Cal/OSHA has proposed unrealistic changes to heat illness regulations—changes that can directly impact how you run your operations, if approved as proposed. Despite being framed as safety improvements, these new changes under Title 8 §3395 and §3396 go far beyond reasonable protections. They impose excessive paperwork, strict work restrictions, and unrealistic expectations on employers in the state. These proposed changes target acclimatization, employee monitoring, and written heat illness prevention plans.

The most concerning change is the mandatory acclimatization schedule triggered by any day over 80°F for new employees in outdoor workplaces and triggered when any indoor workplace is over 87°F. That could apply for half of the year in some areas in California, specifically the Central Valley. Under these new rules, new employees can only work at 20% capacity on Day 1, while returning employees are capped at 50%. Employers must restrict heat exposure for new and returning employees, regardless of their experience:

• New employees: Capped at 20% of normal workload on Day 1, increasing incrementally to 80% by Day 4.
• Returning employees (after 14 days): Capped at 50% on Day 1, reaching 80% by Day 3.

The schedules are lifted only if the employer can prove the worker has recently performed similar tasks under comparable heat conditions—a proof that requires more documentation.

On top of this, Cal/OSHA now requires employers to distribute their Heat Illness Prevention Plan, available in multiple languages, to new employees during:

• The time of hire
• During heat illness training
• And at least once annually (no more than twice per year)

Folks are already doing the right things—providing water, shade, training, and adjusting schedules when needed. These new rules don’t improve safety—they undermine the ability to operate a business in California.

We’re pushing back on these unrealistic proposed regulatory changes and will be submitting comments to the Cal OSHA Standards Board. The comment period for the proposed changes is open until July 7^th, 2025. We’ll keep fighting on your behalf and pushing back on outlandish regulatory changes like this one.

The new proposed revisions to the Protection from Wildfire Smoke regulations under Cal/OSHA’s §5141.1, is impractical for farming operations. The proposed updated rule requires employers to provide NIOSH-approved respirators, such as N95s, to all agricultural employees when the AQI for PM2.5 reaches 151 but does not exceed 300, and mandates their use when the AQI exceeds 300. In addition, employers must now conduct medical evaluations for respirator use and track real-time air quality, when the AQI exceeds 500.

However, all other non-agricultural employees have a different threshold. All other employers with outdoor workers must provide N95’s when the AQI for PM2.5 reaches 151 but does not exceed 500 and mandates their use when the AQI exceeds 500. Why would agricultural employees be singled out versus all other industries with employees working outdoor? Where is the science-based approach to this? Existing safety practices and common-sense decisions have long protected workers during smoke events and this proposed regulation is yet another additional regulatory and biased burden. Adding to the burden are new demands for medical evaluations (when the AQI exceeds 500), respirator supply logistics, and AQI monitoring.

There needs to be a more flexible, risk-based approach that supports both worker health and economic sustainability. Voluntary protections and practical risk assessments would better serve both worker safety and agricultural sustainability. The Association is strongly opposed to the proposed changes and will be submitting comments during the open comment period which closes July 7^th, 2025. Stay tuned for updates.

Earlier this month, the California Air Resources Board (CARB) announced the intention to roll back the requirement to electrify California fleets.  Passed in 2024, The Advanced Clean Fleets (ACF) and the Advanced Clean Trucks (ACT) rules were controversial from the start.  The ACT rule required equipment manufacturers to meet in-state sales benchmarks of zero-emission vehicles, culminating in 100% sales of ZEVs in the state by 2036.  The ACF rule would require applicable businesses to replace existing fossil fuel burning vehicles with ZEVs at certain annual benchmarks.  The passage of the rules was met with immediate legal challenges, and ultimately needed waiver approval from the U.S. Environmental Protection Agency in order to enforce the regulation. 

CARB has announced that, as part of their legal settlement with 17 states as well as the California Trucking Association, that the agency will not be enforcing the mandatory ZEV sales requirement on manufacturer’s inventory.  Additionally, changes to the ACT rule remove priority fleets and drayage trucks from being the first equipment category to electrify.  While this is welcomed news for overregulated California industries, CARB intends to wait out the current federal administration with the hopes of reintroducing the waiver petition to EPA during a more favorable presidential cabinet. 

