By: Shaina Oliver, Colorado Organizer, Moms Clean Air Force and EcoMadres
Date: July 2, 2025
About: OSHA Proposed Heat Rule, Docket #OSHA-2021-0009
To: Occupational Safety and Health Administration (OSHA)
Thank you for taking the time to hear my comments. My name is Shaina Oliver, Field Organizer with Moms Clean Air Force-EcoMadres' Colorado chapter. Over 43,079 Colorado parents and caregivers are united for our children’s right to play, learn, and live in a safe environment.
I first want to acknowledge the ancestral lands of over 574 Tribal Nations of what is now known as the United States. I work and reside on the ancestral lands of 48 Tribal Nations of Colorado. Importantly, I’m a mom of four and wife and we are descendants of the “Indian Removal Act” known as “The Long Walk of the Navajo” living and working in Denver, Colorado.
As a working mother with loved ones and family members, our communities are socioeconomically vulnerable and are most likely to work the farms, construction sites, utility sites, and as first responders. And according to The Association of Farmworker Opportunity Programs, it’s estimated that there are up to 500,000 child farmworkers in the U.S., with some starting work as young as age 10. I know family members who work agriculture jobs in Colorado and they’re not the best jobs to have. These work sites do little to provide appropriate cooling spaces and cool water accessibility. I also have a father who’s an electrician who’s expected to work through all weather conditions and has worked at many construction and oil and gas sites. Each year Colorado along with other states continues to break record heat indexes, and poor air quality continues to increase along with the heat. According to the American Lung Association’s most recent State of the Air Report, Colorado communities Denver, Greeley, and Aurora continue to rank as the 6th worst area for ozone-smog pollution, which is made worse by extreme heat and is detrimental to outdoor workers, child workers, and pregnant workers who are especially vulnerable.
Moms Clean Air Force recognizes that farm workers are at high risk of heat-related stress: they are up to 35 times more likely to die from heat-related stress than the general population. 80% of farm workers identify as Hispanic and one analysis found that construction workers are 13 times more likely to die than workers in other industries. A 2020 study of child farm workers in North Carolina found that 48% had experienced a heat-related illness within the previous 12 months. As moms we know extreme heat has adverse impacts on maternal health, which has been linked to preterm birth, low birthweight, pregnancy loss, and heat-related stress in newborn babies. According to the Bureau of Labor Statistics, exposure to environmental heat resulted in 479 US worker deaths between 2011-2022 with an average of 40 fatalities per year during that time period.
Colorado parents strongly support OSHA’s Heat Injury & Illness Protection Plan proposal. This is a critical step towards protecting outdoor and indoor workers faced with extreme weather and heat stressors. Moms Clean Air Force calls on OSHA to finalize the strongest possible version of this standard as quickly as possible with the inclusion of additional protection for workers during heat waves and poor air quality days.