Association Opposes Cal/OSHA Indoor Heat Stress Regulation

The Association joined several other agricultural organizations in submitting written comments opposing CalOSHA’s proposed “Heat Illness Prevention in Indoor Places of Employment” standard.  Last year, the legislature in its infinite wisdom decided it was necessary for California to not only be the only state with an outdoor heat illness regulation, they passed legislation to mandate the Cal/OSHA adopt an “indoor heat illness” regulation.  Accordingly, Cal/OSHA has now drafted and released a proposed standard entitled Heat Illness Prevention in Indoor Places of Employment.  If enacted, the proposed standard would require employers to conduct the following:

  • Establish, implement and maintain an effective heat illness prevention plan for “indoor heat illness”
  • Measure the wet bulb globe temperature (WBGT)
  • Identify each individual employee’s work activity levels and clothing adjustment factors
  • Conduct heat stress hazard assessment of all facilities
  • Provide access to potable drinking water
  • Provide for preventative cool-down rest periods of no less than 5 minutes
  • Establish effective first-aid and emergency response procedures for responding to possible heat illness
  • Provide engineering controls to reduce employee exposures to reduce heat stress including but not limited to: isolation of hot processes or work areas, shielding of radiant heat sources, insulating hot objects, and local exhaust ventilation
  • Provide administrative controls including but not limit to: reduced activity levels, work-rest schedules and cooled rest areas
  • Remind employees throughout the work shift to drink plenty of water
  • Conduct pre-shift meetings to review high heat procedures
  • Make personal protective equipment, such as water-cooled garments, air-cooled garments, ice-packet vests, wetted over-garments and heat-reflective clothing available to employees exposed to high heat sources
  • Keep records of heat stress hazard assessments and trainings

The Association has reviewed the proposed standard and attended the recent workshop held in Oakland on the proposed standard.  Based upon that review we have serious concerns with the proposed regulations and the impact they could have on agricultural operations, including tree nut farms, hullers and processors.  We feel strongly that the proposed standard is not warranted or justified in the agricultural industry, is overly cumbersome and too complicated and costly to implement.

EPA Denies Activist Petition Aimed to Ban Chlorpyrifos

The Environmental Protection Agency (EPA) Administrator Scott Pruitt signed an order denying the activist petition that sought to ban chlorpyrifos (Lorsban). This long fought battle starting in October 2015 was begun with pressure from Natural Resources Defense Council (NRDC) and the Pesticide Action Network North America (PANNA) to submit a petition proposing to revoke all U.S. food tolerances of chlorpyrifos, in essence regulating it out of use. As one of the most widely used pesticides across the world, California Cotton Ginners and Growers Association (CCGGA) and other representatives of the agricultural industry defended the product and grower practices relentlessly in an effort to keep the product available. The largest issues being the main argument in the petition was centered on a study that lacked availability of raw data, duplication or further review. CCGGA and others recently submitted comments citing issues with this data, today’s news shows they listened. EPA’s denial of the petition is based off of the foundation in which EPA was created on, relying on sound-science and a transparent process. EPA will now direct its efforts to updating and revising its human health assessment for chlorpyrifos under the standard procedures of the ongoing registration review process, scheduled for completion on October 1, 2022. This is great news for producers and shows the EPA’s redirection towards supporting a scientific process!

High VOC Restrictions to Continue in SJV Through 2017

The Department of Pesticide Regulations released their Annual Volatile Organic Compounds (VOC) Emissions Inventory Report. Pursuant to the State Implementation Plan goals the San Joaquin Valley, one of five ozone nonattainment areas (NAAs) in California, was to have VOC emissions no greater that 18.1 tons/day. This is the equivalent to a 12 percent reduction from 1990. In 2013 the San Joaquin Valley NAA exceeded this benchmark triggering additional restrictions on non-fumigant pesticides identified as high-VOC. While emissions went down in 2015, the regulations require that the high-VOC restrictions remain in effect from May-October 2017. However, the exemption for use on high-VOC Chlorpyrifos (Lorsban) for use on late season aphid remains in effect.

Water Announcement Tempers Enthusiasm on California Cotton Acreage Increase

The good news is that cotton acreage looks like it will increase for the 2nd year in a row.  Record rainfall and snowpack, coupled with stable cotton prices and falling prices from other commodities are leading to an increase in cotton acreage.  However, that increase is being tempered by a disappointing, less than expected water allotment from the Central Valley Project (CVP) of only 65%, and the potential flooding in the Tulare lake bottom in Kings County.

As of today, all indicators of water supply are above normal.  Way above.  Currently, the statewide snowpack is at 164% of average, while statewide rainfall is over 200% of average to date, with Blue Canyon in the northern Sierras at 245% and Mariposa in the central Sierras at 211% of average to date.   Reservoirs are all higher than average with Shasta at 87%, Oroville at 74%, New Melones at 77%, Don Pedro at 88%, and most importantly San Luis is at 98%.  Flood releases are occurring at many of these dams including Shasta, Oroville, Folsom, and Millerton.