With little movement in prices, cotton acreage in California will drop by about 35% in 2025, with almost all of the drop being pima acreage. According to the preliminary planting intentions survey conducted by the California Cotton Ginners and Growers Association over the past month, the Association is currently estimating approximately 93,600 acres of pima, and about 22,690 acres of upland statewide for the 2025 cotton season plus or minus 10%. This survey is based on surveys from all the gins in California and things could change when the final field surveys are completed by CDFA. This is a total estimated cotton acreage for California of 116,290 acres. If it plays out, it will represent a 35% decrease in pima acreage and relatively no change in upland acreage in California as compared to 2024. Again, this is preliminary, but reflects what all gins are reporting.   

U.S. Secretary of Agriculture Brooke Rollins today announced the latest slate of presidential appointments for key Farm Service Agency (FSA) and Rural Development (RD) State Director roles.  “When America’s farming communities prosper, the entire nation thrives. This new group of USDA appointees will ensure President Trump’s America First agenda is a reality in rural areas across the country. I am grateful for the leadership of these new state directors and look forward to their work reorienting the agency to put Farmers First again,” said Secretary Rollins.  FSA State Directors help implement and execute the U.S. Department of Agriculture’s (USDA) policies in planning, organizing, and administering FSA programs through state offices across the country.  RD State Directors help affirm the mission of the Trump Administration by focusing on finding ways to empower rural America and unleash economic prosperity.  Key appointments for California include the following:

• Bryan Anguiano Appointed as State Director, California Rural Development Bryan Anguiano serves as State Director of Rural Development in California. Before being appointed to USDA, Bryan served as California State Director for the Republican National Committee and President Trump’s campaign. During his tenure with the RNC, he oversaw the RNC’s investment for four years and three elections cycles, including the 2022 midterms, 2024 presidential elections, and the California gubernatorial recall.

• Connie Conway Appointed as State Executive Director, California Farm Service Agency Connie Conway serves as State Executive Director of the Farm Service Agency in California, a role she held during President Trump’s first term. She most recently served as chairman of the World Ag Expo, the largest annual outdoor agricultural exposition.

Continuing to focus on maximizing California’s water supplies, the Bureau of Reclamation has announced another increase in water supply allocations for the Central Valley Project for south-of-Delta agricultural contractors. While all north-of-Delta Central Valley Project contractors are currently at 100% of their supplies, south-of-Delta irrigation water service and repayment contractors are today being increased from 40% to 50%.  All other Central Valley Project contract allocations remain the same per the March 27 water supply update. Initial Central Valley Project contract allocations were announced on Feb. 25. “Today’s increase in allocations reinforces our commitment to achieving the objectives outlined in Executive Order 14181, which seeks to maximize water supplies within the Central Valley Project,” stated Acting California-Great Basin Regional Director Adam Nickels. “We are pleased that today’s optimization of available water supplies will continue to support California farmers and the communities we serve.”

AB 942: IOUs Trying to Break Ag Solar Contracts

AB 942 (Calderon) proposes to let the IOUs break the contracts that were signed by agricultural producers and processors who invested in solar energy. The bill would force customers who have been in the Net-Energy Metering (NEM) program for more than 10 years on NEM 1.0 or NEM 2.0 to transition to the newest NBT tariff (NEM 3.0).
 
Customers in NEM 1.0 and NEM 2.0 contracted a 20-year grandfather period on the tariff when they entered the program. AB 942 wants to break that contract. 
 
The bill would also transition any solar installation to the newest tariff if a property is sold. 

AECA strongly opposed this legislation, and urges you to contact your local Assemblymembers and Senators to communicate your opposition. 
 
