CWS Submits Comment on Virginia Notice of Intended Regulatory Action on Heat Illness

On September 22, the Coalition for Workplace Safety submitted comments to the Virginia Department of Labor and Industry (“DOLI”) regarding the agency’s Notice of Intended Regulatory Action (“NOIRA”) regarding the development of a heat illness prevention standard.

Our comment emphasized that CWS and its members support the core protections already authorized in the Virginia Code — access to water, shade or climate-controlled environments, rest periods, acclimatization protocols, and effective training. “Where CWS differs from some stakeholders is not on whether workers should be protected but on how to design a standard that achieves that protection without imposing requirements disproportionate to the risk in Virginia’s specific conditions.” We call on DOLI to implement a standard that reflects the Commonwealth’s working conditions, not simply to copy other states or federal OSHA’s proposed rulemaking, and we advocate for DOLI to implement a standard that relies on user-friendly temperature monitoring, not complex measurements. CWS plans to continue to engage with the agency as it moves forward with the regulatory process.