The California Cotton Ginners and Growers Associations (CCGGA) and the Western Agricultural Processors Association (WAPA) submitted comments calling into question the proposed new requirements by CalOSHA.  The new requirements would require lighting to be provided such that light can be measured at 10 foot-candle light power within a 25 foot radius when working around agricultural equipment.  In attempting to determine the impact of these proposed rules, CCGGA and WAPA took measurements of an almond loading operation, cotton module unloading operation and a cotton bale loading operation, with all of these activities occurring at night.  These measurements clearly demonstrated the inability to comply with the law as proposed, and in the one instance where additional had been provided to help rectify the situation, an air pollution control district violation was also created!  As a result, CCGGA and WAPA have serious concerns with the premise for the proposed revisions, serious concerns with the industry’s ability to meet the proposed requirements for levels of light intensity, and issues with whether or not the standard is necessary based on a couple of the measurements we conducted.  CCGGA and WAPA submitted the comments and the measurements in response to CalOSHA’s request for data supporting the industry’s claims that the proposed regulations are not necessary and impractical to meet.