Letter to Oregon Occupational Safety and Health Administration
March 17, 2022
RE: PUBLIC COMMENT PERIOD-OSHA RULES TO ADDRESS EXCESSIVE HEAT AND WILDFIRE SMOKE Dear Oregon OSHA,
These comments are on behalf of Climate Jobs. Climate Jobs members are labor advocates and union leaders, of many years standing. As an organization, our concerns are broadly related to advocating for and engaging working people in a rapid and sustainable transition towards a more climate-supportive economy with good jobs – which includes jobs that do not put one’s health at risk. We recognize that serious adaptations in the workplace, including those required to protect worker health and safety, will be necessary to continue specific types of work as the climate continues to warm and wildfires spread.
Many of Oregon’s essential workers - roofers, landscapers, farmworkers, construction workers, public sector workers who maintain our parks, monitor the health of our streams, and test our auto emissions – are already experiencing health challenges due to the impact of climate change in Oregon.
Workers should be protected from having to trade their health and lives for a job. In this respect, we fully agree with the principles that led to the creation of federal and state OSHAs. We acknowledge the incredibly challenging work of OSHA staff in moving Oregon towards strong protections for workers exposed to excessive heat and wildfire smoke.
We appreciate your close attention to the experiences workers shared during listening sessions and hearings. We believe that OSHA has responded to a number of science-based arguments presented by the PCUN/OEC-led Rulemaking Advisory Group, of which we are a member.
There is so much promise in these rules - promise to preserve the health of Oregon’s workers and to save lives as our state’s climate becomes hotter and wildfires continue. However, we also believe that there are some critical areas that need strengthening to ensure that workers are truly protected against known dangers of high heat and wildfire smoke. We understand that OSHA has to balance the interests of various stakeholders, however, OSHA’s core mission is “To advance and improve workplace safety and health for all workers in Oregon.” Oregon workers depend on OSHA to fulfill this mission.
This is particularly important to Oregon’s most vulnerable workers who are disproportionately represented among those who will suffer from future excessive heat and wildfire smoke.
The Oregon Health Authority’s January 2021 report to the governor, related to its Climate Emergency mandate, stated, “Sadly, agricultural workers, fishers, forestry workers and hunters account for 20% of heat-related deaths in the United States. Farmworkers, the vast majority of whom in Oregon are Latinx immigrants, are particularly vulnerable due to social factors such as racism, language barriers, and lack of adequate housing. In urban areas, people who work and reside in urban heat islands (i.e., construction workers) are also more at risk of climate-related health hazards.” This reality creates a special role for OSHA in protecting the most vulnerable workers in Oregon.
Comments on the Smoke Rules
Strong wildfire smoke rules are critical due to the serious acute and chronic health effects workers face without such protection. Wildfire smoke particulates, small enough to be absorbed from the lungs into the bloodstream, are associated with respiratory and heart disease. Recent research has shown that the particulates can pass from the bloodstream into the brain, potentially causing neurodegenerative diseases such as Alzheimer’s disease. https://www.sciencedaily.com/releases/2021/12/211206220009.htm
A 2019 study of firefighters across the United States found that long-term exposure to particulate matter in wildfire smoke significantly increased the risk of dying from lung cancer and cardiovascular disease. In addition, volatile chemicals that are known carcinogens have been identified in wildfire smoke. https://pubmed.ncbi.nlm.nih.gov/30981117/
These real and serious health risks do not occur in a single fire season; they build up from repeated exposure. Oregon’s wildfire smoke rules must protect workers against the health dangers of repeated exposure, as well as against the dangers of single incident exposure.
We recommend the following changes to the OSHA Smoke Rules:
1) Revise the AQI triggers downward for mandatory respirator use and fit tests. The triggers in the proposed rule are not based on published public health guidance or peer reviewed scientific research. The trigger level for mandatory respirators in the proposed rule is AQI 251, an air quality level that is unmoored from the health risk levels established by EPA and the scientists who created the AQI
scale. AQI 251 is neither the start nor the end of any of the recognized AQI risk levels; it is a random point already halfway into the “very unhealthy for all” risk level. If Oregon rules are going to use the widely recognized and trackable AQI scale, which they should, then they must also respect the health risk levels that form its basis. The trigger for mandatory respirator use should be set at the point where the air quality is “very unhealthy for all” – at AQI 201.
