Thank you for the opportunity to comment on this proposed regulation. Our association represents (1) turfgrass professionals who are responsible for sports fields, golf courses, sod farms, commercial and home lawns and (2) landscapers who are responsible for trees, shrubs, annuals, perennials and non-plant aspects of the outdoor environment.  Our membership also includes university and municipal personnel from across the Commonwealth.

We deeply appreciate the concern expressed by legislators, associations, and individuals regarding the dangers of heat stress. We do not seek to minimize their concerns. The health and safety of all persons involved with the turfgrass and landscape industry is our prime concern.

Our issue with the proposed regulation is the adoption of a state heat illness standard apart from the adoption of such a standard by OSHA. That being said, when the Regulatory Advisory Panel is created, we ask that a representative from the Virginia Agribusiness Council be appointed to represent the turf and landscape industries.