OSHA HEAT RELATED ILLNESS REQUIREMENTS AND RESOURCES

OSHA recently issued a National Emphasis Program – Outdoor and Indoor Heat-Related Hazards which indicates their interest in regulating this area. The  OSHA website: Heat - Overview: Working in Outdoor and Indoor Heat Environments | Occupational Safety and Health Administrationprovides updated guidance on how to prevent and protect workers from heat-related hazards and to comply with the NEP. 

The website contains guidance on multiple topics that should be considered by employers. Some key items include:

Heat Illness Prevention Plan

An effective heat-related illness prevention program as part of a broader safety and health program and aligns with OSHA's Recommended Practices for Safety and Health Programs core elements. The heat-related illness prevention program should establish how the employer will determine if workers are exposed to a heat hazard based on environmental conditions (e.g., weather, or indoor temperature and humidity), clothing, and workload. The heat-related illness prevention program also includes policies to implement environmental controls, plan work schedules, and use personal protective equipment (PPE). Following the OSHA hierarchy of controls suggests engineering controls, followed by work practices and administrative controls, then PPE are the most effective ways to prevent heat-related illness and fatality.

The following are some engineering controls that may reduce heat stress:

When engineering controls are not enough to keep worker exposures to heat below hazardous levels, administrative controls are another way to prevent a worker's core body temperature from rising. Some administrative controls that may reduce heat stress include:

When engineering and administrative controls are not enough, PPE is a way to provide supplemental protection. PPE that can reduce heat stress include:

An effective heat-related illness prevention program should include a worker acclimatization program, heat alert program, and medical monitoring program. It should also establish a training program that includes recognition of heat-related illness symptoms and what to do in a heat-related illness emergency. 

Acclimatization Program

To reduce the impact that heat stress will have on the core body temperature, employers should use a structured program to help workers adapt to working in the heat. An effective heat acclimatization program increases the time each day, over a 7-to-14-day period that an un-acclimatized worker is exposed to heat stress while the worker conducts normal work activities. Also, acclimatized workers who are not exposed to heat stress for a week or more may need some time to re-acclimatize ― typically two or three days.

Medical Monitoring Program

More robust heat-related illness prevention programs establish a medical monitoring program to consider workers' individual needs for ensuring that their core body temperature does not reach unsafe levels and for early identification of signs that they are experiencing heat-related illness. This program should include pre-placement and periodic medical evaluations, as well as a plan for monitoring worker health (e.g., core temperature, hydration, pulse, and/or blood pressure) on the job. NIOSH. 2016, Criteria for a Recommended Standard: Occupational Exposure to Heat and Hot Environments has more information about what to evaluate and monitor to prevent heat-related illness.

Training Program

Specific heat-illness prevention training is important to ensure that supervisors and workers are prepared to work safely in hot environments. Training should include information about recognizing heat-related illness symptoms; proper hydration; heat-protective clothing and equipment care and use; other factors that affect heat tolerance (e.g., medications, alcohol, obesity, etc.); and how to acclimatize, report symptoms, work in pairs, and how to give appropriate first aid. Additionally, supervisors should also receive appropriate training on how to monitor weather reports and weather advisories, as well as how to use adjusted temperatures (e.g., WBGT and heat index) to make decisions about protective measures.

An effective training program includes support from a safety and health professional with experience and/or training in heat stress and illness. First-line supervisor awareness and training are critical to ensuring that a heat-related illness prevention program is effectively implemented.

Heat Index use as an Adjusted Temperature

The heat index is a screening tool that uses temperature and relative humidity to calculate an adjusted temperature, representing how the conditions feel more accurately than just the ambient temperature. Since the WBGT uses four factors for calculating an adjusted temperature, it is even more accurate when determining if there is a heat hazard present. ACGIH, U.S. Armed Forces and athletic associations use WBGT for calculating an adjusted temperature in their guidance and policies.

For more information on the heat index, see the National Weather Service website.

OSHA/NIOSH Heat Safety App provides location-specific and real-time calculations of the heat index along with actions to be taken, first aid tips, risk factors, and other tools. It is a terrific tool.

Heat Alert Program

Effective heat alert programs (HAPs) are developed and implemented whenever a heat wave is likely to occur. The National Weather Service defines a heat wave as a period of abnormally and uncomfortably hot and unusually humid weather typically lasting two or more days. More specifically for workplaces, a heat wave is described by NIOSH as when the daily maximum temperature exceeds 35°C (95°F) or when the daily maximum temperature exceeds 32°C (90°F) and is 5°C (9°F) or more above the maximum reached on the preceding days.

Day-to-Day Supervision

An individual at the worksite should be responsible for monitoring conditions and implementing the employer's heat plan throughout the workday. This individual can be a foreman, jobsite supervisor, plant manager, safety director, or anyone else with the proper training. Proper training includes knowing how to:

The individual who is responsible for the heat plan should be on-site, where the workers are. On-site monitoring allows accurate determination of heat stress.

Heat-Related Illnesses / Signs & Symptoms / First Aid

The supervisor responsible and employees should be trained in the types of heat related illnesses, their symptoms.

First aid personnel and equipment must be available under the General and Industry Standards, however, first aid for heat-related illnesses generally includes:

The OSHA Heat website also includes a Heat Stress calculator, case studies, personal risk factors and more.

Additional Resources: 

1. OSHA-NIOSH Info Sheet: Protecting Workers from Heat Illness, www.osha.gov/sites/default/files/publications/osha-niosh-heat-illness-infosheet.pdf. 

2.CDC Workplace Safety and Health Topics:HeatStress,www.cdc.gov/niosh/topics/heatstress.

3.NIOSH Criteria Document: Criteria for a Recommended Standard: Occupational Exposure to Heat and Hot Environments, February2016,www.cdc.gov/niosh/docs/2016-106/.

4.American Conference of Governmental Industrial Hygienists (ACGIH®) Action Limit (AL)for un-acclimatized workers and a Threshold Limit Value (TLV®)  for acclimatized workers, see Heat Stress and Strain: TLV® PhysicalAgents2026or latest edition. See ACGIH®website at https://www.acgih.org/.

5.NOAA/NWS Heat Safetywebpage,www.weather.gov/safety/heat.

6.Federal Register, 89 FR 70698, 29 CFR § 1910, 1915, 1917, 1918, 1926, and 1928, Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings; Advance Notice of proposed rulemaking (ANPRM), OSHA, August 30, 2024. 

7.Title 8 §3396 Indoor Places of Employment 

8.OSHA Memorandum, Procedures for Local and Regional Emphasis Programs, December 3, 2014. 

9.OSHA Publication 3905, Whistleblower: Recommended Practices for Anti-Retaliation Program, 2017. 

10.OSHA Webpage, Heat Illness Prevention Campaign.