The trigger for respirator fit tests in the proposed rule is AQI 501 which is literally off the AQI chart, a full 200 points above what the EPA’s AQI scale declares to be “hazardous” air quality. The AQI risk levels are set by EPA and based on sound, peer reviewed science. At AQI 301, EPA recommends that all individuals avoid all physical activity outdoors. As many workers will continue to work at AQI 301 and above, use of fit-tested respirators should begin at that level.
N95 or equivalent respirators are, at best, 95 percent effective and certainly less effective if a worker has facial hair or the mask is not the best fit possible for a given worker. Therefore, workers will still breathe in unknown amounts of particulates. Fit testing will assure that exposures to dangerous particulates and some of the co-pollutants are greatly reduced.
We have heard employers argue that they would prefer higher trigger levels for mandatory respirator requirements or that wearing of respirators be only on a voluntary basis. Employers argue that workers don’t want to wear respirators and employers don’t want to force workers to wear them. The arguments we have heard from employers are based on employer convenience, not on worker safety and health. OSHA’s job, as noted above, is to ensure safe and healthful working conditions. Therefore, we urge OSHA to lower the respirator mandate AQI triggers to levels supported by occupational health and safety research (AQI 201 for mandatory respirator use and AQI 301 for fit-tested respirators). And, we further urge OSHA to address employer concerns by emphasizing, through training materials and direct contact with workers and employers, the importance of creating a workplace culture of health and safety.
2) Include requirements for a Smoke Illness Prevention Plan and Emergency Medical Plan. The goal of a Smoke Illness Prevention Plan is to be prepared to respond to observed or reported health concerns before a health emergency occurs. This type of plan (as in the proposed heat rules) should include measures to mitigate smoke-related health symptoms (i.e., fatigue; difficulty breathing) to ensure that employees can obtain relief before a full-blown medical emergency. An Emergency Medical Plan must also be in place, ready to be immediately implemented, in cases where preventive measures have come too late or trained medical intervention is required. An emergency medical plan (also in the proposed
heat rules) would include response steps were a worker to show or report serious health by symptoms (i.e., asthma attack; severe chest pain). As the word Emergency indicates, time is of the essence in these situations and having an emergency plan in place can mean the difference between recovery and loss of health or life.
3) Require best available technology respirators as improved respirator technology develops and becomes available. Over time, more effective/comfortable respirators that are appropriate to different types of work in high AQI conditions may be developed. It is reasonable that OSHA be able to change respirator requirements as improvements are made without rule change.
4) Require that smoke exposure assessments are conducted in enclosed buildings, structures and enclosed vehicles, including negative air spaces, and describe how those assessments will be conducted; clarify that AQI 101 or lower must be maintained in those spaces. A workplace can have an HVAC system that does not achieve the result of offering workers clean air. OSHA should require that employers monitor the AQI levels in indoor environments with portable measuring devices at regular intervals. Workers must be able to request that an employer re-check air quality as conditions
change. If an HVAC system does not achieve the thresholds in the rule, employers must initiate administrative or engineering controls and comply with the rest of the rule for non-exempt worksites.
Strengthening the final smoke rule by setting lower triggers for the respirator mandate and the fit test, providing a Smoke Illness Prevention Plan and Emergency Medical Plan, providing OSHA with flexibility on respirator requirements, and providing further protection to workers in enclosed spaces would be in the interest of both employers and workers. Employers do not benefit when workers are injured on the job whether it is a fall due to fatigue from working in smoke or a severe asthma attack brought on by a combination of heat stress and smoke inhalation from a non-fit tested respirator. No employer wants a worker to end up in the ER or, worse, to lose their life due to an acute episode or later chronic disease caused by multiple exposures to wildfire smoke.
Comments on the Heat Rules
Work in excessive heat poses both health and safety risks to workers. The health risks, as with exposure to smoke, may be both acute and chronic.
