The Trainer Checks the Box That Cannot Protect You

What follows is an imagined OSHA Heat Illness Prevention Training transcript from a Central Valley agricultural operation, dated June 2026. The trainer is fictional. The physiology is peer-reviewed, the regulations are cited from statute, and the 72-hour window she describes kills real people every summer.

—Eds.

HEAT ILLNESS PREVENTION TRAINING — EMPLOYER RECORD Date: June 3, 2026 Location: [REDACTED] Vineyards, Madera County, CA Trainer: Guadalupe Ochoa-Fenn, MS, PhD Exercise Physiology Trainees: 14 new seasonal employees (first day) Temperature at training start: 84°F / 6:15 AM Projected high: 109°F

Trainer Name and Qualifications

Lupe: Guadalupe Ochoa-Fenn. PhD exercise physiology, UC Davis. Former research associate, Western Center for Agricultural Health and Safety. Currently contracted acclimatization trainer, third season with this operation. Certified in occupational heat stress assessment.

You don't need this next part for the form. My tía picked grapes for twenty-two years, forty minutes from where we're standing. She's retired now. Bad knees, not heat. She got lucky, which is not a thing you should have to say about someone who worked that hard for that long. Anyway. That's why I'm in this field at six in the morning instead of writing grant applications nobody reads.

Describe the Environmental and Personal Risk Factors for Heat Illness, as Required Under Cal. Code Regs. Tit. 8, § 3395

Lupe: Environmental risk factors: air temperature, humidity, radiant heat from direct sunlight, air movement. Personal risk factors: age, weight, fitness, medical conditions, medications, alcohol use, prior heat illness, and acclimatization status.

That last one is the one that matters today.

You are all unacclimatized. I need you to understand what that word means in your actual body, not on this form.

Right now, your blood plasma volume is baseline. Your sweat rate is roughly half a liter per hour.¹ By the end of two weeks, if we do this correctly, your body will produce more than two liters per hour.² Your heart rate at the same workload will drop. Your core temperature will rise more slowly. Your sweat will carry less salt. Your blood volume will expand ten to twelve percent, which means your heart won't have to choose between sending blood to your muscles and sending it to your skin to cool you.³

That's the body you'll have in two weeks. Today you have a different body. Today your body is running last winter's operating system in June.

Fifty to seventy percent of outdoor heat fatalities happen in the first few days.⁴ Cal/OSHA's own data: almost half on day one. Eighty percent within the first four days.⁵

You are in the kill zone. I say that every year and every year I wish I had a softer word and every year I don't use one.

Describe Employer Procedures for Acclimatization of New Employees

Lupe: ☑ The employer provides a graduated exposure schedule.

OK. I checked the box. Let me tell you what the box means and what it doesn't.

The science says you should work twenty percent of a normal shift today. That's one hour and forty minutes. Tomorrow, forty percent. Day three, sixty. Day four, eighty. Full schedule by day five.⁶ This is called the Rule of 20 Percent. It is boring. It is the single most evidence-based intervention we have for keeping you alive this week. I love boring interventions.

California requires that you be closely monitored for your first fourteen days.⁷ This operation follows that. I will be watching you. Your crew lead will be watching you. We use a buddy system. You do not work alone. If your buddy looks wrong, you say something. If your buddy says they're fine and they look wrong, you say something louder.

Here is what the form does not say.

Last August, the federal government proposed a national heat standard that would have required this protocol for thirty-six million workers.⁸ It mandated that if your employer sent you home after your twenty-percent exposure on day one, they still had to pay you for the full day.⁹ Think about that for a second. Paying workers to not die. That provision would have made it economically irrational to skip acclimatization.

That rule was killed in 2025.¹⁰ What replaced it is this form. Voluntary compliance. Fifty-three heat citations issued nationally in nearly two years.¹¹ There is now a bill in the Senate to permanently prohibit a federal heat standard from ever being finalized.¹²

You are in California. You are, relatively speaking, lucky. This state's heat protections reduced deaths by thirty-one percent.¹³ One state east of here, in Arizona, the same sun hits the same body and there is no law requiring shade, water, rest, monitoring, acclimatization, or this conversation. The physiology doesn't change at the state line. The protection does.

I am checking the box because the box exists in California. The box does not exist for the majority of agricultural workers in this country.

Sorry. Strike that. Or don't. The transcriptionist can decide. I've stopped caring about the transcriptionist.

Confirm: Water, Shade, and Rest Break Procedures Were Explained ☐

Lupe: ☑ Yes. Water: cool, fresh, accessible, enough for each of you to drink a quart per hour.¹⁴ Not soda. Not energy drinks. Water. I know. I'm very fun at parties.

Shade: available at eighty degrees and above, which — checks thermometer — was nineteen minutes ago. At ninety-five degrees, which we will hit by eleven, you get a mandatory ten-minute cool-down rest every two hours.¹⁵

I need you to actually take them.

