The Occupational Safety and Health Administration (OSHA) has proposed a new standard, “Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings.”
This new OSHA Standard would apply to general, construction, maritime and agriculture employers.
Public comments on OSHA’s proposed heat illness standard
You can submit comments on OSHA’s proposed heat illness standard (OSHA-2021-0009) before Dec. 31, 2024. Click the “Docket Documents” tab to read other public comments or submit your own. Rule making agencies like OSHA consider public comments when writing the law. Your comments are visible to everyone, so don’t include personal information about yourself or others.
You can read the complete text of the proposed standard on the Federal Register’s website.
Heat is dangerous
Heat is the leading cause of death among all weather-related events. Without swift treatment, excessive heat can cause heatstroke and even death. Employers are required to protect employees from unsafe work conditions, like excessive heat.
However, OSHA doesn’t have a dedicated heat illness standard. Instead, it cites employers under the General Duty Clause of the Occupational Safety and Health Act. And since there is no standard, issuing a preemptive citation to prevent heat illness is difficult. Citations usually happen after a worker has been hurt. OSHA aims to protect lives, not merely cite employers for wrongdoing. A heat exposure standard would help their efforts.
OSHA’s proposed standard would require employers to create a plan for evaluating and controlling indoor and outdoor heat hazards. It would obligate employers to protect employees from heat hazards, inside and outside. Some OSHA state plans, like California’s Cal/OSHA, already have a heat exposure standard. Federal OSHA will likely follow Cal/OSHA’s lead.
Without a plan, workers risk getting sick from the heat indoors and outdoors. In addition to weather-related heat, heat-generating machinery can threaten indoor workers. Heat-producing machines include:
- Ovens
- Grills
- Furnaces
- Kilns
- Dryers
- Die casting machines
- Steam-powered machines
- Autoclaves
- Distillation apparatuses
- Reactor vessels
- Heat exchangers
- Hot oil systems
- Engines
- Power generators
- Boilers
Excessive heat worsens existing health conditions like asthma, diabetes, kidney failure and heart disease. Pregnant and older workers have a higher risk for heat illness. All workers are at risk during the first few weeks of work while they get used to the environment.
Get ahead of heat illness
If you don’t have a heat illness plan, make one. It’s good for you and your employees. Heat-related illness is preventable. Here are some tips for creating a heat illness prevention program:
- Identify someone to oversee the heat illness prevention program.
- Develop a plan to allow workers to acclimate to the heat. Include new hires, temporary workers and workers returning from absences.
- Create water and shade breaks. Make sure fresh water is always available.
- Be aware of heat indices.
- Revise schedules to avoid outdoor work during the highest heat hours, usually 10 a.m.- 4 p.m.
- Train workers on the stages of heat illness.
- Create a first-aid plan for responding to each stage of heat illness. Rehearse the plan with your workers.
- Isolate heat-generating equipment to limit prolonged exposure to heat sources.
- Ventilate work areas to expel hot air from the environment.
- Use dehumidifiers indoors to reduce the air’s moisture and heat index.
- If working in high heat is unavoidable, use the buddy system. Train workers to look out for one another.
- Instruct workers to wear light-colored, loose-fitting clothing on hot days. If you require uniforms, have different uniforms for different weather.
OSHA has detailed heat exposure information and resources for employers. OSHA can still cite you for exposing workers to high heat. The best way to handle the heat is to have a safety plan and stick to it. By the time OSHA passes the official standard, you’ll be ready.
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For more information about this prosposed standard, please contact our Risk Management team.
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