The deleterious effects of heat on workers are well documented. They include acute health effects such as heat exhaustion, heat stroke and injuries caused by physical fatigue and confusion and chronic health effects including cardiovascular diseases, mental health problems, and chronic kidney disease. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4202759/
According to CDC data, farm workers are 20 times more likely to die from heat-related causes than other workers. Studies have found that heat stress poses a substantial risk to construction workers who are especially vulnerable as the majority (e.g., 73% in the U.S.) engage in heavy work outdoors. Studies have shown that construction workers in the U.S. are 13 times more likely to die from a heat-related illness compared to workers in other industries, and within the industry, roofers and road construction workers face a particularly high risk of heat-related illness. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5858316/
We recommend the following changes to the OSHA Heat Rules:
1) The partial exemption for “light” work should be removed. This category is ill-defined in the rules, open to wide and highly subjective interpretation, and likely will expose countless workers to dangerous
heat conditions with no relief. Consider someone working in full sun: standing, walking, bending and stooping. This could describe the job of many who work in construction - flaggers, laborers using light hand tools, or landscapers in public parks. If this work is done in an 88-degree heat index and direct sun, which NIOSH scientists have determined adds 13 degrees to calculate heat load, the worker would experience an effective temperature of 101 degrees. It is wrong and dangerous that these workers not have required access to shade and cool water, nor be trained to identify warning signs of heat
illness. Because sun exposure is not taken into account and further because many people move from light to moderate to heavy work in one shift, we strongly urge OSHA to remove this partial exemption for work described as “light.”
2) Eliminate work/rest schedule Option A. Option A virtually cancels the protections that a work/rest schedule provides. After hearing workers’ stories about how heat made their pace of work intolerable and unsustainable, we were relieved that OSHA added provisions for a work/rest schedule that would allow workers to recuperate, lowering the heat load on their bodies, in the shade so that they could continue on with work much more safely. Option A fails
to indicate how the variables of PPE, clothing, and intensity of work should be measured or how the work/rest schedule should be adjusted once measured. Option A fails to require consideration of the well-documented danger and need for adjustment related to sun exposure.
Here’s a real-life scenario that is unfortunately likely to become much more common, showing that Option A will not be protective and can easily put workers' health and safety in danger. Imagine a farm or construction worker doing work of moderate intensity in a 95-degree heat index in full sun. That sun exposure, according to NIOSH-validated research, means that the worker is experiencing an added heat load of 13 degrees, bringing their effective heat load to 108 degrees. According to the minimal requirements of Option A, the required rest is 10 minutes every two hours. It is easy to see that employers might well double the break to ten minutes per hour if the work is moderate and there is no PPE or special clothing worn. Such a plan, totally allowable under Option A, would expose that worker to a dangerous heat load. Based on scientific research, NIOSH has concluded that for light work at a heat load of 108 degrees, workers should work 35 minutes and rest 25 minutes in a 60 minute period. Option A does not come close to this protective recommendation. It will not protect countless workers, especially as a heat index of 95 degrees will become more common in Oregon. We believe that OSHA is in the position to set the proper standards for the work/rest schedule, not the employer, and urge the removal of Option A.
3) Change the required break time for the first tier of Option C to ten minutes every hour. Option C seems to afford good protection in tiers two, three and four; however, there is a critical problem with the first tier - from a heat index of 90F to a heat index of 94F. This tier’s minimal requirement suffers from the same problem as Option A. The heat load on workers due to exposure to direct sun is not counted, nor is intensity of work. Therefore, a farmworker, construction worker, or warehouse worker in a heat index of 90 degrees F in full sun (heat load to worker of 103) doing moderate or even intense work will only get a break of ten minutes every two hours. This is very serious because it is already common to work in a heat index of 90F to 94F. The heat index is roughly 90 degrees F in the Willamette Valley when the air temp is 87 degrees. We strongly urge OSHA to change the required break time for the first tier of Option C to ten minutes every hour.
Climate Jobs strongly believes that the exemption for light work should be removed. Option A of the work/rest schedule should be removed. Option B of the work/rest schedule should be retained and
Option C, Oregon OSHA’s simplified work/rest schedule should be retained with the change to the first tier discussed above.
Conclusion
In conclusion, we again want to express our gratitude to OSHA staff for their efforts during this long rulemaking process. So much progress has been made towards putting in place the most protective rules possible for Oregon workers. As we all know, Oregon’s rules will be the model as other states and our federal government face the critical need to protect workers more fully. We support rules that will make the promise of OSHA’s mission a reality by protecting workers to the fullest extent possible as they continue to do the work Oregonians benefit from in an increasingly perilous climate. We urge OSHA to maintain the strong worker-protective measures in the proposed rules but to also seriously consider our recommendations and move forward with stronger rules in place.
