The California Cotton Ginners and Growers Associations (CCGGA) and the Western Agricultural Processors Association (WAPA) partnered with several other agricultural groups to submit comments in opposition to the proposed amendments to CalOSHA’s latest proposed revisions to the Heat Illness Standard. While the agency has removed the onerous and impractical distance requirements for shade and water, serious issues remain. The concerns focused on a failure to demonstrate necessity, as CalOSHA has not provided a shred of evidence that these changes will provide any additional protection over the existing standard. The group also expressed concerns with the additional rest period requirements that would only apply to agriculture! And while the distance requirement for shade at 700 feet was removed, it still requires shade to cover all employees at any point in time. This is not only impractical it is most likely impossible in an ag setting. These proposed changes were under a 15 day comment period. CalOSHA remains under serious pressure to pass these changes due to a lawsuit by the UFW. But the Associations remain resolute in opposition to the proposed changes and will remain so until such time as evidence is provided that demonstrates sufficient evidence to warrant revisions to the existing standard.