OSHA to focus on indoor and outdoor heat hazards

On April 8, 2022, OSHA launched a National Emphasis Program (NEP) on indoor and outdoor heat-related hazards. The NEP is effective for three years. State Plans are encouraged, but not required, to adopt this instruction. Each region is expected to double their annual heat inspections compared to 2017 through 2021.

The NEP targets high-hazard industries or activities, such as working outdoors in an area experiencing a heat wave as announced by the National Weather Service (NWS), or working indoors near radiant heat sources such as steel mills and foundries. Affected employers listed in Appendix A of the NEP (CPL 03-00-024) and include a variety of construction employers, manufacturers, and wholesalers as well as nursing care facilities, hotels, car dealerships, and restaurants.

The Bureau of Labor Statistics (BLS) reports that heat exposure causes an annual average of 35 fatalities and 2,700 cases with days away from work. However, OSHA believes that fatalities may be underreported since the cause of death is often listed as a heart attack when exposure to a heat-related hazard may have been a factor.

Inspection guidance

OSHA’s compliance safety and health officers (CSHOs) will open or refer a heat-related inspection for any hazardous heat conditions observed, cases recorded in OSHA 300 logs, or if an employee describes heat-related hazards like exposure to high temperature conditions without adequate training, acclimatization or access to water, rest, and shade.

Additionally, CSHOs are expected to ask about heat-related hazard prevention programs on “heat priority days” when the heat index is expected to be 80°F or more.

During heat-related inspections, CSHOs will:

• Review OSHA 300 Logs for any heat-related illnesses;
• Review any records of heat-related emergency room visits and/or ambulance transport, even if hospitalizations did not occur;
• Interview workers for symptoms of headache, dizziness, fainting, dehydration, or other conditions that may indicate heat-related illnesses;
• Determine if the employer has a program addressing heat exposure; and
• Identify activities relevant to heat-related hazards such as working in direct sunlight or near a heat source, wearing heavy or bulky clothing or equipment including PPE, and estimate workload exertions and duration of exposures.

Programmed inspections will occur on any day that the NWS has announced a heat warning or advisory for the local area. On those days, the establishments listed in Appendix A will be used for programmed inspections.