Sleeping Within Six Feet: Challenging Oregon’s Labor Housing COVID-19 Guidelines Emma K. Accorsi a , Julie Samples b , Linda A. McCauley c , and Nargess Shadbeh b a Harvard T. H. Chan School of Public Health, Boston, Massachusetts, USA; b Oregon Law Center, Portland, Oregon, USA; c Emory University Nell Hodgson Woodruff School of Nursing, Atlanta, Georgia, USA ABSTRACT Facing the onset of the COVID-19 pandemic and increasing outbreaks among farmworkers and food processing workers across the nation, the Oregon Occupational Health and Safety Administration (OR OSHA) issued temporary regulations, in contrast to optional recommenda- tions, in late spring. These regulations aimed to reduce the risk of COVID-19 transmission among farmworkers, but made compromises that may fail to reduce the risk of further outbreaks among Oregon’s agricultural workers, particularly those living in agricultural labor housing. Instead of considering the scientific literature that called for attention to space and length of time for social distancing among unrelated persons in indoor areas, the agency accepted the 6-foot social distancing rule of thumb and allowed even shorter distances between beds with the installation of plastic or plywood barriers. The 6-foot distance (or less with a barrier) between people sleeping next to each other in poorly ventilated housing has proved disastrous. Additionally, testing for migrant and seasonal farmworkers is neither uniform nor thorough, and little data have been collected to assess the success of existing testing efforts. New regulations must be adopted for farm labor housing that limit occupancy to at most two unrelated individuals for a room of 200 square feet; include expanded specification on the provision of fresh air in shared living spaces; and support increased access to testing, surveillance testing, and alternative safe housing at labor housing sites for identified cases. KEYWORDS Farmworkers; COVID-19; Oregon; labor housing Oregon farmers rely heavily on migrant and sea- sonal farmworkers from the Pacific seaboard to harvest their prized blueberries, cherries, and pears from late May into October. For nearly a century, employer-provided labor housing has been Oregon’s go-to solution for migrant and sea- sonal farmworkers. Oregon’s Occupational Health and Safety Administration (OR OSHA) regulates the housing and working conditions of farmwor- kers in Oregon. Oregon’s approximately 330 labor housing sites can house up to 10,000 farmworkers and their families during each season. As a state plan state, 1 OR OSHA has its own regulations for field sanitation 2 and labor housing, 3 but key provi- sions that have become the focus of concern for advocates during this pandemic, such as the num- ber of toilets and sinks, square footage for occu- pants, and ventilation, are not much different from the federal regulations. 4,5 In March 2020, with the onset of COVID-19 in Oregon, farmworker advocates familiar with the minimally protective labor housing and field sani- tation protections for farmworkers urged OR OSHA to issue temporary regulations in the areas of labor housing, transportation, and field sanitation. They also urged the Oregon Health Authority (OHA) to work with employers, clinics, and public health officials to protect workers and offer testing and treatment. OR OSHA immedi- ately rejected this request, but allowed public comments. More than a month later, after an explosion of COVID-19 cases in agricultural set- tings across the nation from New York to Washington, 6,7 OR OSHA issued temporary reg- ulations with an effective date of June 1, 2020. 8 Oregon identified 16 million USD to assist growers in adapting to the temporary regulations. 9 This included 5 million USD allo- cated for the rental of portable toilets and sinks for the field, as the new regulations require one toilet and handwashing facility for every 10 work- ers (1:10) in the field, instead of the federal 4 and CONTACT Nargess Shadbeh nshadbeh@oregonlawcenter.org Oregon Law Center, Portland, OR, USA JOURNAL OF AGROMEDICINE 2020, VOL. 25, NO. 4, 413–416 https://doi.org/10.1080/1059924X.2020.1815622 © 2020 Informa UK Limited, trading as Taylor & Francis Group