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Cal/OSHA Takeaways From 2020: Top Citations & Resources for Employers

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HeavyConnect Team
Fieldworkers harvest broccoli

Last week AgSafe held their annual Innovate Regulatory Compliance Conference with webinars hosted by officials throughout the industry. Douglas Parker, Chief of Cal/OSHA Division of Occupational Safety and Health, spoke about trends in worker safety from 2020. We attended with employers’ needs in mind. These are some of our main takeaways from the session:

Top Two Employer Citations

Between October 2019 and September 2020, the top violation was missing Injury and Illness Prevention Programs. The second most common citation was failing to provide employees with written programs for Heat Illness Prevention (HIP). Employers are encouraged to focus on these two areas and put standards in place in advance of the hottest months of the year. Tools like mobile apps for documenting worker training can help employers move away from a paper training matrix and provide their employees with easy access to a written HIP program.

COVID-19 Emergency Temporary Standards

The COVID-19 Emergency Temporary Standards were released on November 30, 2020 to impose more stringent rules about health screenings, training, and safety requirements. After the rules came out, Cal/OSHA held advisory committee meetings to receive comments from the public. They are currently considering granting more flexibility around housing and transportation requirements. However, those amendments have not yet been released.

Based on recent labor audits, the most common COVID-19 violations are:

  • Missing face coverings, particularly soon after the new rules were released.
  • Not allocating enough physical distance, especially during processing and sorting.
  • Not providing sufficient hand washing facilities.

Although the CDC has advised that vaccinated workers do not need to be quarantined if they are exposed to COVID-19, Cal/OSHA is waiting for guidance from the California Department of Public Health. They have not yet taken new CDC instructions on vaccinations into account, but that may change. 

Nighttime Illumination

On July 1, 2020, a new Nighttime Illumination in Agriculture Rule went into effect. It requires workers to wear class 2 high-visibility garments and employers to provide additional lighting. As the practice of night working grows due to more extreme heat, employers will need to implement these new rules.

Managing Wildfire Concerns

Outdoor workers will keep facing challenges related to wildfire smoke. Parker encouraged employers to keep the “Hierarchy of Controls'' approach in mind. This involves starting with the most ideal, broad strategies and works down to more specific controls. 

  1. Elimination: Physically remove the hazard
  2. Substitution: Replace the hazard
  3. Engineering Controls: Isolate people from the hazard
  4. Administrative controls: Change the way people work
  5. PPE: Protect the worker with Personal Protective Equipment

Parker acknowledged that not all these strategies will be options for employers and that Cal/OSHA will continue providing resources on wildfire smoke protection.

Heat Illness Prevention

The last 7 years have been the hottest on record in California. During Cal/OSHA’s inspections, they only see 60% compliance with Heat Illness Prevention rules. The most common citations are issued for a lack of drinking water or shade provided to workers. Spanish language resources on this topic can be found at

Additional Resources for Employers

California employers have to comply with many different regulations that change often. We understand that it can be complicated and overwhelming to stay on top of all these areas of compliance, avoid citations, and ultimately keep workers safe. If you are an employer interested in learning about how digital tools like field training software can help you comply with labor regulations, give us a call at (833) 722-5727 or email

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