Thank you,
Leslie Kochan, Nikki Mandell and Laurie King, Climate Jobs
March 17, 2022
RE: PUBLIC COMMENT PERIOD-OSHA RULES TO ADDRESS EXCESSIVE HEAT AND WILDFIRE SMOKE Dear Oregon OSHA,
These comments are on behalf of Climate Jobs. Climate Jobs members are labor advocates and union leaders, of many years standing. As an organization, our concerns are broadly related to advocating for and engaging working people in a rapid and sustainable transition towards a more climate-supportive economy with good jobs – which includes jobs that do not put one’s health at risk. We recognize that serious adaptations in the workplace, including those required to protect worker health and safety, will be necessary to continue specific types of work as the climate continues to warm and wildfires spread.
Many of Oregon’s essential workers - roofers, landscapers, farmworkers, construction workers, public sector workers who maintain our parks, monitor the health of our streams, and test our auto emissions – are already experiencing health challenges due to the impact of climate change in Oregon.
Workers should be protected from having to trade their health and lives for a job. In this respect, we fully agree with the principles that led to the creation of federal and state OSHAs. We acknowledge the incredibly challenging work of OSHA staff in moving Oregon towards strong protections for workers exposed to excessive heat and wildfire smoke.
We appreciate your close attention to the experiences workers shared during listening sessions and hearings. We believe that OSHA has responded to a number of science-based arguments presented by the PCUN/OEC-led Rulemaking Advisory Group, of which we are a member.
There is so much promise in these rules - promise to preserve the health of Oregon’s workers and to save lives as our state’s climate becomes hotter and wildfires continue. However, we also believe that there are some critical areas that need strengthening to ensure that workers are truly protected against known dangers of high heat and wildfire smoke. We understand that OSHA has to balance the interests of various stakeholders, however, OSHA’s core mission is “To advance and improve workplace safety and health for all workers in Oregon.” Oregon workers depend on OSHA to fulfill this mission.
This is particularly important to Oregon’s most vulnerable workers who are disproportionately represented among those who will suffer from future excessive heat and wildfire smoke.
The Oregon Health Authority’s January 2021 report to the governor, related to its Climate Emergency mandate, stated, “Sadly, agricultural workers, fishers, forestry workers and hunters account for 20% of heat-related deaths in the United States. Farmworkers, the vast majority of whom in Oregon are Latinx immigrants, are particularly vulnerable due to social factors such as racism, language barriers, and lack of adequate housing. In urban areas, people who work and reside in urban heat islands (i.e., construction workers) are also more at risk of climate-related health hazards.” This reality creates a special role for OSHA in protecting the most vulnerable workers in Oregon.
Comments on the Smoke Rules
Strong wildfire smoke rules are critical due to the serious acute and chronic health effects workers face without such protection. Wildfire smoke particulates, small enough to be absorbed from the lungs into the bloodstream, are associated with respiratory and heart disease. Recent research has shown that the particulates can pass from the bloodstream into the brain, potentially causing neurodegenerative diseases such as Alzheimer’s disease. https://www.sciencedaily.com/releases/2021/12/211206220009.htm
A 2019 study of firefighters across the United States found that long-term exposure to particulate matter in wildfire smoke significantly increased the risk of dying from lung cancer and cardiovascular disease. In addition, volatile chemicals that are known carcinogens have been identified in wildfire smoke. https://pubmed.ncbi.nlm.nih.gov/30981117/
These real and serious health risks do not occur in a single fire season; they build up from repeated exposure. Oregon’s wildfire smoke rules must protect workers against the health dangers of repeated exposure, as well as against the dangers of single incident exposure.
We recommend the following changes to the OSHA Smoke Rules:
1) Revise the AQI triggers downward for mandatory respirator use and fit tests. The triggers in the proposed rule are not based on published public health guidance or peer reviewed scientific research. The trigger level for mandatory respirators in the proposed rule is AQI 251, an air quality level that is unmoored from the health risk levels established by EPA and the scientists who created the AQI
scale. AQI 251 is neither the start nor the end of any of the recognized AQI risk levels; it is a random point already halfway into the “very unhealthy for all” risk level. If Oregon rules are going to use the widely recognized and trackable AQI scale, which they should, then they must also respect the health risk levels that form its basis. The trigger for mandatory respirator use should be set at the point where the air quality is “very unhealthy for all” – at AQI 201.
