Summary of OSHA’s Proposed Heat Stress Standard 2024
OSHA has released its long awaited, proposed Heat Stress standard. Keep in mind that this isn’t a law (yet), but if passed, it will create significant and complicated new requirements for employers who’s operations expose employees to excessive heat.
Why Has OSHA Released the Proposed Heat Stress Standard?
Let’s begin by reviewing why heat stress is so dangerous and therefore, why OSHA is trying to pass this proposed law.
Heat exposure is the leading killer of all weather related conditions in the US. Heat stress can cause a number of serious medical conditions including heat stroke and even fatalities if not carefully monitored and controlled.
On average, 40-50 workers die every year from heat exposure. In addition, approximately 4000 serious heat related illnesses occur each year.
Keep in mind that these numbers are based on OSHA 300 log submissions for “recordable” events, so the actual number of fatalities and illnesses is much higher.
Heat stress hazards are most prevalent in outdoor industries such as construction, and can be made worse in indoor environments when certain types of equipment are used including furnaces and ovens. Certain groups of workers are also at greater risk including elderly, obese & pregnant workers.
Due to these risks, employers who’s work activities, especially those that occur outdoors or in un-airconditioned environments, must take steps to protect their employees from related harm.
Exclusions and Triggers for the Proposed Heat Stress Standard
Let’s continue by reviewing exceptions and temperature triggers for the proposed law:
- Exclusions to the standard include emergency services, indoor work where air conditioning keeps the temperature below 80º F, remote work, and indoor sedentary work such as sitting, occasional standing and walking, and lifting objects less than 10 pounds. These exclusions ONLY apply if all employee tasks fall within one or more of these exclusions. If some employees do not, then the employer must comply with respect to those work activities that are covered.
- Triggers: Work related temperatures (aka “heat triggers”) also determine applicability as follows: it depends upon whether employees can reasonably be expected to work in temperatures exceeding what OSHA calls the “initial heat trigger.” The initial heat trigger is either a National Weather Service heat index (what the body’s temperature feels like when considering relative humidity and air temperature) of 80º F or a “wet bulb globe temperature” (a temperature measurement accounts for air temperature/humidity/radiant heat and air movement) equal to recommended alert limits set by the National Institute for Occupational Safety and Health (NIOSH). If employees cannot reasonably be expected to work in conditions reaching the initial heat trigger, or if they can only be expected to do so for durations of 15 or less minutes per hour, the standard does not apply to them.
What’s Required in the Proposed Heat Stress Standard?
Now let’s review the law’s compliance requirements, which are extensive and arduous. Keep reading and you’ll see what I mean.
It all begins with development of a company and/or site specific “HIIPP;” Heat Illness and Injury Prevention Plan. The plan must include the following elements:
- A complete list of job tasks and activities covered by the plan
- Written policies and procedures needed to comply with the law
- An identification of the heat metric (“trigger”) the employer plans to use: heat index or wet bulb globe temperature
- A heat monitoring plan
- A heat emergency response plan.
Other HIIPP requirements:
- Employers with 10 or more employees must have a written HIIPP
- Employers must designate one or more “heat safety coordinators” to implement and manage the HIIPP
- Employers must seek the input of non-managerial, front-line employees in the development and implementation of the HIIPP
- Review of HIIPP at least annually or when a recordable heat related event occurs.
- The HIIPP must be made available to all employees in a language that they can understand.
- Employers with outdoor work activities must monitor heat using National Weather Service forecasts and continually measure temperature and heat conditions while working, or if conditions are near trigger points, just assume that the work area is covered by HIIPP.
- Employers with indoor work activities must identify all areas and activities that could trigger the program.
What Must Happen When Heat stress Conditions Trigger?
- Provide drinkable water at a temperature that is cool and in sufficient quantity to provide each affected employee at least 1 quart of water per hour.
- Rest/break areas:
- For outdoor activities, employers most provide shaded areas, natural or artificial but not from equipment, or an enclosed space with air conditioning/moving air.
- Indoor break areas must have either well ventilated and moving air (ie: fans) or air conditioning. Humid work areas may require dehumidifiers.
- Employers must also provide compensation for heat breaks and encourage their use
- Open 2-way communication with affected employees
- If PPE is provided for cooling purposes, it must be properly stored and maintained (as with all PPE).
- Develop procedures to allow employees to be fully acclimated to excessive heat working conditions.
- Communicate to affected employees of high heat conditions and provide water, breaks and procedures for seeking assistance in emergencies
- Carefully monitor for symptoms and signs of heat stress
- Provide at least 15 minute breaks every 2 hours during elevated temperatures
HIIPP Emergency Response Plan Requirements
The proposed Heat Stress Standard’s Emergency Response Plan includes the following requirements:
- Medical care and procedures for providing assistance to employees showing symptoms of heat stress
- Specific directions for emergency responders to the work site address(s)
- Emergency contact telephone numbers
- Procedures describing how employees should contact management or supervisors in the event of need for emergency care
- Procedures for ensuring that emergency responders can reach employees experiencing heat stress symptoms or emergencies
- Designate company staff who are responsible for ensuring that heat stress procedures and controls are implemented when conditions meet triggers.
Other Requirements and Controls
The proposed Heat Standard also includes the following compliance requirements and controls:
- Written procedures for responding to employees showing signs and symptoms of heat stress
- How to monitor for signs of heat stress
- Required first aid
- How to reduce body temperature for affected employees
- How to contact emergency responders
- Development of an employee training program
**This blog post is intended to provide summary guidance regarding OSHA’s proposed Heat Stress Standard, but should not be interpreted as a substitute for the actual Standard. More information can be found on OSHA’s website.”
Although the standard is still early in the review process and is not yet law, due to the extreme hazards created by exposures to heat stress, and the fact that OSHA can currently fine employers who have experienced heat stress events under the General Duty Clause, we highly recommend that affected employers begin building and implementing the standard and an HIIPP as soon as possible.
Also remember the risk of civil lawsuits that impacted employees, or their families, can bring against employers if they’re injured or killed as a result of heat stress exposures.
If the proposed Heat Stress Standard is approved, it will become effective within sixty days and affected employers will have 150 days to become compliant.
