OSHA’s recently issued a National Emphasis Program – Outdoor and Indoor Heat-Related Hazards. This NEP outlines how OSHA will manage, inspect for and issue citations related to heat related illness (HRI). The following is a summary of key requirements and targets. A copy of the NEP is available on the NSPCA website.
The goal of this NEP is to reduce or eliminate worker exposures to heat-related hazards that result in illnesses, injuries, and deaths, by targeting industries and worksites, including worksites with radiant heat sources, where employees are exposed to heat-related hazards and have not been provided adequate protection that includes cool water, rest, cool areas, training, and acclimatization.
OSHA is required to investigate HRI during other inspections of OSHA 300/301 forms, “plain view” evidence or other factors are identified. Additionally, OSHA is required to perform programmed inspection on targeted sources and are to be vigilant, during their travels to and from job sites, and stop to conduct compliance assistance or self-referral inspections of outdoor work environments in plain view (e.g., construction worksites, highway and bridge work, lawn care, and maintenance workers, etc.) on any day that the NWS announced a heat warning or advisory for the local area where employees may be performing moderate or more strenuous work or working in direct sunlight (or other radiant heat sources) for extended periods of time.
Targeted Areas are identified in Appendix A. An abbreviated version is provided below:
APPENDIX A
TARGETED GENERAL INDUSTRIES
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2017 NAICS Industry Sector Title
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Petroleum and Coal Products Manufacturing
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Steel Product Manufacturing from Purchased Steel
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Nonferrous Metal (except Aluminum) Production and Processing
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Architectural and Structural Metals Manufacturing
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TARGETED CONSTRUCTION INDUSTRIES
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Residential Building Construction
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Nonresidential Building Construction
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Utility System Construction
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Highway, Street, and Bridge Construction
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Foundation, Structure, and Building Exterior Contractors
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Building Equipment Contractors
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Building Finishing Contractors
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Other Specialty Trade Contractors
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During any heat-related inspections, OSHA will:
a) Review OSHA 300 Logs and 301 Incident Reports for any entries indicating heat-related illness(es),
b) Review any records of heat-related emergency room visits and/or ambulance transport, even if hospitalizations did not occur,
c) Interview workers for symptoms of headache, dizziness, fainting, dehydration, or other conditions that may indicate heat-related illnesses, including both new employees and any employees who have recently returned to work,
d) Identify activities relevant to heat-related hazards. These can include, but are not limited to:
1. Potential sources of heat-related illnesses (e.g., working in direct sunlight, a hot vehicle, or areas with hot air, near generators, dust collectors, etc., inside containment).
2. The use of heavy or bulky clothing or equipment, including personal protective equipment, such as Tyvek or non-breathable suits.
3. Workload exertions, which can be estimated by observing the types of job tasks performed by employees and whether those activities can be categorized as moderate, heavy, or very heavy work, considering both average workload and peak workload; and
4. Duration of exposure during which a worker is continuously or repeatedly performing moderate to strenuous activities.
e) Measure temperatures
1. OSHA can use the OSHA-NIOSH Heat Safety Tool App as a resource. This App provides current and projected heat indices forthat day at the current location. The App indicates the hazard levelsas: Caution (less than 80°F),Warning (80°F –94°F), Danger(95°For higher), and offers recommended actions to protect workers.
2. OSHA can also use NWS or NOAA advisories as evidence of potentially dangerous heat conditions, Extreme Heat Warning—Take Action! Extreme Heat Watch—Be Prepared!, and Heat Advisory—Take Action!
f) Review any Heat Illness Prevention Plan in place.
Following a review, OSHA may issue Prepared or recommendations for voluntary compliance. They may include:
General Controls - General controls include training, personal protective equipment (PPE), engineering, work practice, and administrative controls, and heat alert and heat illness and prevention programs.
Training - inform workers of the following:
a) Hazards of heat-related illnesses.
b) How to avoid heat-related illnesses by recognizing and avoiding situations that can lead to heat-related illnesses.
c) Recognition of signs and symptoms of heat-related illnesses.
d) First aid procedures.
e) Employer's program to address heat-related illnesses.
f) Advise workers that certain medications and medical conditions can increase risk of heat stress.
g) In addition, alert workers to the dangers of using illegal drugs and alcohol in hot work environments. Illegal amphetamines, such as methamphetamine, are particularly hazardous when heat stress is present.
h) Some conditions, such as pregnancy, fever, gastrointestinal illness, heart disease, and obesity, may increase the risk of heat-related illness. Advise workers to check with their doctors if they have any questions. In some instances, workers with chronic conditions may need extra time to become acclimatized or may need other accommodations, such as more frequent breaks or restricted work.
i) Encourage workers to consult a doctor or pharmacist if they have questions about whether they are at increased risk for heat-related illness because of health conditions they have and/or medications they take.
Personal Protective Clothing and Equipment
a) Hats for work outdoors in the sun.
b) For indoor work, loosely worn reflective clothing designed to deflect radiant heat, such as vests, aprons, or jackets.
c) Cooling vests and water-cooled/dampened garments may be effective under high temperature and low humidity conditions. However, be aware that cooling vests can become an insulator when they reach the body's temperature.
d) In environments where respirator usage is necessary, consult with an industrial hygienist to determine the appropriate clothing to prevent heat stress while still protecting the workers.
Engineering Practice Controls
a) Use air conditioning
b) Increase general ventilation
c) Provide cooling fans
d) Run local exhaust ventilation where heat is produced (e.g., laundry vents)
e) Use reflective shields to block radiant heat
f) Insulate hot surfaces (e.g., furnace walls)
g) Stop leaking steam
h) Provide shade for outdoor work sites.
Administrative and Work Practice Controls
a) Schedule hot jobs for cooler parts of the workday; schedule routine maintenance and repair work during cooler seasons of the year when possible.
b) Provide adequate, cool drinking water on the worksite that is easily accessible and permit employees to take frequent rest and water breaks.
c) Use relief workers and reduce physical demands of the job.
d) Use work/rest schedules.
e) Allow new workers and workers returning from extended absences to get used to hot working environments by gradually increasing their workload.
States with Heat Standards
California – Heat Illness Prevention Title 8 §3395 Outdoor Places of Employment Title 8 §3396 Indoor Places of Employment
Colorado - 7 CCR 1103-15 Heat Illness and Injury Protection
Maryland - 09.12.32 Heat Stress Standards
Minnesota - 5205.0110 Indoor Ventilation and Temperature in Places of Employment
Nevada - R131-24AP Heat Illness Prevention
Oregon - 437-002-0156 Heat Illness Prevention
Washington – Outdoor Heat Exposure Rules: o General industry: WAC 296-62-095 through 09560
Be alert for OSHA inspections. Make sure you have a Heat Illness Prevention Plan that incorporates the controls above as applicable to your work. OSHA has a variety of resources related to heat for your use.See part 2 on OSHA HRI Requirements and Resources .
