My name is Dr. Marion Moses and I am pleased to have the opportunity to testify before the North Carolina Department of Labor at the request of the Farm Workers Legal Services regarding field sanitation standards for agricultural workers.

I am currently in the department of epidemiology at the Johns Hopkins University School of Hygiene and Public Health and am licensed to practice medicine in Maryland, New York and California. I graduated from Temple University School of Medicine, trained in Internal Medicine at the University of Colorado and completed a residency in Occupational Medicine at Mount Sinai in New York City I am certified in Occupational Medicine by the American Board of Preventive Medicine Prior to attending medical school I was a registered nurse and graduated from Georgetown University School of Nursing I received a Masters in Nursing Education from Columbia University Teachers College.

My interest and concern for the health and other problems of migrant and seasonal agricultural workers began 18 years ago in 1964 when I first became aware of the failure of these workers to be protected by laws applicable to other workers. At this time I was living in California and my knowledge of and experience with agricultural workers is in that state, primarily in the San Joaquin Valley.

From 1966 to 1971 I worked full time with the United Farm Workers of America in Delano, California as a nurse practitioner. From 1969 to 1971 I was administrator of their health program. My duties included direct out-patient and Preventive health care, as well as organization and supervision of health facilities in other areas of the state. I also helped set up the Robert F. Kennedy Farmworkers Health Benefit Plan. I have had experience monitoring health and safety regulations in regard to sanitation as well as safe handling of pesticides.

I would now like to discuss my position on the proposed regulation.

The scientific reasons why drinking water should be provided in any occupational setting are especially cogent in agriculture where extremes of temperature, humidity, physical effort, as well as exposure to toxic chemicals are a part of the work environment. Metabolic heat is produced by the body even at rest and increases with physical exertion. When ambient temperature is high the water loss from the body from sweating, by which the body cools itself, can be substantial High humidity can further increase body temperature since it reduces sweating.

It can thus be seen that there are several conditions which may predispose the agricultural worker to heat related illness. The most serious of these is heat stroke, which can be fatal. Heat cramps and heat exhaustion can also occur which are less serious. The long term effects of heat stress, if any, are not known and this is a developing area of epidemiological research What is known is that a heat stroke death is a preventable death What prevents it is an ample and available supply of drinking water Depending on the temperature, humidity. Physical effort, age of the person and other factors, as much as 2 gallons may be required over an eight hour period But one should not have to justify providing water to the workers on the basis of avoiding death from heat stroke Agricultural labor is physically demanding, very hard work done under environmental conditions as described. Water deprivation under these conditions might be producing effects on the renal, cardiovascular, or other body systems that are cumulative or delayed Long term effects are not known and physiological stresses placed on workers by depriving them of water may put them more at risk for other disease, even though there are no apparent detrimental effects at the time.

The public health reasons why handwashing facilities and toilets should be provided in any occupational setting are also especially cogent in agriculture, whose work force is often more susceptible to infectious and parasitic disease due to conditions of poverty and migrancy. Poor sanitation and disease have been known to be associated for over one hundred years. Civilized societies. in fact, have flourished most healthily where humans have most successfully separated themselves from their excretions. A large variety of infectious and parasitic diseases are known to be transmitted by the fecal-oral route, including hepatitis and typhoid among many others Demanding proof that Provision of sanitary facilities will decrease disease incidence is neither necessary nor ethical There have been several classic studies that have done so and it is not cost-effective to reinvent the wheel in this regard A deaf ear should be turned to special pleading against such a basic, successful, and universal public health practice We should ask why agricultural workers are held to a higher standard than other workers The bank teller, schoolteacher and construction worker do not have to make a case that they will cause widespread disease in their place of work if a toilet and handwashing facilities are not provided Why should the agricultural worker have to?

I remember when I first began working with agricultural workers in California, we used to say that there would be plumbing on the moon before the fields of the San Joaquin Valley I was watching the Columbia space shuttle launch while I was Preparing this testimony and it occurred to me that that had to be the world's most expensive Portable toilet. And under the regulations being proposed here today a toilet wouldn't even be required since there were only 2 workers at the site.

I believe that other considerations supercede both the scientific and public health reasons that drinking water handwashing facilities and toilets should be provided for agricultural workers. These considerations are social and ethical, or if you will, "moral" In other words it should be done because it is the right and decent thing to do, because it the fair and just thing to do Denying workers the proper means to fulfill basic physiological needs can be seen as a violation of a social contract human beings make with each other in regard to exchange of labor for hire. No worker should be required to sacrifice his or her human dignity as part of the bargain.