OSHA considering heat illness prevention rule

The Spring 2021 regulatory agenda notes that OSHA is considering a regulation on heat illness prevention for both indoor and outdoor workers. A request for information is expected in October, and feedback would be used to develop a proposed rule, so a final standard is probably a couple of years away. Currently, OSHA uses the General Duty Clause to address heat hazards.

The agenda points out that workers in agriculture and construction are at highest risk, but indoor workers can be at risk also. OSHA notes that a rule may require addressing complex issues like heat stress thresholds, acclimatization planning, exposure monitoring, and medical monitoring. Several state-plan states (California, Washington, and Minnesota) already have heat illness regulations.

Evaluate the risks

New workers in outdoor jobs are generally at highest risk for heat-related illnesses. Most incidents occur in the first four days on the job, before workers build up a tolerance for working in hot conditions.

The heat index considers both air temperature and humidity and is a better risk measure than air temperature alone. OSHA warns against relying on heat index alone, but notes that it may be helpful as part of a hazard assessment. Additional considerations include:

• Indoor work: Weather reports cannot gauge conditions inside a building.
• Direct sunlight: Temperature and heat index are measured in the shade, but working in the sun may be considerably hotter.
• Reflective material: Water, metal, or other materials can reflect sunlight onto workers.
• Heat sources: Heat generated by fires, hot tar, ovens, or heat-absorbing surfaces such as roads and roof surfaces.
• Wind: Air movement has a cooling effect, but buildings may block the wind.
   

Create a plan

Employers should create a plan to prevent heat-related illness. Elements to consider include:

• What training will be provided to workers and supervisors?
• How will new workers gradually develop heat tolerance?
• What engineering controls and work practices will be used to reduce heat stress?
• Are first aid measures adequate, and who will summon medical assistance if necessary?
• Who will provide daily oversight?

Since heat conditions can change rapidly, someone at the worksite should monitor conditions and adjust the plan throughout the workday. In industries such as delivery services where on-site monitoring isn’t feasible, consider training workers on heat illness and who to contact regarding any heat-related conditions that develop.