OSHA Heat Safety Standards Growing More Rigid

Heat safety standards are growing more stringent as OSHA ramps up heat stress regulations.

In accordance with the Occupational Safety and Health Administration's (OSHA) current National Emphasis Program authorization, OSHA will select more than 70 at-risk employers for pre-planned inspections in areas under a heat warning or advisory. 

The emphasis will be placed on high-risk industries, including foundries, warehouses, agriculture, waste collection, and residential construction. 

Besides these industries at the highest risk due to certain environmental conditions, below are other scenarios where OSHA can and likely will inspect for heat stress:

Scenario 1: The facility has a reportable injury, such as an inpatient hospitalization because of an employee's heart attack, and the heat index was above 80 on the day of the incident

Scenario 2: Employee complaint to OSHA about unsafe work conditions related to heat.

Scenario 3: Pre-planned inspection for combined NEPs subject to the industry, such as Forklift, Noise, and Heat

Now, let’s discuss the best practices businesses can use to pass these inspections.

The secret to passing all inspections is knowing what the inspector is looking for. 

With OSHA’s NEP, Certified Safety and Health Officers (CSHOs) review and inspect a number of heat illness-related compliance procedures and documents. 

The best ways to prepare are to have and consider the following documents and questions:

• Supply OSHA 300 Logs and 301 Incident reports (if required by that industry).
• Interview workers for symptoms of headache, dizziness, fainting, dehydration, or other conditions that may indicate heat-related illnesses, including both new employees and any employees who have recently returned to work.
• Determine if the employer has a heat illness and injury program addressing heat exposure, and consider the following:
• Is there a written program?
• How did the employer monitor ambient temperature(s) and levels of work exertion at the worksite?
• Was there unlimited cool water readily accessible to employees?
• Did the employer require additional breaks for hydration?
• Were there scheduled rest breaks?
• Was there access to a shaded area?
• Did the employer provide time for the acclimatization of new and returning workers?
• Was a “buddy” system in place on hot days?
• Were administrative controls used (earlier start times, and employee/job rotation) to limit heat exposures?
• Did the employer provide training on heat illness signs, how to report signs and symptoms, first aid, how to contact emergency personnel, prevention, and the importance of hydration?
• Identify/review activities relevant to heat-related hazards. These can include, but are not limited to:
• Potential sources of heat-related illnesses (e.g., working in direct sunlight, a hot vehicle, or areas with hot air, near a gas engine, furnace, boiler, or steam lines).
• The use of heavy or bulky clothing or equipment, including personal protective equipment.
• Estimate workload exertions by observing the types of job tasks performed by employees and whether those activities can be categorized as moderate, heavy, or very heavy work, considering both average workload and peak workload.
• Duration of exposure during which a worker is continuously or repeatedly performing moderate to strenuous activity (2).”

Following the theme and essentialness of preparedness, companies have the resources and ability to mitigate heat illness before it happens. 

OSHA/NIOSH’s Heat Safety App: An Important Resource for Employers

This app is available on all iOS and Android devices and is an essential tool for heat measurement.

This app is a free, simple heat calculator that provides employers with an index for the user’s specific location and workload guidance that follows occupational safety and health recommendations for hot conditions. 

OSHA also recommends using an on-site wet-bulb globe temperature to measure the impact of environmental heat on body temperature. 

OSHA cites the WBGT meter as an example because it incorporates temperature, humidity, sunlight, and air movement into a single measurement. 

Another essential part of preparedness is training and a proper heat illness prevention plan. Adequate training includes reminders and ongoing safety briefs. 

Reminders can be formed from knowing the symptoms and moving quickly to reduce their effects.

This swift movement is the difference between the employee making it home from a shift and possibly experiencing a medical episode and suffering a serious injury at the job site. 

Proper first aid for heat-related illness is to cool the affected worker. 

Cooling techniques such as ice or cold towels on areas that produce the highest amount of sweat, being the head, neck, trunk, armpits, and groin, and immersing the worker in cold water or an ice bath are the best techniques. 

Combining these techniques with cool air and staying with them until the symptoms subside are proper first-aid principles.  

Another way employers can prepare is by creating and consistently updating a heat-illness prevention plan.

This written plan should include and provide answers to the following questions:

• Who will be on your heat illness prevention team? They will check the heat index, monitor jobsite conditions, implement proper controls, and provide supplies and equipment to workers.
• Who will be responsible for monitoring workers’ health on individual job sites during high heat index days?
• Have you allowed for acclimatization for new and returning employees? (Most injuries happen in the first few days of working in high-heat environments.)
• Do you need to consider providing additional breaks, shade, and water?
• Does each job site provide access to proper personal protective equipment, such as evaporative cooling vests and large fans?
• Do you need to up the frequency of jobsite reminders for sunscreen application and hydration?
• Do your procedures adequately address the need for rapid response to heat illness once it occurs? (2)

Collaborative efforts between supervisors and workers are key to passing inspections. 

Workers and environmental safety should be of the highest priority, as the number of heat-related fatalities is larger than the 35 fatalities and 2,700 injury cases reported by the U.S. Department of Labor’s Bureau of Labor Statistics. 

All employers should be and stay prepared for these inspections through proper research, monitoring, and implementation of safety plans for high-heat conditions. 

Beyond the National Emphasis program, OSHA and the Biden Administration offer additional free resources to ensure safety policies are addressed and properly followed. 

Both high and low-risk industries should take advantage of these resources and work to combat the effects of the climate crisis on the worksite and the planet as a whole. 

References

OSHA Outdoor WBGT Calculator. Heat - OSHA Outdoor WBGT Calculator | Occupational Safety and Health Administration. (n.d.). Retrieved August 18, 2022, from https://www.osha.gov/heat-exposure/wbgt-calculator

What companies need to know about OSHA’s new heat illness rules. Occupational Health & Safety. (2022, June 30). Retrieved August 18, 2022, from https://ohsonline.com/articles/2022/06/30/what-companies-need.aspx

for indoor and outdoor heat hazards: Foley & Lardner LLP. Blogs | Labor | Employment Law Perspectives | Foley & Lardner LLP. Retrieved August 18, 2022, from https://www.foley.com/en/insights/publications/2022/04/the-heat-is-on-osha-natl-emphasis-programhazards#:~:text=The%20Occupational%20Safety%20and%20Health,outdoor%20and%20 indoor%20work%20 environments