Keep Your Company Compliant in August: Heat Safety

• _{Not applicable to HUB100 or GHR Hotline Clients}

Topics to Discuss and/or Review

1. Review Heat Illness Standard laws. For clients with access to the Forms Library, references to this section can be found in the folder “Safety and OSHA”.

• • The Occupational Safety and Health Administration (OSHA) has issued a Notice of Proposed Rulemaking (NPRM) targeting heat exposure in workplaces throughout the United States. The proposed standard applies to all employers in general industry, construction, maritime, and agriculture sectors where OSHA has jurisdiction. It covers both indoor and outdoor work environments affected by excessive heat.
  • If implemented in its current form, the Key Requirements under proposed law include:
    • Heat Illness Prevention Plan: Employers must develop and implement a written plan to evaluate and control heat hazards in the workplace.
    • Risk Assessment: Employers are required to assess heat risks and implement measures when heat levels pose a risk to workers.
    • Water, Rest, and Shade: The plan must include provisions for providing drinking water, rest breaks, and access to shade or cool areas.
    • Acclimatization: Employers must have procedures to help new or returning workers acclimatize to high heat conditions.
    • Training: Employers must provide training on heat illness prevention, recognizing symptoms, and first aid.
    • Emergency Procedures: Clear procedures must be in place to respond to heat-related emergencies.
  • OSHA encourages public comments on the proposed rule and plans to hold a public hearing after the comment period.

2. Prepare for compliance with OSHA’s proposed rule:

• • Develop and implement a written Heat Illness Prevention Plan
    • Assess the Risk: Identify the specific heat-related risks in your workplace. Consider factors like outdoor work, high temperatures, and humidity levels.
    • Define Roles and Responsibilities & Assign Responsibilities: Designate specific individuals or teams responsible for implementing and monitoring the heat illness prevention plan.
    • Develop Procedures
      • Water, Rest, and Shade: Ensure that employees have access to cool drinking water, regular rest breaks, and shaded or cool areas.
        • Water and Hydration
          • Provide sufficient cool drinking water close to the work area.
          • Encourage employees to drink water frequently.
        • Rest Breaks and Shade
          • Ensure employees have access to shaded or cool areas for rest breaks.
          • Schedule more frequent breaks during high heat conditions.
      • Emergency Procedures: Establish clear procedures for responding to heat-related emergencies, including recognizing symptoms and providing first aid.
    •  Training
      • Train all employees and supervisors on heat illness prevention.
      • Cover topics such as recognizing symptoms, first aid, and the importance of hydration and rest.
    •  Monitoring
      • Regularly monitor the temperature and heat index in the workplace.
      • Implement additional precautions when temperatures rise, such as increasing the frequency of breaks.
    •  Acclimatization
      • Gradually increase workloads and allow more frequent breaks for new workers or those returning from an absence.
      • Ensure employees are acclimatized to the heat.
    •  Recordkeeping
      • Maintain records of any heat-related illnesses and the measures taken to prevent them.
      • Document training sessions and monitoring activities.
    • Personal Protective Equipment (PPE)
      • Provide appropriate PPE to protect employees from heat exposure.
      • Ensure PPE does not contribute to heat stress.
    •  Communication
      • Establish a system for communicating with employees about heat conditions and prevention measures.
      • Use signs, posters, and meetings to reinforce heat illness prevention.
  • Check State law for specific Heat Illness Standard laws. Several states and localities have specific heat illness prevention requirement (see: https://www.osha.gov/heat-exposure/standards)
    • California enforces the Heat Illness Prevention in Outdoor Places of Employment standard and as of July 24, Cal/OSHA requires measures to protect workers in indoor workplaces where temperatures reach 87°F under the Heat Illness Prevention in Indoor Places of Employment standard. Both standards require employers to take specific actions, including providing water, access to cool-down areas, rest breaks, training and acclimatization when ambient temperatures reach a specified threshold.
    • Colorado's Heat Illness and Injury Protection Rules for Agricultural Employers apply on days when the temperature at an agricultural worksite is, or is forecast to be, at least 80 degrees Fahrenheit (F).
    • Minnesota implements a heat stress standard designed to protect indoor and outdoor workers against the risk of heat-related illnesses by requiring employers to take certain measures, including training workers who may be exposed to hot environments.
    • Oregon's permanent Heat Illness Prevention Rules that apply whenever an employee performs work activities in indoor or outdoor environments where the heat index reaches or exceeds 80 degrees Fahrenheit.
    • Washington has rules regarding outdoor heat exposure protections that apply to all employers with employees performing work in an outdoor environment when they are exposed to outdoor heat.
    • Meanwhile, Florida and Texas have enacted laws prohibiting cities and counties within their borders from adopting their own heat illness prevention measures. This means that only state-level regulations will apply in Florida and Texas, and local governments cannot impose additional requirements on employers regarding heat safety.

Tips

More information in reference to the topics discussed in this month’s compliance calendar can be found in our comprehensive online Forms Library, which is available to members 24/7.