OSHA Emphasis on Addressing Heat Hazards is Pretty Cool
On April 8, 2022, OSHA enacted a National Emphasis Program (NEP) to “protect employees from heat-related hazards and resulting injuries and illnesses in outdoor and indoor workplaces” where the heat index surpasses 80°F. The initiative targets more than 70 industries including automotive, warehousing, manufacturing, healthcare, construction, and agriculture. While this may seem daunting, employers have access to many resources to develop and implement programs to protect their employees.
Currently, employers are held accountable for worker safety under the General Duty Clause, Section 5(a)(1) but heat-related hazards present a special, growing challenge that needs to be addressed. As OSHA notes, outdoor temperatures have increased over the past 19 years, and heat is now the leading cause of work-related fatalities related to weather. Indoor workers may be at heightened risk, due to lack of environmental controls, while persons of color, disproportionally employed in high-risk industries, also face increased exposure to heat.
A Heat Illness Program should include the following:
Assessment: Identify hazards by monitoring employees and environmental conditions. Frequently check on your employees when they are starting a new job, or when conditions change in a current job or task. Assess worker responses for signs of illness. Measure heat and humidity to obtain a heat index. Yes, there is an app for that! Search for the NIOSH Heat Safety Tool on your iPhone or Android device to monitor the outdoor index as reported by the National Weather Service, or plug in your own reading to calculate the risk level.
Response: Determine what response is necessary for the identified heat index, the type of work, the condition of your employees, and any special circumstances in the workplace such as the effects of PPE, working at heights, or proximity to hot equipment and products. Utilize the hierarchy of controls to mitigate hazardous conditions.
Training: Implement a training program to recognize heat-related hazards and resulting illness. Provide information on appropriate first aid for heat stress, heat exhaustion, and heat stroke. OSHA's Heat Illness Prevention Campaign provides downloadable training and awareness materials.
Acclimatization: During OSHA's Stakeholders Meeting on Heat-Related Hazards, it was reported that 3 out of 4 heat-related fatalities in the workplace occurred within the first week of employment. Allow workers to ease into the job gradually.
Water-Rest-Shade: These three are key to preventing illness and injury when the heat index rises. Plan to have water and a cooler area available for rest. Adapt work schedules when hotter temperatures are predicted.
OSHA is in the process of developing a new standard for heat injury and illness prevention, and has published an Advance Notice of Proposed Rulemaking. In the meantime, OSHA's National Emphasis Program reminds employers of their continued obligation to provide a safe workplace even beyond the General Duty Clause, and to take proactive steps to reduce the chance for heat-related illness and injury to their workers in any environment, indoors and outdoors.
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