Senator Marie Alvarado-Gil (SD 4, Madera, Merced, Stanislaus, Tuolumne)
senator.alvarado-gil@senate.ca.gov 916-651-4004
Senator Anna Caballero (SD 14, Fresno, Merced, Madera, Tulare) 
senator.caballero@senate.ca.gov 916-651-4014
Senator Shannon Grove (SD 12, Fresno, Kern, Tulare)
senator.grove@senate.ca.gov 916-651-4012
Senator Melissa Hurtado (SD 16, Fresno, Kern, Kings, Tulare)
senator.hurtado@senate.ca.gov 916-651-4016
Senator Jerry McNerney (SD 5, San Joaquin)
senator.mcnerney@senate.ca.gov 916-651-4005
Assm. Juan Alanis (AD 22, Merced, Stanislaus)
assemblymember.alanis@asm.ca.gov 916-319-2022
Assm. Joaquin Arambula (AD 31, Fresno)
assemblymember.arambula@asm.ca.gov 916-319-2031
Assm. Jasmeet Bains (AD 35, Kern)
assemblymember.bains@asm.ca.gov 91-319-2035
Assm. Stan Ellis (AD 31, Kern, Tulare)
assemblymember.ellis@asm.ca.gov 916-319-2031
Assm. Heath Flora (AD 9, San Joaquin, Stanislaus)
assemblymember.flora@asm.ca.gov 916-319-2009
Assm. Alexandra Macedo (AD 33, Fresno, Kings, Tulare)
assemblymember.macedo@asm.ca.gov 916-319-2033
Assm. Rhodesia Ransom (AD 13, San Joaquin)
assemblymember.ransom@asm.ca.gov 916-319-2013
Assm. Esmeralda Soria (AD 27, Fresno, Madera, Merced)
assemblymember.soria@asm.ca.gov 916-319-2027
Assm. David Tangipa (AD 8, Fresno, Madera, Mariposa, Tuolumne)
assemblymember.tangipa@asm.ca.gov 916-319-2008

Policymakers and regulators need stand up to the IOUs and ensure they honor the agreements made with growers and processors. 

It’s time for the California Cotton Ginners and Growers Association’s 2025 Annual Meeting! This year it will be held in conjunction with Supima’s Annual Meeting and will be held Wednesday, May 21^st at the International Agri-Center in Tulare, California. Registration and Continental Breakfast will begin at 7:30 am. The program will begin with Breakout Sessions at 8:30 am and will end with lunch. A link to the Registration Form and Agenda is below. Please complete and submit the form as soon as possible to allow the Association to make sure we can appropriately plan for the meeting. You can email the form to Michelle Franco at michelle@ccgga.org or fax it to our offices promptly at (559) 252-0551. The cost of the event is free, but we encourage you to consider making a donation of at least $25 to the CCGGA Federal PAC or CCGGA State PAC to help protect California cotton at the state and federal levels. The CCGGA Federal PAC can only accept personal checks. Any corporate contributions must be made to the CCGGA State PAC. If you have any questions, please call our office at (559)252-0684. 

The Association hosted the annual Ginners School & Managerial Seminar last week out in Corcoran. Ginning employees were able to hear presentations on Machine Guarding, Lock Out Tag Out, Spill Prevention Control & Countermeasure Response, Workplace Violence, Loader & Module Handling Safety as well as Fire Response. Gin employees were also tested for their safety knowledge inside of the gin during the Safety Contest. This year’s test was tightly contested, but ultimately Anthony Arreguin of Olam Agri took home the top prize. Managers were able to hear updates from Catherine Houlihan of Barsamian & Moody on 2025 Updates to Labor Law, as well as receive the required Supervisor Sexual Harassment Training from Rigo Ceja with AgSafe. The Association would like to thank the sponsors for this year’s event: CropRX, L.P. Brown, R&C Supply, Robinson’s Sheet Metal, Samuel Packaging and Tama USA Inc.,. Additionally, the Association would like to thank the staff at J.G. Boswell for their help in setting up the event, as well as providing trainers for the different classes held that day. Another special “Thank You” also goes out to Captain Gonzalez with the Kings County Fire Department who helped teach some of the sessions in between responding to emergency requests that day. We couldn’t have done it without your help and support. 

It’s time for the California Cotton Ginners and Growers Association’s 2025 Annual Meeting!  This year it will be held in conjunction with Supima’s Annual Meeting and will be held Wednesday, May 21^st at the International Agri-Center in Tulare, California.  Registration and Continental Breakfast will begin at 7:30 am.  The program will begin with Breakout Sessions at 8:30 am and will end with lunch. Please complete and submit the registration form as soon as possible to allow the Association to make sure we can appropriately plan for the meeting.  You can email the form to Michelle Franco at michelle@ccgga.org or fax it to our offices promptly at (559) 252-0551.  The cost of the event is free, but we encourage you to consider making a donation of at least $25 to the CCGGA Federal PAC or CCGGA State PAC to help protect California cotton at the state and federal levels.  The CCGGA Federal PAC can only accept personal checks.  Any corporate contributions must be made to the CCGGA State PAC.  If you have any questions, please call our office at (559)252-0684.