge such as a safety engineer or industrial hygienist. The coalition stated the current regulations and process already provide for an adequate and appropriate protection of worker safety.