Eighty-six percent of farmworkers in one study had received heat training. Forty-two percent could answer a basic question about acclimatization correctly afterward.¹⁶

I am the forty-two percent problem. My job is to say these words. My job is also to make sure these words get into your body and not just onto this form. Those are two completely different jobs and this form only tracks one of them. I have a PhD and I have not solved the other one. Three summers and counting.

Describe Emergency Response Procedures

Lupe: If someone stops sweating, that's wrong. If someone is confused, stumbling, slurring words — heat damages cognition before it damages organs¹⁷ — you do not wait. You do not think maybe they're tired. You call me. You call 911. You move them to shade, you pour water on them, you do not put them in a car and drive to a parking lot.

I say that because of a specific girl.

California's heat standard already existed. It had been law for three years. The law was in a binder somewhere. It was not in that vineyard.

So when I say call 911, I am not reading from the binder. I am telling you what happens when someone doesn't.

Training Delivered in Language Understood by Majority of Employees ☐

Lupe: ☑ English and Spanish. Two workers indicated Mixtec as primary language; bilingual crew member translated key points.

The form asks if the language was understood. It does not ask if the situation was understood. One in four farmworkers in California don't know they have the right to file a safety complaint.¹⁹ Forty-three percent have at least one chronic condition that increases heat risk.²⁰ Some of you are on piece rate, which means every minute you spend in shade costs you money, which means the protocol that keeps you alive also keeps you poor.²¹

That's not a problem I can solve with a training transcript. But I want you to know that I know it's there. That when I tell you to rest and you look at me like I'm the one who doesn't understand, I know exactly what you understand that I'm asking you to ignore.

Trainer Certification

I, Guadalupe Ochoa-Fenn, certify that the above training was delivered in accordance with Cal/OSHA Title 8, Section 3395, and that all employees were informed of the risk factors, symptoms, and procedures related to heat illness prevention.

I further certify that this form is accurate, complete, and insufficient.

Signed: ________________________ Date: June 3, 2026

☑ Training Completed ☐ Workers Protected

Footnotes

1. ScienceDirect, "Heat Acclimatization — an overview," https://www.sciencedirect.com/topics/medicine-and-dentistry/heat-acclimatization ↩

2. Ibid. ↩

3. Physiopedia, "Heat Acclimation," https://www.physio-pedia.com/Heat_Acclimation ↩

4. OSHA, "Heat — Overview," https://www.osha.gov/heat-exposure ↩

5. Western Center for Agricultural Health and Safety / UC Davis, "Acclimatization: Getting Used to Working in the Heat," https://agcenter.ucdavis.edu/news/acclimatization-getting-used-working-heat ↩

6. OSHA, "Heat — Protecting New Workers," https://www.osha.gov/heat-exposure/protecting-new-workers ↩

7. Cal. Code Regs. Tit. 8, § 3395, via Cornell LII, https://www.law.cornell.edu/regulations/california/8-CCR-3395 ↩

8. OSHA, "Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings Rulemaking," https://www.osha.gov/heat-exposure/rulemaking ↩

9. Lindabury, McCormick, "Heat Stress: OSHA's Proposed New Rule," https://www.lindabury.com/firm/insights/heat-stress-oshas-proposed-new-rule-and-what-it-means-for-employers.html ↩

10. Jacobin, "Workers Don't Have to Die in the Heat," May 2026, https://jacobin.com/2026/05/working-conditions-heat-deaths-protections ↩

11. Ogletree Deakins, "OSHA's Proposed Heat Illness Prevention Standard," https://ogletree.com/insights-resources/blog-posts/oshas-proposed-heat-illness-prevention-standard-is-at-the-white-house-for-review-whats-next/ ↩

12. GovInfo, "Heat Workforce Standards Act of 2026" (S. 4427, 119th Congress) ↩

13. Jacobin, May 2026. ↩

14. 99calor.org (California DIR), "Heat Illness Prevention," https://www.99calor.org/english.html ↩

15. California DIR, Title 8, Section 3395, https://www.dir.ca.gov/title8/3395.html ↩

16. Western Center for Agricultural Health and Safety / UC Davis. ↩

17. Deshayes et al., "Shifting focus," Experimental Physiology, 2024, https://physoc.onlinelibrary.wiley.com/doi/full/10.1113/EP091207 ↩

18. Jacobin, May 2026; Groundwork Collaborative, "Extreme Heat is Killing America's Workers," https://groundworkcollaborative.org/work/extreme-heat-is-killing-americas-workers/ ↩

19. CapRadio, "As temperatures rise, is California doing enough to keep its farmworkers safe?" March 30, 2026, https://www.capradio.org/articles/2026/03/30/as-temperatures-rise-is-california-doing-enough-to-keep-its-farmworkers-safe/ ↩

20. Ibid. ↩

21. PMC/NIH, "How Does Environmental Temperature Affect Farmworkers' Work Rates?" https://pmc.ncbi.nlm.nih.gov/articles/PMC10332655/ ↩