In a special unprecedented presentation, Association President/CEO Roger Isom testified before the CalOSHA Standards Board on their proposed new standard “Heat Illness Prevention in Indoor Places of Employment.” The presentation occurred last week during the CalOSHA Standards Board regular Board Meeting, but the presentation by the Association was the only item on the agenda and the Board allowed Isom 15 minutes to present the topic. As a reminder the proposed standard is triggered when indoor paces of employment hit 82 °F, and requires engineering controls to bring indoor temperatures to below 87 °F. This would apply to any cotton gin, nut huller or processor and any farm warehouse or shop building. The requirement to cool the buildings to below 87 °F is the primary issue and presents the biggest and most expensive challenge to meeting such a low target temperature.  Isom provided cost estimates from $1 million for a single building to $9.5 million for multiple buildings to install air conditioning, but also stated it would present operational issues with cotton gins and almond hullers as those operations require large volumes of air to either move products from point A to point B, or is used to pull hulls, shells, and dust from the conveyance of products. The proposed regulation states this is only required unless it is not feasible, but “feasible” is not defined.  The lack of a definition is what causes the most concern as it leaves it up to enforcement discretion and subjectivity. The Association emphasized the need to define “feasible” in the context of this regulation. No other presentation was provided and we will now have to wait and see what CalOSHA does with the proposed regulation in response.