Heat Stress in the Workplace: OSHA’s Continuing Actions

July 30, 2024|Heat Stress, Industrial Hygiene in the Workplace

By: Ray Chishti, Contributor

In response to the increasing concern regarding heat-related illnesses and fatalities in the workplace, OSHA has taken pro-
active measures by initiating rulemaking activities. The objective is to establish comprehensive guidelines that aim to prevent and mitigate heat stress.

By setting clear requirements for employers across various industries, OSHA’s efforts prioritize worker well-being and emphasize the need for employers to be vigilant in addressing heat-related risks. These guidelines will ensure that adequate protection and safety measures are in place to safeguard workers from the dangers of excessive heat.

Rulemaking Continues into 2024

Weather gurus predict that 2024 will not be immune to record-setting inclement weather, including heat stress. OSHA continues its rulemaking activity around setting a national heat stress prevention standard, as shown in its Fall 2023 Agenda. Heat-stress prevention PPE includes:

Loose-fitting, long-sleeved shirts or pants
Hard hats with a wide brim
Shaded safety glasses
Cooling vests
Cooling towels
Cooling bandanas

OSHA does not have a heat-specific standard—yet! Continuing its multi-year efforts so far, OSHA’s last significant step was on June 20, 2023, by starting Small Business Regulatory Enforcement Fairness Act (SBREFA) meetings. In this process, OSHA presented to small entity representatives (SERs).

The Agency explored different possibilities for various aspects of a heat-specific standard to prevent or decrease heat-related injuries and illnesses in both outdoor and indoor work environments. SERs provided OSHA and the Small Business Advocacy Review (SBAR) Panel input about the rule and how it may affect their workplace and respective industries. The SBAR Panel prepared a report to OSHA on ways to reduce the potential impact of the rule on small entities.

Meetings concluded November 3, 2023. The Agency’s efforts to address heat stress continue into 2024, as it completes its review of the Panel’s report.

National Emphasis Program through 2025

Starting in April 2022, OSHA implemented a National Emphasis Program (NEP) that specifically addresses heat-related hazards in both indoor and outdoor workplaces. This program will be in effect until 2025, with the possibility of an extension.

The NEP aims to enforce regulations by targeting high-hazard industries or activities where heat-related risks are prevalent. This includes industries such as construction, manufacturing, warehousing, beverage distribution, nursing care facilities, grocery wholesalers and hotels.

The NEP expands on previous OSHA initiatives and provides guidelines for inspections. Employers are encouraged to review the NEP to determine if their industry is included in the program. By reviewing the NEP, employers can get a good sense of how OSHA may enforce a future national heat illness rule.

Industrial Hygiene & Heat Stress

Industrial hygiene and heat stress are interconnected in the realm of workplace safety and health. Industrial hygiene focuses on recognizing, evaluating and managing hazards in the workplace to ensure the welfare of employees. Heat stress is one such hazard that industrial hygienists and many safety professionals assess and address to safeguard workers from the detrimental effects of excessive heat exposure. If OSHA finalizes its standard, employers will want to ensure they have qualified persons in their workplace to assist with implementing it.

These professionals play a pivotal role in preventing heat-related illnesses and injuries by implementing measures to minimize heat stress at work. They conduct thorough assessments to gauge the level of heat exposure and evaluate the effectiveness of existing controls, such as ventilation systems, PPE and work/rest schedules. Additionally, they provide recommendations for engineering controls, administrative controls and personal protective measures to mitigate the risks associated with heat stress.

By integrating heat stress management into their comprehensive industrial hygiene programs, employers can foster a safer and healthier work environment. This encompasses strategies like heat stress monitoring; employee training on heat-related hazards; provision of cool drinking water; establishment of shaded rest areas; and adjustment of work schedules to minimize heat exposure during peak temperatures.

In essence, industrial hygiene and heat stress are closely intertwined, as industrial hygienists and safety professionals play a vital role in identifying and managing heat stress hazards in the workplace to safeguard the health and well-being of workers.

Recognizing, Evaluating & Managing Hazards

Monitoring the physiological, medical and exposure levels of workers is essential for preventing heat-related illnesses and fatalities and will be essential for meeting employers’ duties under the proposed rule. By implementing monitoring programs, both employees and employers can be alerted when workers are experiencing heat strain and need to take proper actions, such as seeking water, rest, shade, cooling or medical attention. These monitoring activities can include assessing environmental conditions; self-monitoring urine color; and monitoring heart rate and core body temperature. In some industries, wearable technologies can be used for
individual-level biomonitoring.

To gain more insights into heat-monitoring activities or programs in occupational settings, here are some questions to consider:

What are the best practices for implementing a monitoring program?
How effective are these monitoring activities in preventing heat-related illnesses in workers?
How is exposure, medical or physiological monitoring currently implemented or tracked across various time scales (e.g., hourly, daily) in your occupational setting?
What are the risks or challenges associated with implementing medical or physiological monitoring in the workplace?
Do you currently use physiological or medical monitoring to identify high-risk employees?
Are there any unique concerns or approaches when developing a monitoring program for small businesses compared to large businesses?

Implementing buddy systems and educating workers about the signs and symptoms of heat-related illnesses can also be beneficial. Workers can proactively look for signs and symptoms in their coworkers and encourage them to rest, hydrate, find shade or seek emergency medical attention if necessary.

Cost of Heat Stress Prevention Programs

OSHA remains interested in continuing to understand the positive impacts of reducing injuries, illnesses, deaths and compromised operations in the workplace. This includes not only the physical aspects but also the emotional distress, staffing turnover and unexpected reallocation of resources that can result from such incidents. OSHA is also interested in continuing to assess the overall productivity effects of implementing measures to prevent heat-related issues.

To gather information on this topic, OSHA previously asked questions related to the costs associated with heat-related injuries and illnesses, such as worker’s compensation. The Agency is also interested in continuing to explore the potential benefits of implementing its proposed heat illness rule.

If OSHA publishes a final national heat stress prevention standard, employers should be prepared to implement various preventive measures, including training, breaks, acclimatization or following state rules.

Editor’s Note: See “Newsflash,” page 6, for the latest developments on this topic. IHW

About the Author:

Ray Chishti is a dedicated Workplace Safety Editor at J. J. Keller & Associates, Inc. Ray’s extensive expertise spans over 18 years in diverse sectors, including fossil fuel power plants, utilities, retail establishments, warehousing and college campus construction. Holding a Juris Doctor with a concentration in Occupational Safety and Health, Ray is an authorized OSHA trainer for both general industry and construction.