OSHA’s First Step Towards A Federal Heat Standard

Federal standards mean universal protection and prevention for vulnerable workers in hot conditions. 

To maintain a proper work environment that meets heat-illness prevention standards, there must be adequate cooling.

OSHA, the Occupational Safety and Health Administration, is addressing heat-related illnesses and injuries occurring on worksites across the nation.

Whether outdoors or indoors, all employers must ensure workers have proper conditions during extreme heat.

In order to address concerns about worker conditions in the heat, OSHA announced in October last year that it would increase monitoring and investigations of heat-related injuries, illnesses, and deaths. 

With this announcement came the Advanced Notice of Proposed Rulemaking (ANPRM)  for Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings.

This notice was the first step towards establishing a federal heat standard.

In the process of establishing federal and government-authorized standards, administrations must solicit public comments and data to inform recommendations on how to address specific issues.

In the case of heat-related illness, OSHA invited employers and the public to comment and offer expertise and data on heat thresholds, heat-related workplace issues, heat acclimation planning, and exposure monitoring.

After collecting information for three months, OSHA began its review to establish regulations to protect workers from excessive heat exposure. 

Despite the lack of federal regulations and guidelines, certain states have been developing their own requirements for protecting workers from excessive heat.

States including California, Minnesota, Oregon, and Washington have all developed provisions regulating the following particulars:

• Type of workplace
• Temperature thresholds
• Employee protections

Employee protection, in their terms, focuses on methods such as hydration, shade, monitoring, training, and other actions employers can take.

Backtracking to the ANPRM, this standard is set to be specific to heat-related injury and illness prevention.

This standard will provide the federally required employer obligations and the measures necessary to more effectively protect employees from hazardous heat.

The ultimate goal of the standard is to prevent and reduce occupational injuries, illnesses, and fatalities caused by exposure to hazardous heat.

The publication of the ANPRM allowed OSHA to focus on issues such as the scope of a standard, heat stress thresholds across industries, heat exposure monitoring methods, and heat acclimation planning.

The issues include the nature, types, and effectiveness of controls that may be required to become a part of a standard.  

Other information that falls under OSHA’s specific topics includes vital factors such as race and gender pay disparity in “Inequalities in exposures and outcomes among workers of color and low-wage earners,” and climate change in “Impacts of climate change on hazardous heat exposure for outdoor and indoor settings.” 

The current scope of the proposed OSHA federal rule is the solicitation of information to large and small employers with a multitude of work arrangements across the U.S.

The rule’s scope even has a regional focus on the Southern states of Mississippi, Arkansas, South Carolina, West Virginia, and Nevada.

The rule also cites a number of strategies for employers to reduce occupational heat-related injuries and illnesses, including:

• Heat injury and illness prevention programs
• Engineering controls, administrative controls, and utilizing personal protective equipment (PPE);
• Acclimatization (the process of the human body becoming accustomed to new environmental conditions by gradually adapting to the conditions over time)
• Monitoring the physiological, medical, and exposure of workers
• Planning and responding to heat-illness emergencies and
• Worker training and engagement

Climate change and the socioeconomic impact on exposure to hazardous heat are also major parts of the proposed OSHA federal rule.

Climate change is estimated to result in the loss of 2 billion labor hours and $160 billion in lost wages due to extreme temperatures alone.

The proposed rule acknowledges this and other inequalities and exposures for workers exposed to hazardous heat.

The rule also addresses the concerns of cities that exhibit disparities in those affected by heat-related illness, including pregnant workers and people of color.

Studies show that heat is the number one cause of weather-related events in the workplace.

Heat received this ranking as it can exacerbate existing health conditions such as heart problems, kidney failure, and asthma.

Excessive heat also affects the workplace, leading to reduced production and worker errors due to dehydration and heat-related impairment.

Studies have indicated that worker productivity declines 4% for every degree above 80℉.

Excessive workplace heat exposure is also linked to:

• Reduced work hours
• Higher employee turnover
• Increased medical leave
• Additional employer costs from hiring & training new employees

The Atlantic Council's Adrienne Arsht-Rockefeller Foundation Resilience Center estimates the annual economic loss from heat to be more than $100 billion.

Large impacts such as this are likely to double by 2030 and quintuple by 2040 based on projections of continued heat intensification from climate change. 

Studies also show that hydration alone, being one of the treatments for excessive heat, does not reduce core body temperature.

Proper hydration and constant monitoring of climate control are needed to maintain full mental functioning, which declines with prolonged heat exposure.

Facility managers can proactively implement heat mitigation options before OSHA-imposed federal regulations take effect through monitoring. Options for monitoring consist of:

• Implemented centralized climate control
• Using cooling products such as evaporative cooling fans or towers tied into permanent systems
• Establishing cooling stations that incorporate access to hydration in conjunction with portable cooling products

Additional monitoring is conducted through employers' decisions.

An important question to ask is whether owning or renting a cooling solution is better.

The answer to this question depends on need and financial flexibility.

Despite this decision, it is critical for employers to take steps such as investing in cooling solutions to protect workers from heat exposure and related illnesses and injuries. 

Industries can take a step towards heat prevention methods today with Sonicu.

Sonicu technology includes alarms and notifications for thresholds.

Alarms that include threshold ranges, customizable time delays, and specific alarm recipients can be set up within the Sonicu system.

Customization, including the method of receiving alarm notifications and the generation of alarm notification reports, is one of the many intricate features of the Sonicu platform.

To find out more about the alarm and notifications feature, watch this video and schedule a demo today.

Sources: 

“Alarms and Notifications.” YouTube, YouTube, 21 Mar. 2022, www.youtube.com/watch?v=0ck9TceccuM.

Coffman, Jackie, et al. “OSHA Issues ANPRM on Heat Injury and Illness Prevention.” JD Supra, www.jdsupra.com/legalnews/osha-issues-anprm-on-heat-injury-and-8154517/.

Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings Rulemaking | Occupational Safety and Health Administration, www.osha.gov/heat-exposure/rulemaking.

Tenn, Ashlee. “Cooling Solutions Feature: OSHA, Heat Exposure, and Worker Safety.” Facility Executive, 27 June 2022, https://facilityexecutive.com/2022/06/cooling-solutions-feature-osha-heat-exposure-worker-safety/