Yet, with all of these positive factors, farmers relying upon the CVP water are only going to receive 65% of their allotment.  While industry is thankful for the water, it is inconceivable that the number isn’t closer to 80% or more.  Unfortunately, this will have a direct impact on the cotton plantings for this coming year.

According to preliminary planting intentions survey conducted by the California Cotton Ginners and Growers Association this past month, the Association is currently estimating approximately 186,000 acres of pima and 70,000 acres of upland statewide for the 2017 cotton season.   This survey is based on surveys from all of the gins in California prior to planting and a lot can happen between now and when things are actually planted.  If it plays out, it will represent a 22% increase in pima acreage and a 6% increase in upland acreage in California as compared to 2016.

Successful Sticky Cotton Summit at Fresno State

The California cotton industry gathered at Fresno State to participate in the 2017 Sticky Cotton Summit hosted by California Cotton Ginners and Growers Association (CCGGA). Dean of the Jordan College of Agricultural Sciences and Technology Dr. Sandra Witte welcomed the group to Fresno State campus and thanked the attendees for the ongoing support that the agriculture industry has shown for the Jordan College. Attendees of the summit had the opportunity to meet Dr. Margaret Ellis of Fresno State. Dr. Ellis is the recipient of a CCGGA research grant surrounding Fusarium in cotton and fungicide efficacy, she is the first professor at Fresno State to receive a grant from the Association.

Jordan College Dean Dr. Sandra Witte welcoming Sticky Cotton Summit attendees.

As the program for the Sticky Cotton Summit got underway panels from the mill, merchant, ginner, grower, PCA and UCCE offered their perspective on how sticky cotton impacts their respective segments of the industry. In addition, USDA-ARS researcher Chris Delhom demonstrated the diverse testing methodologies that are present throughout the country, in part creating an issue of developing uniform testing standards for the industry to adopt. The conclusion of the summit resulted in an open group discussion that led to action items for the industry and CCGGA to pursue. The items included looking into a uniform gin level penalty for sticky cotton delivered, conducting outreach, education and retraining on thresholds and best management practices for growers, seeking additional research dollars to invest in sticky cotton testing measures as well as increasing awareness in order to have more open communication surrounding the issue. CCGGA was directed to develop an industry subcommittee to ensure the progress of the action items outlined from the day’s discussion. We will be sure to provide updates and progress as these items are pursued.

Following the summit Fresno State’s Ag One Foundation welcomed members and staff of CCGGA to tour Fresno State’s 1,000-acre farm, the Fresno State Gibson Farm Market as well as a tour of the new Jordan Agricultural Research Center. The tour showcased the diversity of the agricultural operations students have access to use as well as the vision for the agricultural centered research to be conducted on campus for years to come.

Air District Puts Everything on the Table to Address PM2.5

Succumbing to the pressure of having to attain an impossible air quality standard with very little assistance from the California Air Resources Board (CARB) or Federal EPA, the San Joaquin Valley Air Pollution Control District unveiled a long list of far reaching control measures to reduce PM2.5.  Those measures up for discussion include:


  • Replace all almond harvesters in Valley with latest low-emitting harvester technologies
  • Install PM control technology on larger under-fired charbroilers installed within last 10-15 years (360 out of 1,800)
  • Enhance CMPs for ag operations to reduce directly emitted PM
  • Replace 23,628 older high emitting residential wood-burning devices with cleaner devices
  • Electrify 1,053 ag pump engines in areas impacting peak PM2.5 sites where access to electricity is available
  • Lower NOx limit for container glass plants
  • Lower NOx emissions from various boiler, steam generator, process heaters > 5 MMBtu/hr
  • Lower NOx emissions from various boiler, steam generator, process heaters 2 to 5 MMBtu/hr
  • Install ultra-low NOx flare technology and require additional flare minimization practices
  • Lower NOx emissions from various non-agricultural engine categories
  • Replace 74,912 heavy heavy-duty trucks with upcoming 0.02 g/bhp-hr ultra-low NOx trucks that are 90% cleaner than 2010 trucks recently required by ARB’s Truck and Bus Regulation
  • Replace 110,000 medium heavy-duty trucks with upcoming 0.02 g/bhphr ultra-low NOx trucks that are 90% cleaner than 2010 trucks recently required by ARB’s Truck and Bus Regulation
  • Replace 102,936 light heavy-duty trucks with upcoming 0.02 g/bhp-hr ultra-low NOx trucks that are 90% cleaner than 2010 trucks recently required by ARB’s Truck and Bus Regulation
  • Install 2,622 natural gas fueling stations for deployment of 0.02 g/bhp-hr ultra-low NOx heavy duty trucks
  • Replace 320,000 passenger vehicles with zero-emission vehicles
  • Replace 76 locomotives with new Tier 4 locomotives


