On July 2, 2024, the Occupational Safety and Health Administration (OSHA) released a draft version of its proposed rule to protect workers from the significant health effects of extreme heat. Per OSHA, when the Heat Injury and Illness Prevention Standard (29 CFR 1910.148) is finalized, it will help protect approximately 36 million employees in indoor and outdoor settings and substantially reduce workplace heat injuries, illnesses, and deaths.
According to OSHA, every year dozens of workers die, and thousands more suffer illnesses related to hazardous heat exposure that are most often preventable. Record-breaking high temperatures across the United States have increased the risk of heat-related workplace exposure, especially during the summer months.
The proposed regulation sets OSHA heat triggers at a specified National Weather Service heat index, or at a wet bulb globe temperature equal to the National Institute for Occupational Safety and Health (NIOSH) recommended heat stress exposure limit. The initial heat trigger is set at a heat index of 80°F or at a wet bulb globe temperature equal to the NIOSH Recommended Alert Limit (RAL). The high heat trigger is set at a heat index of 90°F or a wet bulb globe temperature equal to the NIOSH Recommended Exposure Limit (REL).
Requirements of the proposed rule include:
- Developing a written Heat Injury and Illness Prevention Plan (HIIPP) to address the types of work activities covered by the plan, all policies and procedures implemented to comply with the standard, and emergency procedures that must be followed when an employee experiences signs and symptoms of a heat-related illness. Employers would also be required to designate a heat safety coordinator to implement and monitor the HIIPP.
- Providing training to all employees covered by the HIPP that includes risk factors for heat stress, how to recognize signs and symptoms of heat-related illness and which require immediate action, and the importance of staying hydrated and taking rest breaks.
- In outdoor work areas, accurately determining employees’ exposure to heat by monitoring the temperature frequently. In indoor work areas, identifying areas where the heat index could reach 80°F or higher and including a temperature monitoring plan as part of the written HIIPP.
- Implementing employer-required heat injury prevention measures, for example, requiring employers to provide readily accessible drinking water and suitable break areas. Employers must also allow and encourage employees to take paid rest breaks as needed to prevent overheating.
- Putting additional provisions in place that would apply when conditions result in temperatures at or above the high heat trigger including paid fifteen-minute breaks at least every two hours and a buddy system to monitor coworkers for signs of heat illness or employee observation by a supervisor or heat safety coordinator.
Although the proposed regulation applies to all employers, it would not apply to work activities for which there is no reasonable expectation of exposure at, or above, the initial heat trigger or to short-duration employee exposures at or above the initial heat trigger of 15 minutes or less in any 60-minute period. In addition, it would not apply to work activities performed in areas or inside vehicles where air conditioning consistently keeps the ambient temperature below 80°F. Sedentary work activities in indoor work areas that involve sitting, occasional standing and walking for brief periods, and infrequent lifting of objects weighing less than 10 pounds would also be exempt.
OSHA encourages the public to participate in the rulemaking process by submitting comments when the proposed standard is officially published in the Federal Register. Instructions on how to provide input on the draft version of the proposed rule can be found on OSHA’s Rulemaking Process website.
For additional information on OSHA’s proposed Heat Injury and Illness Prevention Regulation or for assistance determining if the rule will affect your organization, please contact us.
This blog was written by Beth Graham, Director of Quality, Research, and Training