The trigger for respirator fit tests in the proposed rule is AQI 501 which is literally off the AQI chart, a full 200 points above what the EPA’s AQI scale declares to be “hazardous” air quality. The AQI risk levels are set by EPA and based on sound, peer reviewed science. At AQI 301, EPA recommends that all individuals avoid all physical activity outdoors. As many workers will continue to work at AQI 301 and above, use of fit-tested respirators should begin at that level.
N95 or equivalent respirators are, at best, 95 percent effective and certainly less effective if a worker has facial hair or the mask is not the best fit possible for a given worker. Therefore, workers will still breathe in unknown amounts of particulates. Fit testing will assure that exposures to dangerous particulates and some of the co-pollutants are greatly reduced.
We have heard employers argue that they would prefer higher trigger levels for mandatory respirator requirements or that wearing of respirators be only on a voluntary basis. Employers argue that workers don’t want to wear respirators and employers don’t want to force workers to wear them. The arguments we have heard from employers are based on employer convenience, not on worker safety and health. OSHA’s job, as noted above, is to ensure safe and healthful working conditions. Therefore, we urge OSHA to lower the respirator mandate AQI triggers to levels supported by occupational health and safety research (AQI 201 for mandatory respirator use and AQI 301 for fit-tested respirators). And, we further urge OSHA to address employer concerns by emphasizing, through training materials and direct contact with workers and employers, the importance of creating a workplace culture of health and safety.
2) Include requirements for a Smoke Illness Prevention Plan and Emergency Medical Plan. The goal of a Smoke Illness Prevention Plan is to be prepared to respond to observed or reported health concerns before a health emergency occurs. This type of plan (as in the proposed heat rules) should include measures to mitigate smoke-related health symptoms (i.e., fatigue; difficulty breathing) to ensure that employees can obtain relief before a full-blown medical emergency. An Emergency Medical Plan must also be in place, ready to be immediately implemented, in cases where preventive measures have come too late or trained medical intervention is required. An emergency medical plan (also in the proposed
heat rules) would include response steps were a worker to show or report serious health by symptoms (i.e., asthma attack; severe chest pain). As the word Emergency indicates, time is of the essence in these situations and having an emergency plan in place can mean the difference between recovery and loss of health or life.
3) Require best available technology respirators as improved respirator technology develops and becomes available. Over time, more effective/comfortable respirators that are appropriate to different types of work in high AQI conditions may be developed. It is reasonable that OSHA be able to change respirator requirements as improvements are made without rule change.
4) Require that smoke exposure assessments are conducted in enclosed buildings, structures and enclosed vehicles, including negative air spaces, and describe how those assessments will be conducted; clarify that AQI 101 or lower must be maintained in those spaces. A workplace can have an HVAC system that does not achieve the result of offering workers clean air. OSHA should require that employers monitor the AQI levels in indoor environments with portable measuring devices at regular intervals. Workers must be able to request that an employer re-check air quality as conditions
change. If an HVAC system does not achieve the thresholds in the rule, employers must initiate administrative or engineering controls and comply with the rest of the rule for non-exempt worksites.
Strengthening the final smoke rule by setting lower triggers for the respirator mandate and the fit test, providing a Smoke Illness Prevention Plan and Emergency Medical Plan, providing OSHA with flexibility on respirator requirements, and providing further protection to workers in enclosed spaces would be in the interest of both employers and workers. Employers do not benefit when workers are injured on the job whether it is a fall due to fatigue from working in smoke or a severe asthma attack brought on by a combination of heat stress and smoke inhalation from a non-fit tested respirator. No employer wants a worker to end up in the ER or, worse, to lose their life due to an acute episode or later chronic disease caused by multiple exposures to wildfire smoke.
Comments on the Heat Rules
Work in excessive heat poses both health and safety risks to workers. The health risks, as with exposure to smoke, may be both acute and chronic.
