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December 17, 2021

U.S. Department of Labor

OSHA 

RE: U.S. Department of Labor rulemaking to protect workers, outdoors and indoors, from heat hazards amid rising temperatures

Pasa Sustainable Agriculture appreciates the opportunity to comment on this rulemaking. Pasa represents more than 7,500 farmers and sustainable food system advocates in Pennsylvania and beyond, and has supported farming that is economically and environmentally sustainable for the past 30 years. On November 19, we held a listening session on the topic of heat and climate impacts to farm workers that included a consultant who advises farms on this topic, as well as presentations from two of our farmer members—one representing an urban farm, and one representing a more typical rural farm. Both farms have been implementing measures to alleviate the impacts of excessive heat on their farm workers for several years, and we share some of those recommendations, along with those of our California-based consultant, here in hopes that they help guide your rulemaking.

Our consultant panelist, Elena Velz, advises farms in the central valley of California on measures to mitigate heat impacts. She stresses basic awareness of the dangers of excessive temperatures, and urges farm managers to learn the signs of heat stress and heat stroke. Additional pointers: Talk to farm workers, in their language, so they truly understand any advice, opportunities or directions. Be willing to adjust working hours to avoid the heat of the day. Have a system in place to call for help, and know where to take workers showing signs of heat stress where they can get immediate medical help. Provide basics like adequate shade, water, salt tablets or other electrolytes. Encourage an open workplace where workers feel empowered to let supervisors know when someone is experiencing heat stress or worse – heat stroke – and to make recommendations of their own to improve working conditions. Ms. Velez provided the attached information sheets that she routinely shares with farms when consulting on this topic, and we have summarized some of these pointers above.

Our rural farmer panelist, Jenifer Glenister of New Morning Farms, urged fellow farm managers to  use common sense, communicate clearly and often, and take advantage of on-farm resources that can help. Ms. Glenister, farm manager/owner of this 95-acre diversified organic vegetable farm in south-central Pennsylvania, has workers periodically take breaks at their shaded stream corridor and even get their feet wet or immerse in the creek to cool down. Other practices and recommendations used by this more traditional farm: Provide signage in the worker’s meeting room on warning signs for heat stress and stroke. Have a medical kit known and easily available. Provide plenty of water and salt tablets, hats and other appropriate gear,and encourage breaks as needed. Set up a canopy for shade where workers can take breaks. Incidentally, many of these practices are also important for livestock who also experience heat stress and even heat stroke.

For our urban farmer panelist, Ali Ascherio, who works at Weavers Way Cooperative – a 3-acre vegetable farm in the city of Philadelphia—conditions are even more extreme for farm workers and volunteers than in a rural setting. There is little shade, no stream, and more heat-island effects from the surrounding city-scape. And yet many of the practices and precautions are similar. Farm workers and volunteers are encouraged to work early morning and late afternoon/evening shifts, and take frequent water breaks. An adjacent farm store provides a respite from the heat and sun during the day for short breaks. Water and salt tablets are provided liberally. Workers are educated by the farm manager on warning signs for heat stress and heat stroke, and encouraged to speak up or simply stop and sit in the shade if feeling heat effects. A table under a tree has been set up as an additional place to sit and drink.    

Other recommendations:

Solar panels that provide shade as well as protection from hail, rain and other impacts are not only protective of underlying crops but can protect farm workers as well. They also reduce water use, create moist hydro-climates, and reduce carbon emissions that fuel climate change. OSHA should support the installation of solar panels, particularly dual use panels, for farmers who want them.

Training for farm managers who may not be aware of the dangers of excessive heat impacts can help them understand the many relatively simple and cost-effective measures they can take to help ensure farm workers aren’t harmed by these increasingly dangerous conditions. OSHA should provide widespread training for farm owners and farm managers across the country.

All farms should be required to undergo basic heat training, and be certified in meeting basic heat-mitigating measures like adequate breaks, water, electrolytes, shade, emergency equipment, and medical rescue planning. OSHA should make this training a requirement for all farms that receive federal agricultural supports.

Additional resources:

https://ehs.fullerton.edu/documents/forms/Heat%20Illness%20Prevention%20Program.pdf

https://www.cdc.gov/niosh/mining/UserFiles/works/pdfs/2017-128.pdf

https://www.isri.org/docs/default-source/default-document-library/heat-safety-resources.pdf

https://www.beaumont.org/health-wellness/blogs/know-the-difference-between-heat-stroke-heat-exhaustion

Pasa contact: Sara Nicholas, Policy Strategist, sara@pasafarming.org, (717) 226-8445