Last year, California employers began implementing two new major requirements related to worker health and safety: Indoor Heat Illness Prevention and Workplace Violence Prevention. These new mandates required companies to make potentially significant adjustments to their workplace practices and facilities. As if that weren’t enough, Cal/OSHA has an extensive list of rulemaking projects planned for 2025. Here’s an overview of the most significant issues slated for resolution this year.

Ultra-High Heat Standards and Wildfire Smoke
Under AB 2243 (2021), Cal/OSHA must consider adding an “ultra-high heat” provision to its heat illness prevention standard and require employers to distribute their heat illness prevention plans to employees. Additionally, Cal/OSHA is tasked with considering revisions to the wildfire smoke standard to lower the air quality threshold for mandatory respiratory protection from 500 to 301. In exchange, employers may be exempt from requirements like fit testing and medical evaluations when mandating respiratory protection. DOSH states it will post an online discussion early this year and hold an advisory committee. The proposal submission to the board is planned by December.

Walking Working Surfaces
Cal/OSHA is actively working on updates to the Walking Working Surfaces Regulation, which aims to enhance safety standards for workplaces across various industries. Roger Isom, president and CEO of Western Tree Nut Association (WTNA), is playing a key role in this process, participating in the Advisory Committee as the sole representative from the agricultural industry. Cal/OSHA has announced plans to release a revised draft of the regulation shortly after the start of the year. Two advisory committee meetings are set for 2025 in March and October of this year.

First Aid Kit
Efforts to simplify first aid kit requirements, dating back to 2006, are anticipated to progress this year. The revisions aimed to allow kits to meet national standards, such as ANSI, rather than requiring sole approval by a physician. The proposed updates would mandate weekly inspections, clear accessibility with labeled locations and evaluations to add items based on workplace hazards. The board plans to publish this proposal by June for a public hearing. A new proposal is expected to be presented for a public hearing in June 2025.

Autonomous Tractors
One key area under consideration is the regulation of autonomous agricultural equipment. Historically, Cal/OSHA required driverless tractors to have an operator present in the vehicle. Concerns were raised on the safety of using autonomous tractors. However, as of October 2024, the agency has indicated a shift in this stance, expressing openness to regulatory reforms that would allow autonomous vehicles to operate without an onboard operator. The Advisory Committee meeting is anticipated for June 2025.

Permissible Exposure Limit (PEL) Revisions
The board plans a September public hearing on a proposal to significantly lower the permissible exposure limit (PEL) for trichloroethylene, a chemical used in refrigerants and solvents, from 25 ppm to 2.2 ppm. This reduction aims to decrease cancer risk from 106 to 1 per 1,000 workers. Additional PEL changes are anticipated for other chemicals, including cyclohexane, tris/borate/EDTA, n-propanol, trimethylamine (TMA) and ethylene glycol derivatives.

Workplace Violence
Cal/OSHA plans an advisory hearing in 2025 to gather input on a proposed workplace violence prevention standard for general industry, as required by SB 553. The hearing will address key aspects, such as recordkeeping, post-incident response procedures and identifying workplace violence hazards. The goal is to collect feedback from stakeholders on the draft workplace violence prevention standard currently being developed by Cal/OSHA. Currently, workplace violence regulations are based on legislation and largely shaped by interpretations. The new regulatory process will provide an opportunity for stakeholder feedback, allowing folks to contribute to the discussion. Eventually, these regulations will supersede the existing state legislative requirements outlined in statute. Cal/OSHA must submit the proposed workplace violence prevention standard to the Board by Dec. 31, 2025, and the Board must adopt the standard by 2026.

Cal/OSHA is expected to have a packed year, tackling numerous proposed changes and regulatory updates that could impact various industries, including agriculture. The agency shows no signs of slowing down, with several new proposals this year. WTNA is staying engaged, closely monitoring developments and providing input as these issues move through the rulemaking process. WTNA’s involvement ensures the unique challenges and needs of the tree nut industry are considered during the regulatory process.