The deleterious effects of heat on workers are well documented. They include acute health effects such as heat exhaustion, heat stroke and injuries caused by physical fatigue and confusion and chronic health effects including cardiovascular diseases, mental health problems, and chronic kidney disease. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4202759/
According to CDC data, farm workers are 20 times more likely to die from heat-related causes than other workers. Studies have found that heat stress poses a substantial risk to construction workers who are especially vulnerable as the majority (e.g., 73% in the U.S.) engage in heavy work outdoors. Studies have shown that construction workers in the U.S. are 13 times more likely to die from a heat-related illness compared to workers in other industries, and within the industry, roofers and road construction workers face a particularly high risk of heat-related illness. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5858316/
We recommend the following changes to the OSHA Heat Rules:
1) The partial exemption for “light” work should be removed. This category is ill-defined in the rules, open to wide and highly subjective interpretation, and likely will expose countless workers to dangerous
heat conditions with no relief. Consider someone working in full sun: standing, walking, bending and stooping. This could describe the job of many who work in construction - flaggers, laborers using light hand tools, or landscapers in public parks. If this work is done in an 88-degree heat index and direct sun, which NIOSH scientists have determined adds 13 degrees to calculate heat load, the worker would experience an effective temperature of 101 degrees. It is wrong and dangerous that these workers not have required access to shade and cool water, nor be trained to identify warning signs of heat
illness. Because sun exposure is not taken into account and further because many people move from light to moderate to heavy work in one shift, we strongly urge OSHA to remove this partial exemption for work described as “light.”
2) Eliminate work/rest schedule Option A. Option A virtually cancels the protections that a work/rest schedule provides. After hearing workers’ stories about how heat made their pace of work intolerable and unsustainable, we were relieved that OSHA added provisions for a work/rest schedule that would allow workers to recuperate, lowering the heat load on their bodies, in the shade so that they could continue on with work much more safely. Option A fails
to indicate how the variables of PPE, clothing, and intensity of work should be measured or how the work/rest schedule should be adjusted once measured. Option A fails to require consideration of the well-documented danger and need for adjustment related to sun exposure.
Here’s a real-life scenario that is unfortunately likely to become much more common, showing that Option A will not be protective and can easily put workers' health and safety in danger. Imagine a farm or construction worker doing work of moderate intensity in a 95-degree heat index in full sun. That sun exposure, according to NIOSH-validated research, means that the worker is experiencing an added heat load of 13 degrees, bringing their effective heat load to 108 degrees. According to the minimal requirements of Option A, the required rest is 10 minutes every two hours. It is easy to see that employers might well double the break to ten minutes per hour if the work is moderate and there is no PPE or special clothing worn. Such a plan, totally allowable under Option A, would expose that worker to a dangerous heat load. Based on scientific research, NIOSH has concluded that for light work at a heat load of 108 degrees, workers should work 35 minutes and rest 25 minutes in a 60 minute period. Option A does not come close to this protective recommendation. It will not protect countless workers, especially as a heat index of 95 degrees will become more common in Oregon. We believe that OSHA is in the position to set the proper standards for the work/rest schedule, not the employer, and urge the removal of Option A.
3) Change the required break time for the first tier of Option C to ten minutes every hour. Option C seems to afford good protection in tiers two, three and four; however, there is a critical problem with the first tier - from a heat index of 90F to a heat index of 94F. This tier’s minimal requirement suffers from the same problem as Option A. The heat load on workers due to exposure to direct sun is not counted, nor is intensity of work. Therefore, a farmworker, construction worker, or warehouse worker in a heat index of 90 degrees F in full sun (heat load to worker of 103) doing moderate or even intense work will only get a break of ten minutes every two hours. This is very serious because it is already common to work in a heat index of 90F to 94F. The heat index is roughly 90 degrees F in the Willamette Valley when the air temp is 87 degrees. We strongly urge OSHA to change the required break time for the first tier of Option C to ten minutes every hour.
Climate Jobs strongly believes that the exemption for light work should be removed. Option A of the work/rest schedule should be removed. Option B of the work/rest schedule should be retained and
Option C, Oregon OSHA’s simplified work/rest schedule should be retained with the change to the first tier discussed above.
Conclusion
In conclusion, we again want to express our gratitude to OSHA staff for their efforts during this long rulemaking process. So much progress has been made towards putting in place the most protective rules possible for Oregon workers. As we all know, Oregon’s rules will be the model as other states and our federal government face the critical need to protect workers more fully. We support rules that will make the promise of OSHA’s mission a reality by protecting workers to the fullest extent possible as they continue to do the work Oregonians benefit from in an increasingly perilous climate. We urge OSHA to maintain the strong worker-protective measures in the proposed rules but to also seriously consider our recommendations and move forward with stronger rules in place.
Thank you,
Leslie Kochan, Nikki Mandell and Laurie King, Climate Jobs