OSHA Proposes Heat Stress Standard

 On July 2, 2024, OSHA submitted a draft version of a new standard: “Heat Injury and Illness Prevention” to the office of the Federal Register for publication. For General Industry, the standard will be designated as 1910.148. For Construction, the standard will be designated as 1926.67. While the final proposed rule may differ somewhat from the draft rule, most of the elements of the draft proposed standard will probably be published in the FR.

Here are key points from the draft proposed heat stress standard:

·       Employers must develop a site-specific Heat Injury and Illness Prevention Plan (HIIPP) for outdoor or indoor workplaces. If the employer has more than 10 employees, the HIIPP must be written.

·       For outdoor workplaces, the HIIPP must include which “heat metric” will be used to assess workplace heat. There are two heat metric choices: the heat index, or the wet bulb globe temperature (WBGT). The heat index can be calculated from ambient temperature and relative humidity measurements or determined by forecasts from the National Weather Service “or other reputable sources.” If heat index or WBGT measurements are utilized, measurements must be obtained at or as close as possible to the work area(s).

·       The heat metric has two components (similar to an Action Level and a PEL). The first component is the “Initial Heat Trigger.” This is a Heat index of 80°F or, if the WBGT is used, a WBGT equal to the NIOSH Recommended “Alert” Limit. The second component is the “High Heat Trigger. This is a Heat index of 90°F or, if the WBGT is used, a WBGT equal to the NIOSH Recommended “Exposure” Limit.

·       The HIIPP must address how:

• New employees will be acclimated to heat and how previously acclimated employees who have been off work will be re-acclimated;
• Cool drinking water will be provided;
• Shade or cool break areas and rest breaks will be provided;
• PPE effectiveness will be maintained if cooling PPE is provided;
• Employees will be trained on the signs and symptoms of heat-related illness and how the employer will monitor for such signs and what emergency response provisions will be established. Supplemental training must be provided if there are indications that an employee has not retained understanding, if there is a heat-related injury or illness, or there are workplace changes. Annual refresher training is required.

·       If the employer conducts on-site measurements of heat (heat index or WBGT), written or electronic records must be retained for 6 months.

Under the direction of John M. Dobby, CIH, CSP, Director, Occupational Health & Safety Services, Carnow, Conibear & Assoc., Ltd. has extensive experience in assisting clients with assessing and developing controls for workplace exposures to excessive heat. John has years of experience assisting clients with evaluating and managing a wide range of occupational health exposures in the private and public sectors. Contact him at jdobby@ccaltd.com if you have any questions or would like assistance with heat or other workplace health and safety concerns.