As written, these rules put family farms at risk by creating unworkable compliance costs and shrinking available workforce housing. OFB continues to advocate for policies that protect worker safety while ensuring that Oregon’s farms and ranches can remain viable.
Please read our full, 10 pages of public comments here:
Key Highlights:
Crushing Financial Burden on Farms
OR-OSHA assumes farmers can build new housing or relocate structures to meet the stricter housing capacity reductions, but the reality is different.
The $5 million in state grant funding falls far short of covering the compliance costs, which could exceed $1 million per farm.
Oregon’s farmers already face higher labor costs (70% above the national average) and low net cash income (67% below the national average in 2022), making these mandates unsustainable.
Drastic Reduction in Workforce Housing
Increasing required sleeping space per occupant could cut available housing by 20-50%, while plumbing upgrades would force additional housing capacity reductions.
Seasonal farmworkers, especially in regions with limited housing like Hood River and Southern Oregon, will face fewer options—leading to potential labor shortages during critical harvest seasons.
Unrealistic Implementation Timelines
Some rules are set to take effect as early as January 1, 2025, midway through existing H-2A contracts, creating legal and operational chaos.
Structural changes that require permits, contractors, and financing need at least a 10-year phase-in period, similar to past ALH amendments.
Overreaching and Unnecessary Provisions
OR-OSHA proposes requiring water pressure above Oregon’s building code standards, new electrical outlets instead of power strips, and higher toilet-to-worker ratios, all without scientific justification.
The agency also wants farmers to act as health officials, imposing unclear disease reporting requirements that could violate privacy laws.
Regulations That Harm Rural Families & Youth Programs
The proposed 500-foot setback for housing near livestock threatens small farms and youth programs like 4-H and FFA, making it impossible for families to raise animals while offering worker housing.
This rule also conflicts with Oregon land-use laws, adding another layer of legal uncertainty.
OFB urges OR-OSHA to:
Align ALH rules with federal OSHA and ETA standards to reduce regulatory overreach.
Provide a realistic phase-in period (10+ years) to allow farms to finance and implement structural changes gradually.
Recognize legacy housing built before 1980, as the federal government does, rather than forcing costly retrofits.
Eliminate provisions unrelated to worker health and safety, such as arbitrary sink, storage, and water pressure mandates.
Fair labor housing is a crucial issue, but the conversation shouldn't stop at living conditions. Many workers also struggle with stress and emotional hardships, making mental health and addiction support just as important. Providing resources for both physical and mental well-being can lead to a stronger, more resilient workforce.
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