Dear Mr. Withrow:

Thank you for the opportunity to comment on the Notice of Intended Regulatory Action for the Heat Illness Prevention Standard. The Delmarva Chicken Association (DCA) is the 1,600-member trade association representing the chicken growers, companies and allied businesses in Delaware, the Eastern Shore of Maryland and the Eastern Shore of Virginia. In particular, we have two chicken company members in Accomack county that employ thousands of Virginia residents and contract with more than 60 growers.

DCA is very interested in the process as raising and harvesting chickens is a 24-7 job, no matter the weather. The chicken community is committed to protecting our employees from any harsh working conditions and already has a number of best management practices in place. We have concerns of any Virginia-specific regulations that might conflict with any guidance from OSHA, creating a patchwork of state standards. All employers already have the responsibility of the general duty clause that is in place to provide employees with a safe workplace.

DCA does not fully understand the need for the time and resources that will be used to adopt additional regulations, but we look forward to following the work of the Regulatory Advisory Panel as this process moves forward.