The price tag for all of these measures, which the District says need to be done by 2019?  More than $51 billion!  The District staff laid this out today to the Governing Board stating their back is up against the wall, but realizes the above listed measures are too costly and impractical to achieve without incentive monies.  Unfortunately, the District will face federal sanctions unless they can get into attainment of the PM2.5 standard by 2019.  CCGGA President/CEO Roger Isom testified before the Governing Board on the issue stating that the almond harvesting and CMP modifications have not yet been proven to reduce PM2.5 emissions and further research is needed.  Isom also expressed concerns with rising electricity prices that may dissuade farmers from switching from diesel to electric, and encouraged the District to help on that particular issue.  Later in the same meeting, the District brought up but did not adopt such “draconian measures” as “no farm days”, “no construction days” and “no drive days” where Interstate 5 and Highway 99 would be shut down.  Again, the District was trying to state the seriousness of the issue while placing boundaries on what can and cannot be done.  The District will have to adopt their PM2.5 plan demonstrating attainment by August of this year.

DPR Releases Revised Pesticide Use Near Schools Regulation

The Department of Pesticide Regulation released the revised Pesticide Use Near Schools Regulation today. After several months of reviewing comments, the revised regulation provides little relief to the agricultural industry from these over reaching proposals amended to become effective January 1, 2018.

Below are the most substantial changes to the document:

  • Schoolsite is given a clearer definition, identifying a schoolsite as a property used as a child day care facility (defined by the Health and Safety Code) or kindergarten, elementary or secondary school. The definition includes all areas of property used on weekdays by children who attend such facilities. Commissioners can identify adjacent parks if used for school activities.
    • Schoolsite does not include family day care homes, private schools, vehicles or bus stops not on schoolsite property.
  • The 48-hour notification was eliminated, however annual notification would still be required.
  • Growers who need to use a pesticide that was not included on the annual notification must provide the required information to the school site and commissioner at least 48 hours prior to application

Despite specific requests directly to DPR and through public comments, the regulations failed to identify commodity fumigation exempt from this proposal. The regulation will be open for a 15-day public comment period from March 20th to April 4th. CCGGA, who testified at the Tulare hearing with more than 20 growers, will continue to oppose the proposal.

Written comments relevant to the modifications may be sent via e-mail <>; or may be directed to Ms. Linda Irokawa-Otani, Regulations Coordinator, Department of Pesticide Regulation, 1001 I Street, P.O. Box 4015, Sacramento, California 95812-4015. FAX: (916) 324-1491.

Association Keeps Pressure on Increasing SWRCB Fees

In response to a proposed 27% increase in Irrigated Lands (ILRP) fees and a 7% increase in Waste Discharge (WDR) fees, the Association has been meeting with Assembly and Senate Budget Subcommittee members who will review the State Water Resources Control Board (SWRCB) proposed budgets next week.  Association President/CEO Roger Isom has been walking the halls on the issue highlighting the shift of program cost burden from the General Fund to permit holders such as farms and processors.  In particular, the Association has pointed out the problem with assessing the cost burden of programs such as beach cleanup and monitoring, TMDL and Basin Plan amendments on these two sources.  The Association has also gone to great detail to identify concerns with the sheer cost of the WDR permit as compared to other environmental permits including air pollution permits.  Currently, WDR permits typically cost more than 2 ½ times the air quality permits.  With the looming budget hearings, the Association will remain vigilant in fighting these proposed fee increases.

Hydrauli-flex Scholarship Accepting Applications

In an effort to support the fields such as engineers, machinists and inventors the $1000 scholarship will be exclusive for students finishing their studies in a respective field that utilizes hydraulics. To be eligible for the scholarship students but be in the last year of study for their degree program, be in good academic standing (3.0 GPA or better) and must apply online. The application and additional scholarship requirements can be found at Applications must be turned in no later than June 30, 2017.

Tractor Train-the-Trainer Workshops

In the ongoing effort to increase safety awareness in the agricultural industry, a coalition of agricultural organizations is conducting a specialized “train-the-trainer” workshops with an emphasis on tractor safety.
The training is for Owners, Farmers, Managers, Supervisors and those who are responsible for training on agricultural equipment. Each participant will be provided with the information needed for understanding the rules and regulations on tractor operation and conducting training. Sessions will cover Cal/OSHA regulations, safety aspects and proper operation and maintenance.
This class does not “certify” or authorize the participants to operate a tractor. Official training must be provided by the employer on their specific equipment and documented as such. The training provided is to educate participants on what needs to be covered in their training programs, and how to effectively train their own employees on these same issues.
Cost: $50 per participant
Pay online and Fax form or Fax/Mail registration form and a check payable to:

Western Agricultural Processors Association
1785 N. Fine Avenue, Fresno, California 93727

Office (559) 455-9272
FAX (559) 251-4471
Check out all our locations by clicking the Registration Form below!

Tractor “Train the Trainer” Workshop Registration Form