Record heat is in the news again which may spur a new round of petitions for OSHA to execute an emergency temporary standard (EST) for a heat stress threshold, followed by a permanent Heat Stress Standard. Petitions for both were denied last summer. Many citizens and watch-dog groups felt that OSHA was simply opting for continued employer self-policing. However, even though there is an absence of a Heat Stress Standard, OSHA can hold employers accountable through enforcement outlined in the General Duty Clause, Section 5(a)(1).
There were at least 4 petitions filed last year, which has gotten OSHA’s attention to the concern. With such increased public and special interest group pressure for a standard, OSHA has instituted an increased focus on heat as a hazard during its General Duty Clause inspections. Section III: Chapter 4 of the OSHA Technical Manual for enforcement officers is dedicated to heat stress investigations. The 20 point questionnaire looks for heat-related incidents, acclimation programs, work-rest cycles, availability of water and shade, and training and education. Simply telling employees to take breaks and drink plenty of water as necessary will not meet OSHA expectations and could result in a citation.
If employees are subjected to conditions that could induce heat stress, a successful heat stress program should be in place and include such components as:
▪ Training. Educate on the hazards of heat stress and ways to avoid it. Recognition of danger signs or symptoms as well as First aid procedures.
▪ Personal Protective Clothing/Equipment. Wear light summer clothing that allows free movement and promotes sweat evaporation. Wear clothing that deflects heat. Are cooling vest available?
▪ Administrative/Engineering. Assess and monitor all jobs with strategies for hot days. Reduce physical demands and schedule hot jobs for cooler part of the day. Permit rest breaks and water breaks. Provide air conditioned or shaded areas for breaks. Exhaust hot air and steam.
▪ Health and Acclimatization. Educate employees on how certain prescription drugs (diuretics, anti-hypertension, anti-cholinergic) as well as alcohol abuse can increase susceptibility. Introduce working in hot conditions gradually over several days.
OSHA expects more than water, rest and shade. They would like scheduled work/rest cycles with climate controlled areas for cool down. Additionally they are emphasizing implementation of an acclimatization program for new workers or workers returning from extended absence as well as utilization of temporary employees. They are also looking to see what prompt remedial action an employer took after an employee suffered heat stress.
Risk factors are many including employee physical condition, temperature, humidity, clothing worn, work pace, task assigned, sun exposure and air movement. Training on signs and symptoms along with First Aid is essential. Heat stress may cause confusion resulting in an employee refusing First Aid. Specific procedures for heat-related emergencies need to be implemented.
Although OSHA has opted not to implement a heat-hazard standard at this time, there are still plenty of teeth in their bite regarding employee heat-related illnesses in the workplace. In their letter to deny the petition to Public Citizen’s Health Research Group, OSHA also cited enforcement through over a dozen different standards related to Recordkeeping, Sanitation (potable water), Medical Services and First Aid, Safety Training & Education as well as PPE.
As public pressure continues on this subject, OSHA’s Regional Administrators are directing the Field Inspectors to expedite heat-related inspections and to issue citations. If you would like to evaluate your current program and prepare your workforce for possible heat hazards to avoid employee illness and costly citations contact us now.